PRIVACY POLICY

We, Lazkam Investments cc (“Group,” “we,” “us,” or “our”), including our trading divisions, are committed to safeguarding the privacy of your personal information (“PI”). This Policy (“Policy”) explains how we process your PI, which means, in relation to your PI, various activities including collecting, receiving, recording, storing, updating, using, transferring, or erasing.

This Policy applies to any and all interactions with us where we process PI including your use of any of our websites or mobile applications or engaging with us telephonically or in person and forms part of our website and mobile application terms and conditions. By visiting or using any of our websites or mobile applications, you agree to the terms of this Policy as updated from time to time. We will let you know of any material changes to the Policy.

This Policy applies to all data subjects (persons, whether a natural or juristic person, to whom PI relates) (“you,” “your”), whose PI we collect, regardless of the country where you live or work.

This Policy applies to all PI, whether it was provided to us through our websites, mobile applications, or through any other form of communications with you such as email, telephone, or otherwise (“Channels”), through or by third parties or tools that collect PI.

PI means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including: information relating to race, gender, marital status, ethnicity or social origin, age, disability (mostly as required by labor and credit laws); an identifiable number, e-mail address, physical address, telephone number, identification number, location information, online identifier; biometric information; personal preferences, views or opinions; correspondence of a private or confidential nature; and a name if it appears with other PI relating to you or if disclosing your name itself will reveal information about you. PI can be found in electronic or paper records.

The PI we collect about you is dependent on:

• the transaction you are completing,
• the reason you are communicating with us, and
• the Channel used to communicate with us.

PI may include your name, contact information including email address, postal address, physical address, primary and secondary telephone numbers, date of birth; employment history, criminal history, ethnic origin, language (specifically for employment applications); gender, age, financial information (as required by law, relating to financial services and credit products and services), biometric information (in order for us to identify you when you phone us), billing information, additional information which we are required or permitted by applicable legislation to collect and process, as well as information you elect to share publicly, including on social media and customer forums.

PI excludes:

• information that has been made anonymous so that it does not identify a specific person;
• permanently de-identified information that does not relate or cannot be traced back to you specifically; and
• non-personal statistical information collected and compiled by us.

You must accept all the terms of this Policy when you order any of our products or register for, or use the website, application, or any of our services. By accepting this Policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

The age requirement for engaging with our Channels is 18 years of age. To the extent required by applicable law, users under the age of 18 years of age must obtain parental or guardian consent. We will afford the same level of protection to all PI processed, regardless of the age of the person the PI pertains to.

We collect your PI and only the PI we require for a specific purpose when you:

• voluntarily provide us with information when you interact with us, for example when you send us online enquiries, or you subscribe to or consent to receiving newsletters or other communications from us;
• browse, visit or participate in our various Channels;
• register an online profile on our websites or apps to purchase our products;
• purchase, return, exchange, or enquire about products and services from us;
• agree to the terms and conditions of credit applications and other products and services that contain provisions dealing with the use or disclosure of your PI;
• make general enquiries, lodge complaints, and communicate with us;
• apply for vacancies on our Careers portal by submitting your CV and thereafter should you be employed as an associate of the Group;
• participate in any of our events including competitions where we may also collect photos which could be used in the future;
• visit our offices
• or enter into an agreement with us.

From time to time, we collect your PI from trusted third parties, in which case we will ensure that you have provided your consent for your PI to be disclosed to us.

We do not collect or retain your bank card details used to purchase products or services. Lazkam Investments cc is compliant in terms of PCI DSS. This information is collected by financial institutions that have their own privacy policies. You are advised to never respond to emails that seem to be from us requesting bank card details as this request is most likely fraudulent and should be reported to us immediately.

We do not collect your PI when using cookies about when and how you use our websites, apps, or when you click on an advert of ours that is contained on another website. A cookie is a small text file that is stored on your computer or mobile device when you use it. Cookies hold information such as the identity of the computer or device you used to access our Channels, your server address, domain name, the time and date that you visited our Channels, pages, product, and documentation that you accessed or viewed and which internet browser you used.

We do this so that we can:

• provide you with more personalized service, communication, and products by better understanding your browsing and purchasing behavior;
• track, count, and analyze website visits and usage data;
• understand product preferences and popularity; and
• improve our websites and your online shopping experience.

Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary. You can find out more about cookies at www.allaboutcookies.org.

We use trusted third-party services including Google Analytics that collect, monitor, and analyse our users’ usage. To prevent your PI from being used by Google Analytics you can install an opt-out browser add-on (visit https://tos.google.com/dlpage/gaoptout for details).

Most web browsers can be adjusted to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Refusing a cookie may, in some cases, preclude you from using, or negatively impact, the display or function of our websites or certain areas or features of our websites. You may only send us your own PI or the information of another data subject where you have their permission to do so.