Privacy Policy

This Privacy Policy explains how SS Group (Pty) Ltd ("Snokonoko", "we", "us") collects, uses, shares and protects your personal information when you use the Snokonoko platform.

We process personal information in accordance with the Protection of Personal Information Act, 2013 ("POPIA"). For the purposes of POPIA, SS Group (Pty) Ltd is the responsible party.

1. Scope

This Policy applies to everyone who uses Snokonoko — borrowers, lenders, and people who have been invited to the platform but have not yet registered. It should be read with our Terms & Conditions, KYC Policy and Acceptable Use Policy.

2. What personal information we collect

Account information

• your first and last name;
• your email address;
• your mobile number;
• your password, which we store only as a cryptographic hash and can never read.

Identity and verification information

• your South African ID or passport number and date of birth;
• government-issued identification documents;
• a selfie or liveness check;
• proof of residential address;
• bank account details and confirmation that the account belongs to you.

We ask for these to verify who you are and to reduce fraud, as described in our KYC Policy. Where a higher risk is identified we may request additional documentation or information about the source of funds.

Loan and transaction information

• the loans you offer, accept, decline or cancel, and their terms;
• the identity of the other party to each of your loans;
• the agreement record created when a loan is accepted, which is permanent and cannot be altered;
• every payment and repayment, including amount, date, method and outcome;
• references and confirmations returned by our payment providers.

Technical information

• your IP address and the approximate location it indicates;
• browser and device information;
• a session cookie that keeps you logged in, and a security cookie that protects forms against cross-site request forgery;
• server logs of your activity on the platform.

We do not use advertising cookies and we do not track you across other websites.

3. How we collect it

Most of it comes directly from you, when you register, complete verification, create or respond to a loan offer, or make a payment. Some comes from third parties: our payment providers tell us the outcome of a payment, and verification services confirm whether the identity or bank details you gave us check out.

If someone offers you a loan before you have registered, we hold their record of your email address so the offer is waiting for you when you sign up. If you never register, that record is deleted with the offer.

4. Why we process it, and on what legal basis

Purpose	Basis under POPIA
Creating and running your account	Performance of our contract with you
Presenting, recording and enforcing loan agreements	Performance of a contract
Processing payments and repayments	Performance of a contract
Verifying your identity and bank details	Legal obligation; our legitimate interest in preventing fraud
Detecting fraud, money laundering and platform abuse	Legal obligation; legitimate interest
Sending transactional notifications and statements	Performance of a contract
Investigating disputes and complaints	Legitimate interest; legal obligation
Keeping records we are required by law to keep	Legal obligation
Improving and securing the platform	Legitimate interest
Marketing, where we do it	Your consent, which you may withdraw at any time

We do not sell your personal information, and we do not make decisions about you by purely automated means that have a legal or similarly significant effect.

5. What the other party to a loan can see

Lending is not anonymous on Snokonoko, and it is not meant to be — the product exists for people who already know each other. When you are party to a loan, the other party sees:

• your name;
• the loan's terms, balance and status;
• each repayment, its amount and its date.

They do not see your ID number, your bank account details, your address, your verification documents or your contact details beyond the email address used to invite you.

6. Who else we share it with

We share personal information only where it is necessary, and only with parties who are bound to protect it. Under POPIA these are our operators, and they may use the information only for the purpose we give it to them.

Recipient	What they receive	Why
Peach Payments	Name, email, payment amount and reference	To process payments and repayments
PayFast	Name, payment amount and reference	To process payments and repayments
Resend	Name and email address	To send transactional email
Vercel	Technical and request data	Application hosting
Neon	All stored platform data	Database hosting

We may also disclose personal information:

• to banks, regulators, or law enforcement where the law requires it or permits it;
• to our professional advisers where they need it to advise us;
• to a purchaser, if our business or part of it is sold, subject to this Policy continuing to apply.

7. Information sent outside South Africa

Some of our service providers store or process information outside South Africa. Where that happens, we transfer personal information only in accordance with section 72 of POPIA — that is, where the receiving country or the recipient's binding contractual commitments provide a level of protection substantially similar to POPIA, or where the transfer is necessary to perform our contract with you.

8. How we protect it

• all traffic to and from the platform is encrypted in transit using HTTPS;
• passwords are stored only as salted cryptographic hashes and are never recoverable;
• session and form-protection cookies are marked secure and are not sent over plain HTTP;
• access to production systems is restricted to people who need it;
• payment card details are never stored on our systems — they are handled by our payment providers, who are PCI-DSS compliant.

No system is perfectly secure. If a breach occurs that creates a real risk to you, we will notify you and the Information Regulator as POPIA requires.

9. How long we keep it

Information	Retention
Account information	While your account is open, then 5 years
Loan agreements and repayment records	5 years from the date the loan is settled or closed
Identity verification records	5 years from the end of the relationship
Dispute and complaint records	5 years from resolution
Server and security logs	12 months
Loan offers to people who never register	Deleted with the offer

The five-year periods reflect the record-keeping obligations that apply to financial transactions in South Africa. We may keep information longer where a dispute, investigation or legal claim is unresolved.

10. Your rights

Under POPIA you have the right to:

• Access — ask what personal information we hold about you and get a copy;
• Correction — ask us to correct information that is inaccurate, misleading or out of date;
• Deletion — ask us to delete information we no longer have grounds to keep;
• Objection — object to processing we carry out on the basis of legitimate interest;
• Withdraw consent — where we rely on your consent, withdraw it at any time;
• Complain — to us, or directly to the Information Regulator.

To exercise any of these, email info@snokonoko.co.za. We will respond within a reasonable period and in any event within the time POPIA allows.

Some information we cannot delete on request: a loan agreement is a permanent record of what two people agreed, and financial records must be retained for the periods above. Where we cannot act on a request, we will tell you why.

11. Our Information Officer

SS Group (Pty) Ltd
Attention: The Information Officer
Email: info@snokonoko.co.za

12. Complaining to the Regulator

If you are not satisfied with how we have handled your personal information or your request, you may complain to:

The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Complaints: complaints.IR@justice.gov.za
General enquiries: enquiries.IR@justice.gov.za

13. Children

Snokonoko is not for anyone under 18. We do not knowingly collect information from children. If we learn that we have, we will delete it.

14. Changes to this Policy

We may update this Policy. The current version is always published here with its version number and effective date, and we will tell you through the platform before a material change takes effect.

15. Contact

SS Group (Pty) Ltd
Product: Snokonoko
Email: info@snokonoko.co.za
Website: www.snokonoko.co.za