Privacy Policy

1. Introduction

Kaya Club (Pty) Ltd ("Kaya", "we", "us", "our") respects your privacy and is committed to protecting your personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") and the Consumer Protection Act 68 of 2008 ("CPA").

This Privacy Policy explains how we collect, use, process, store and disclose personal information when you interact with Kaya, including when you apply for membership, use our services, visit our website or communicate with us.

By using Kaya's services, you consent to the processing of your personal information in accordance with this Privacy Policy.

2. Personal Information We Collect

We may collect and process the following categories of personal information:

2.1 Information You Provide to Us

When you apply for membership or interact with Kaya, we may collect:

• Full name
• Identity number or passport number
• Date of birth
• Residential and delivery addresses
• Email address
• Mobile number and WhatsApp number
• Photographs or selfie verification images
• Proof of address
• Payment and banking details
• Credit related information
• Brand preferences and style preferences
• Communication records

2.2 Information We Collect Automatically

When you use our website or digital platforms, we may collect:

• IP address
• Device information
• Browser type
• Operating system
• Location data
• Usage behaviour
• Cookies and tracking data

3. How We Use Your Personal Information

We process personal information for the following purposes:

• To verify your identity and conduct KYC and fraud prevention checks
• To assess credit risk and financial eligibility
• To process membership applications and manage your account
• To communicate with you regarding your membership and services
• To provide customer support
• To curate personalised product recommendations
• To process payments and debit orders
• To recover unpaid debts or losses
• To open insurance or legal claims
• To improve our products, services and platforms
• To conduct internal research, analytics and reporting
• To market Kaya products and services
• To develop new products, partnerships and business models
• To comply with legal and regulatory obligations

4. Lawful Basis for Processing

We process personal information on the following lawful bases:

• Your consent
• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests
• Fraud prevention and risk management

5. Information Sharing and Disclosure

We may share personal information with:

• Service providers such as payment processors, insurers, credit bureaus, debt collectors, IT providers and analytics partners
• Verification and fraud prevention services
• Marketing and communication platforms
• Legal advisors, auditors and regulators
• Business partners or affiliates
• Potential buyers or investors in Kaya

We do not sell personal information, but we may disclose information where required to operate our business or pursue legitimate commercial activities.

6. Cross Border Data Transfers

Your personal information may be processed or stored outside South Africa, including in cloud platforms or third party systems.

By using Kaya's services, you consent to such cross border transfers, provided that reasonable security safeguards are in place.

7. Data Security

We implement reasonable technical and organisational safeguards to protect personal information against loss, misuse, unauthorised access, disclosure or destruction.

However, no system is completely secure and you acknowledge that information is shared at your own risk.

8. Data Retention

We retain personal information for as long as necessary to:

• Provide our services
• Comply with legal obligations
• Resolve disputes
• Enforce agreements
• Pursue legitimate business interests

We may retain certain records indefinitely where required for legal, financial or risk management purposes.

9. Your Rights Under POPIA

You have the right to:

• Request access to your personal information
• Request correction or deletion of information
• Object to processing in certain circumstances
• Withdraw consent for marketing communications
• Lodge a complaint with the Information Regulator

Requests may be made in writing to the contact details below.

10. Marketing Communications

By becoming a Kaya member, you consent to receiving communications regarding Kaya products, services and promotions.

You may opt out of marketing at any time by notifying us.

11. Cookies and Tracking

Kaya uses cookies and tracking technologies to:

• Improve website functionality
• Analyse user behaviour
• Deliver targeted marketing
• Support business intelligence

You consent to the use of cookies by accessing our platforms.

12. Changes to This Policy

We may update this Privacy Policy at any time.

Changes will be posted on our website and will take effect immediately.

Continued use of Kaya services constitutes acceptance of the updated policy.

13. Contact Information

If you have any questions or requests relating to this Privacy Policy, please contact: