Privacy Policy

Ubuntu Life (Pty) Ltd (“Ubuntu Life”, “we”, “us” and “our”) respects your right to privacy, security and online safety and we will only process, collect, use and retain your personal information in accordance with this Policy. We take our responsibility to protect your personal information very seriously and therefore this policy explains how we collect, use, share, protect and process your personal information, as required by the Protection of Personal Information Act 4 of 2013 (POPIA).

Defined terms and the general terms of use will have the same meaning in this policy.

Definitions

“Personal Information” means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:

• Information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
• Information relating to the education or the medical, financial, criminal or employment history of the person;
• Any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
• The biometric information of the person;
• The personal opinions, views or preferences of the person;
• Correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
• The views or opinions of another individual about the person; and
• The name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.

“Policy” means this Privacy Notice and Policy.

“Processing” means any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including:

• The collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation, or use;
• Dissemination by means of transmission, distribution or making available in any other form; or
• Merging, linking, as well as restriction, degradation, erasure, or destruction of information.

Why Ubuntu Life Requires Your Personal Information

Ubuntu Life may have to process some of your personal information in order to provide you with our insurance products and services as well as to provide servicing to you. This information is also used by us to support your interaction with Ubuntu Life and to contact you to respond to your query, complaint or request for information.

Your personal information is gathered through channels we use to distribute, communicate and deliver our products. We only use service providers we trust, and who have agreed to keep your data secure and confidential.

We only process information to establish and verify our customers’ identity in terms of the Applicable Laws; to enable Ubuntu Life to fulfil its obligations in terms of your insurance policy which includes but not limited to policy servicing, premium collection, claims management, required communication; to enable Ubuntu Life to offer other products and services to you; to enable Ubuntu Life to take the necessary measures to prevent any suspicious or fraudulent activity in terms of the Applicable Laws; and reporting to the relevant Regulatory Authority/Body, in terms of the Applicable Laws. We will only process this personal information with your consent.

These details will be used only by our staff, our agents and third-parties sub-contracted by Ubuntu Life. Due to the nature of our business, at times we use other third parties such as service providers and administrators who in turn process your personal information.

Ubuntu Life only processes personal information of children with the consent of a parent or guardian. You may not provide personal information to us if you are under the age of 18.

If you are providing information on behalf of a spouse, dependent, parent, extended family, or child, you confirm that you are authorised and have the necessary consent to provide this personal information to us for processing.

If you have opted for Ubuntu Life to communicate with you, we will notify you electronically of changes or additions to our service offering and send you relevant news and information from time to time. You can opt out of these communications at any time by contacting us at info@ubuntulife.co.za. Information collected, including, but not limited to, industry, product type and location, may be aggregated for business development and research purposes. The information used in this way will not be personally identifiable or linked to individual users in any way.

You have the right to object to the processing of your personal information but in order for Ubuntu Life to engage with you in order to activate and service your policy and benefits, it is required that you accept the terms in this policy.

Face Data and Biometric Verification

During policy signup, the Ubuntu Life app collects face data. The face data we collect is a still facial image captured while you complete a liveness check. We use that image to confirm that a live person is present. We do not collect a three-dimensional face map or facial geometry. We do not use face data for advertising, marketing, profiling, or to train models.

We use this face data only to verify your identity before we issue a funeral policy. The check confirms that you are the person shown on the identity document you provide, and that your face matches government identity records. We also keep the facial image as part of the customer due-diligence record for your policy, so that we can meet our obligations as a financial services provider, service the policy, manage a claim, and prevent fraud.

We share the facial image with our identity verification providers solely so they can perform the liveness check and the biometric match and return a verification result to us. Those providers do not retain your face data after the verification is complete. We do not sell face data, and we do not share it with any other third party for marketing. Our staff, agents, and contracted administrators may access the stored image only to service your policy, handle a claim, prevent fraud, or meet a legal or regulatory request.

We store the facial image on our systems in South Africa, together with your policy record. We retain the facial image for 5 years, because a financial services provider in South Africa must keep customer due-diligence records for that period. When the retention period ends, we delete the facial image. You may ask us to delete it sooner by contacting us at info@ubuntulife.co.za. We will delete it unless a law requires us to keep the record.

If you use Face ID, a fingerprint, or another device biometric to unlock the app, that check is performed by your device operating system on the device. We do not receive, store, or transmit that device biometric data.

Cookies

A cookie is a small text file that is stored onto a hard drive or smartphone when you access a website and is typically used to identify returning visitors, and to collect aggregate information on the number of visitors to a site, the number of pages viewed and which products you viewed. You can choose to prevent the site from storing cookies on your hard drive by disabling cookies in your browser options. Cookie information is used only by Ubuntu Life and our agents and is not provided to any other organisation.

Other Data

From time to time we may collect information such as click data and page-view statistics, the name of the internet service provider and the IP address through which you access our site, the date and time you access the site, the pages that you access while at the site, and the internet address of the website from which you navigated to our site. This information is not personally identifiable and is used in aggregate for website and system administration, traffic, trend analysis and business decision-making.

Sharing Personal Information

Ubuntu Life may share your personal information for further processing with third party service providers, agents, contractors, employees, law enforcement agencies or business affiliates. Personal Information will only be shared in a justified manner and in order to comply with a regulatory requirement in terms of legislation or during a legal process or for a legitimate business requirement. Such third parties have an obligation to keep your personal information secure and confidential.

This will include information shared with:

• Payment processing service providers, merchants, banks and other persons that assist with the processing of payment instructions;
• Law enforcement and fraud prevention agencies and other persons tasked with the prevention and prosecution of crime;
• Regulatory authorities, industry ombudsmen, governmental departments, local and international tax authorities;
• Credit Bureaus;
• Service providers, agents and sub-contractors that Ubuntu Life has contracted with to offer and provide products and services; and
• Persons to whom we cede our rights or delegate our authority to.

Ubuntu Life will only send personal information outside of South Africa, for further processing and storage, in adherence with the requirements in section 72 of POPIA. Currently, data is being stored and processed in South Africa for the purpose of cloud storage, monitoring of our systems and administering policies.

Correction and Access to Information

You have an obligation to advise us if any of your personal information that is held by Ubuntu Life changes or is invalid, to ensure that our records are updated. Any changes can be sent to info@ubuntulife.co.za.

The Promotion of Access to Information Act (PAIA) together with POPIA provides an individual the right to access information that is held by a public or private body in certain instances. This right can be exercised as provided for in the Ubuntu Life PAIA Manual.

Agreement

By using this website, you indicate your acceptance of our Privacy Policy. Your continued use of the website following the posting of changes to these terms will be taken to mean that you accept those changes.

If you feel that we are not living up to our stated Privacy Policy, or if you have any questions about this Privacy Policy, please contact us at info@ubuntulife.co.za or call 087 551 3306.