1. Who We Are
Your personal information is collected by THUNDERLINES, Lda., trading
as luum. digital, Portuguese tax number 516424939, with its registered
office at Rua Jaime Moniz, n.º 12, Edifício Krypton III, Bloco 1, R/C A,
9060-343 Funchal, Portugal ("luum. digital", "we", "us").
luum. digital collects your information as an
operator on behalf of [Client Legal
Name], registration number [CIPC registration
number], [an authorised financial services provider, FSP
number [number],] with its address at 79 Roeland Street, Cape
Town, 8001, South Africa, trading as get-insured.co.za (the
"Company").
The Company is the responsible party for your
personal information. It decides why and how your information is
processed and is responsible for complying with the law. Your
information is shared only with the Company, which will
contact you about your car insurance request. We do not sell, share or
pass on your information to anyone else.
2. Applicable Law
Your personal information is processed in accordance with the
Protection of Personal Information Act 4 of 2013 ("POPIA"). Because
luum. digital is based in the European Union, our processing is also
subject to the General Data Protection Regulation (Regulation (EU)
2016/679, "GDPR").
We process your personal information lawfully and reasonably, only
for the specific purposes described in this Policy, limited to what is
necessary, kept accurate and up to date, kept secure, and retained only
for as long as needed.
3. Information We Collect
With your consent, we collect:
Identity and contact details: first name and
surname, mobile phone number, email address and date of birth.
Information about your request: whether you own
a car, whether you currently have car insurance, your current insurer,
your current type of cover and how much you currently pay.
Technical information: IP address, approximate
location, browser and device type, operating system, pages visited, and
the date and time of your visit.
Consent record: the date, time, IP address, page
and version of the consent text you accepted, as described in section
8.
If you complete a Meta (Facebook or Instagram) lead form, we receive
from Meta the information you entered in that form.
4. Why We Use Your Information
We use your information to:
pass your request to the Company so that it can contact you by
phone, SMS or email with car insurance quotes and information about its
products and services;
automatically check, before passing on your request, that your
phone number and email address are valid;
pre-fill the country flag and dialling code in the form, based on
your IP address and approximate location;
record and prove your consent;
prevent fraud, fake submissions and misuse of the form.
We process your information on the basis of your
consent (POPIA section 11(1)(a) and section 69; GDPR
article 6(1)(a)). Pre-filling the form, recording your consent and
preventing fraud are also based on our legitimate interest in making the
form easy to use, demonstrating compliance and protecting the form
against misuse.
The automatic check of your phone number and email only confirms that
they exist. No decision that has legal or similarly significant effects
on you is made solely by automated means.
5. Who We Share Your Information With
The Company, identified in section 1, as the
responsible party.
Service providers acting as our operators, such
as hosting, phone and email verification, consent recording, CRM and
lead delivery providers. They are contractually bound to process your
information only on our instructions and to keep it secure.
Meta Platforms Ireland Limited, when you use
Meta lead forms or accept Meta cookies, under Meta's privacy
policy.
Regulators and authorities, where required by
law.
Access to your information is limited to authorised staff of these
parties.
6. Cross-Border Transfers
luum. digital is based in Portugal, so your information is
transferred to and processed in the European Union before it is
delivered to the Company in South Africa. The European Union has data
protection laws, including the GDPR, that provide an adequate level of
protection as required by section 72 of POPIA. Some platforms we use,
such as Meta, may process information in other countries under their own
legal safeguards.
7. How Long We Keep Your Information
luum. digital keeps your information for 6 months after it is
collected. The Company undertakes to delete it within a maximum period
of 24 months, unless a longer period is required by law or you become
its client.
If you withdraw your consent, your information is deleted sooner,
except for the record of your consent and your opt-out, which we keep
for as long as needed to demonstrate compliance and to respect your
opt-out.
8. Record of Your Consent
To prove that you gave your consent, we record the date and time you
submitted the form, your IP address, the page, and the version of the
consent text and this Policy that you accepted. This record may be
shared with the Company to show that it was allowed to contact you.
9. Cookies, IP Address and Location
This site uses cookies that are necessary for it to work. With your
consent, it also uses analytics and advertising cookies, including the
Meta Pixel, to measure and improve our campaigns. These may record your
IP address, browser type, pages visited, and the date and time of your
visit. You can accept, refuse or withdraw consent to non-essential
cookies at any time through the cookie banner or your browser
settings.
We use your IP address and approximate location only to automatically
set the country flag and dialling code in the contact form. We do not
store your location or use it for any other purpose.
10. Minimum Age
By accepting this Policy, you confirm that you are 18 years of age or
older. We do not knowingly collect information from children. If we
learn that we have, we will delete it.
11. Your Rights
Under POPIA, you have the right to:
ask whether we hold personal information about you and request
access to it;
ask for your information to be corrected or deleted if it is
inaccurate, irrelevant, excessive, out of date, incomplete, misleading
or unlawfully obtained;
object to the processing of your information, including at any
time to direct marketing;
withdraw your consent at any time, without affecting processing
that took place before you withdrew it;
be notified if your information has been accessed or acquired by
an unauthorised person;
lodge a complaint with the Information Regulator (South Africa),
at www.inforegulator.org.za.
To exercise these rights, contact the Company at
[email protected], or luum. digital using the details in section
15. We may ask you for information to confirm your identity. Requests
for access may also be made under the Promotion of Access to Information
Act (PAIA), as set out in the Company's PAIA manual.
12. How to Stop Being Contacted
You can stop being contacted at any time by telling the person who
contacts you, replying STOP to an SMS, using the unsubscribe link in any
email, or emailing [email protected]. Every marketing message from
the Company will include a way to opt out.
13. Security
We use appropriate technical and organisational measures to protect
your information against loss, damage, unauthorised destruction and
unlawful access or processing. If your information is compromised, you
and the Information Regulator will be notified as required by section 22
of POPIA.
14. Changes to This Policy
We may update this Policy from time to time, for example because of
changes in the law. The current version is always available on this
page.
15. Contact Details
Responsible party
[Client Legal Name] (get-insured.co.za)
Registration number: [CIPC registration number]
[FSP number: [number]]
Address: 79 Roeland Street, Cape Town, 8001, South Africa
Email: [email protected]
Website: get-insured.co.za
Information Officer of the responsible
party
[Name], [email protected], [phone]
Operator
THUNDERLINES, Lda. (luum. digital)
Tax number (Portugal): 516424939
Address: Rua Jaime Moniz, n.º 12, Edifício Krypton III, Bloco 1, R/C
A, 9060-343 Funchal, Portugal
Email: [email protected]
