Privacy Policy
1. DEFINITIONS
In this Policy (as defined below), unless the context requires otherwise, the
following capitalised terms shall have the meanings given to them —
1. “Active Processing” means instances where Lumunous Debt Counselling
has directly been provided with the Personal Information of Data Subjects,
such as when Data Subjects submit an enquiry in respect of its Services, or
when Data Subjects provide Personal Information to Lumunous Debt
Counselling pursuant to concluding any commercial agreement(s) with
Debt Rescue;
2. “Inactive Processing” means instances where Lumunous Debt Counselling
has not actively been provided with the Personal Information of Data
Subjects, such as when Lumunous Debt Counselling deploys Passive
Processing Means to collect information from Data Subjects. These Passive
Processing Means allow Lumunous Debt Counselling to Process certain
kinds of Non-personally Identifiable Information which can perhaps not be
linked to Data Subjects;
3. “Anonymisation” means the Processing of Personal Information in such a
manner that the Personal Information can no longer be attributed to Data
Subjects without the use of additional information, provided that such
additional information is kept separately and is subject to technical and
organisational measures to ensure that the Personal Information are not
attributed to Data Subjects;
4. “Applicable Laws” means any laws applicable to the processing of and
protection of rights associated with Personal Information and includes any
statute, regulation, notice, policy, directive, ruling or subordinate legislation;
the common law; any binding court order, judgement or ruling; any
applicable industry code, policy or standard enforceable by law; or any
applicable direction, policy or order that is given by any regulator,
competent authority or organ of state or statutory industry body;
5. “Biometrics” means a technique of personal identification that is based on
physical, physiological or behavioural characterisation including blood
typing, fingerprinting, DNA analysis, retinal scanning and voice recognition;
6. “Competent Person” means anyone who is legally competent to consent to
any action or decision being taken by any matter concerning a child, for
example a parent or legal guardian;
7. “Consent” means any voluntary, specific and informed expression of will in
terms of which permission is given for the Processing of Personal
Information;
8. “Cookies” means small text files that store Non-personally Identifiable
Information/Data about Data Subjects, either temporarily in connection
with a Data Subjects Internet Protocol (IP) address (known as a temporary
or session cookie and deleted once a Data Subject closes their browser
window) or more permanently on the hard drive of a Data Subject’s device
(known as a permanent or persistent cookie). Lumunous Debt
Counselling’s Website(s) or Mobile Application(s) may from time to time
use session cookies so that Data Subject’s do not have to fill in the same
information from page to page within our Website(s) or Mobile
Application(s). If Data Subject’s elect not to receive cookies, they may be
able to view some, but not all, of the content on our Website(s) or Mobile
Application(s);
9. “Client(s)” means any natural person(s), or juristic person(s), who have
concluded an agreement with Lumunous Debt Counselling in terms of
which such Client procures the Products or Services provided by Lumunous
Debt Counselling;
10. “Data Subject” means Lumunous Debt Counselling’s Client(s) or any Third
Party in respect of whom Lumunous Debt Counselling Processes Personal
Information;
11. “Data Processing Infrastructure” means any and all systems, networks,
servers, workstations, laptops, mobile devices, web applications, mobile
applications, cloud storages, websites owned, controlled or operated by
Debt Rescue;
12. “Embedded Scripts” means, programming code that is designed to collect
information about a Data Subject’s interactions with the relevant
Website(s) or Mobile Application(s). It is temporarily downloaded onto a
Data Subject’s device from our web server or a Third-Party Operator. This
program is active only while a Data Subject is connected to the relevant
Website(s) or Mobile Application(s) and is deleted or deactivated
thereafter;
13. “Electronic Means” means, in relation to the Processing of any Personal
Information, the use of any Website(s), Mobile Application(s), electronic
mail (email), text, voice, sound or image messages by Debt Rescue;
14. “Debt Rescue” means Lumunous Debt Counselling;
15. “Lumunous Group Company” means any company forming part of
Lumunous Group of Companies from time to time;
16. “Non-Electronic Means” means, in relation to the Processing of any
Personal Information, the use of traditional means of Processing, such as
hard copy documents, traditional filing systems deployed for the storage
and retention of Personal Information and face-to-face personal
engagements with Data Subjects;
17. “Mobile Application(s)” means any multi-device software application,
whether in web-based format or device-native format, to which this
Privacy Policy relates and through which Client(s) and Third Parties gain
access to Lumunous Debt Counselling’s Products and/or Services;
18. “Mobile Device Identifier” means device information if you access our
Website(s) or Mobile Application(s) through mobile devices. Certain
features of the relevant Website(s) or Mobile Application(s) may require
collection of mobile phone numbers and we may associate that phone
number with the mobile device identifiers. Additionally, some mobile phone
service providers operate systems that pinpoint the physical location of
devices that use their service. Depending on the provider, Lumunous Debt
Counselling and/or our Third-Party Operators may receive this information.
If Lumunous Debt Counselling associates any such passively collected
information with the Personal Information of Data Subjects, we will treat the
combined information as Personal Information as contemplated in this
Policy;
19. “Non-personally Identifiable Information/Data” means any
information/data which cannot be linked to Data Subjects, such as an
internet domain name, the type of web browser used by a Data Subject,
the type of operating system relied on by a Data Subject, the date and
time of a Data Subject’s visit to our Website(s) and Mobile Application(s),
the specific pages a Data Subject may have visited, and the address of the
website which a Data Subjects may have visited prior to entering or
gaining access to Lumunous Debt Counselling’s Website(s) or Mobile
Application(s);
20. “Operator” means a person or entity who Processes Personal Information
for and on behalf of the Responsible Party, who in the context of the
Website(s) and its associated functionality is IEDM Digital Marketing;
21. “PAIA” means Promotion of Access to Information Act 2 of 2000;
22. “Passive Processing Means” means the use of technologies to facilitate the
Inactive Processing of Personal Information, namely the use of Cookies,
Web Beacons, Embedded Scripts and/or Mobile Device Identifiers;
23. “Person” means any natural person or juristic person;
24. “Personal Information” shall have the same meaning as is given in section 1
of POPIA, which for the avoidance of doubt includes any information
relating to an identifiable, living, natural person, and where it is applicable,
an identifiable, existing juristic person, including, but not limited to:
1. 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;
2. information relating to the education or the medical, financial,
criminal or employment history of the person;
3. any identifying number, symbol, e-mail address, physical address,
telephone number, location information, online identifier or other
particular assignment to the person;
4. the biometric information of the person;
5. the personal opinions, views or preferences of the person;
6. 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;
7. the views or opinions of another individual about the person; and
8. 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; and shall, where applicable,
include Special Personal Information;
25. “Policy” means this Data Protection and Privacy Policy;
26. “POPIA” means the Protection of Personal Information Act, No 4 of 2013;
27. “Processing” means any operation or activity or any set of operations,
whether or not by automatic means, concerning Personal Information,
including:
1. the collection, receipt, recording, organisation, collation, storage,
updating or modification, retrieval, alteration, consultation or use;
2. dissemination by means of transmission, distribution or making
available in any other form by electronic communications or other
means; or
3. merging, linking, blocking, degradation, erasure or destruction. For
the purposes of this definition, “Process” has a corresponding
meaning.
28. “Products” means the various debt counselling services which are
procured by Clients of Debt Rescue;
29. “Regulator” means the Information Regulator established in terms of POPIA;
30. “Responsible Party” means in the context of this Policy, Debt Rescue;
31. “Services” means the various services provided by Lumunous Debt
Counselling to its Client(s), the particulars of which services are clearly set
forth on Lumunous Debt Counselling’s Website from time to time;
32. “Special Personal Information/Data” means Personal Information
concerning, amongst other aspects contemplated in terms of section 26
Part B of POPIA, a Data Subject’s, religious beliefs, race or ethnic origin,
trade union membership, political persuasion, health or sex life, biometric
data, or criminal behaviour;
33. “Third-Party” means any Lumunous Group Company (if applicable),
Client(s), Data Subject(s), employees, independent contractor, agent,
consultant or user of Lumunous Debt Counselling’s Products, Services,
Website or any other digital application interface;
34. “Unique Identifier” means any identifier that is assigned to a Data Subject
and is used by the Responsible Party for the purposes of the operations of
that Responsible Party and that uniquely identifies that data subject in
relation to the Responsible Party;
35. “Website” means the website owned and operated by Lumunous Debt
Counselling sourced at https://debtrescue.co.za;
36. “Web Beacons” means small graphic images called web beacons, also
known as “Internet tags” or “clear gifs,”, which Web Beacons may be
deployed on Lumunous Debt Counselling’s Website(s) pages and e-mail
messages. Web beacons may be invisible to Data Subjects, but any
electronic image inserted into a web page or e-mail can act as a Web
Beacon. Lumunous Debt Counselling may use web beacons or similar
technologies for a number of purposes, including, without limitation, to
count the number of visitors to our Websites, Mobile Application(s), to
monitor how users navigate the Website(s) or Mobile Application(s), to
count how many e-mails that we have sent were actually opened or to
count how many particular articles or links were actually viewed by Data
Subjects in certain circumstances.
2. INTRODUCTION
1. This Policy regulates the Processing of Personal Information by Lumunous
Debt Counselling and sets forth the requirements with which Lumunous
Debt Counselling undertakes to comply when Processing Personal
Information pursuant to undertaking its operations and fulfilling its
contractual obligations in respect of Data Subjects and Third Parties in
general.
2. Lumunous Debt Counselling places a high premium on the privacy of every
person or organisation with whom it interacts or engages with and
therefore acknowledges the need to ensure that Personal Information is
handled with a reasonable standard of care as may be expected from it.
Lumunous Debt Counselling is therefore committed to ensuring that it
complies with the requirements of POPIA and also with the terms of
Applicable Laws.
3. When a Data Subject or Third Party engages with Debt Rescue, whether it
be physically or via any digital, electronic interface such as Lumunous Debt
Counselling Website, the Data Subject or Third Party acknowledges that
they trust Lumunous Debt Counselling to Process their Personal
Information, including the Personal Information of their dependents,
beneficiaries, Clients, members, or employees as the case may be, which
further entrenches the importance of Lumunous Debt Counselling’s
compliance with Applicable Laws in regards to the Processing of Personal
Information.
4. All Data Subjects and Third Parties have the right to object to the
processing of their Personal Information. It should be voluntary to accept
the Terms and Conditions to which this Policy relates. However, Lumunous
Debt Counselling does require the Data Subject’s or Third Party’s
acceptance to enable the proper use of Lumunous Debt Counselling
Website and/or Services.
3. PURPOSE AND APPLICATION
1. The purposes of this Policy are not only to inform Data Subjects of what
Personal Information of theirs Lumunous Debt Counselling may Process,
where Lumunous Debt Counselling may have collected such Personal
Information from (if not directly from them as the Data Subject), how
Lumunous Debt Counselling Processes their Personal Information, but also
to communicate the prevailing standards by which Lumunous Debt
Counselling and its employees, representatives and operators shall
comply in as far as the Processing of Personal Information is concerned.
2. Debt Rescue, in its capacity as a Responsible Party and/or Operator, as the
case may be, shall strive to observe and comply with its obligations under
POPIA and Applicable Laws (as may be applicable and to the extent
necessary) when it Processes Personal Information from or in respect of
any Data Subject.
4. COLLECTING & PROCESSING OF PERSONAL INFORMATION
1. Whenever any Data Subject engages with Debt Rescue, whether it be
physically or electronically, or through the use of its Services, facilities or
Website, Lumunous Debt Counselling will in effect be processing the Data
Subject’s Personal Information.
2. It may be from time to time that Lumunous Debt Counselling has collected
a Data Subject’s Personal Information from other sources and in such
instances Lumunous Debt Counselling will inform the Data Subject by virtue
of any privacy notices it deploys from time to time. In the event that a Data
Subject has shared their Personal Information with any third parties,
Lumunous Debt Counselling will not be responsible for any loss suffered by
the Data Subject, their dependents, beneficiaries, Clients, representatives,
agents or employees (as the case may be).
3. When a Data Subject provides Lumunous Debt Counselling with the
Personal Information of any other Third Party, Lumunous Debt Counselling
will process the Personal Information of such Third Party in line with this
Policy, as well as any terms and conditions or privacy notices to which this
Policy relates.
4. Lumunous Debt Counselling will primarily Process Personal Information in
order to facilitate and enhance the delivery of Products and/or Services to
its Clients, manage and administer its business, foster a legally compliant
workplace environment, as well as safeguard the Personal Information
relating to any Data Subjects which it in fact holds. In such an instance, the
Data Subject providing Lumunous Debt Counselling with such Personal
Information may also be required to confirm that they are a Competent
Person and that they have authority to give the requisite consent to enable
Lumunous Debt Counselling to process such Personal Information.
5. Lumunous Debt Counselling undertakes to process any Personal
Information in a manner which promotes the constitutional right to privacy,
retains accountability and Data Subject participation.
6. Prior to recording the purpose(s) for which Lumunous Debt Counselling
may, or will, process the Personal Information of Data Subjects, Lumunous
Debt Counselling hereby records the broad categories and types of
Personal Information of Data Subjects it may process from time to time:
1. Full names;
2. Identity numbers;
3. Registration numbers;
4. Financial information, including banking account information;
5. Statutory information;
6. Physical and postal address particulars;
7. Telephone numbers;
8. Email addresses;
9. Biometrics;
10. Unique Identifiers.
7. In supplementation of the above and any information privacy notices
provided to any Data Subject from time to time pursuant to any
engagement with them, Lumunous Debt Counselling may process Personal
Information for the following purposes:
1. To provide or manage any information, Products and/or Services
requested by or delivered to Data Subjects in general;
2. To establish a Data Subject’s needs, wants and preferences in
relation to the Products and/or Services provided by Lumunous Debt
Counselling or any other Lumunous Debt Counselling Group
Company;
3. To help Lumunous Debt Counselling identify Data Subjects when they
engage with Debt Rescue;
4. To facilitate the delivery of Products and/or Services to Clients;
5. To allocate to Clients and Data Subjects Unique Identifiers for the
purpose of securely storing, retaining and recalling their Personal
Information from time to time;
6. To maintain records of Data Subjects and specifically Client records;
7. To maintain Third Party records;
8. For recruitment purposes;
9. For employment purposes;
10. For apprenticeship purposes;
11. For general administration purposes;
12. For legal and/or contractual purposes;
13. For health and safety purposes;
14. To monitor access, secure and manage any facilities owned or
operated by Lumunous Debt Counselling regardless of the location;
15. To transact with Third Parties;
16. To improve the quality of Lumunous Debt Counselling’s Services;
17. To transfer Personal Information to any other Lumunous Group
Company so as to enable the relevant Lumunous Group Company to
market its products and/or services to Lumunous Debt Counselling’s
Client(s) or Third Party’s, as well as to render specific services to
Lumunous Debt Counselling itself which would in turn enable
Lumunous Debt Counselling to render its Services to its Client(s);
18. To transfer Personal Information to Third Party service providers so as
to enable Lumunous Debt Counselling to deliver Services to its
Client(s);
19. To analyse the Personal Information collected for research and
statistical purposes;
20. To help recover bad debts;
21. To transfer Personal Information across the borders of South Africa to
other jurisdictions if it is required;
22. To carry out analysis and Client profiling;
23. To identify other products and services which might be of interest to
our Clients and Data Subjects in general, as well as to inform them of
such products and/or services;
24. To comply with any Applicable Laws applicable to Lumunous Debt
Counselling and in some instances other Lumunous Group
Companies.
8. When collecting Personal Information from a Data Subject, Lumunous Debt
Counselling shall comply with the notification requirements as set out in
Section 18 of POPIA, and to the extent applicable, comparable provisions on
other Applicable Laws.
9. Lumunous Debt Counselling will collect and Process Personal Information in
compliance with the conditions as set out in POPIA and/or the Processing
principles in relevant Applicable Laws (as the case may be), to ensure that
it protects the Data Subject’s privacy.
10. Lumunous Debt Counselling will not Process the Personal Information of a
Data Subject for any purpose other than for the purposes set forth in this
Policy or in any other privacy notices which may be provided to Data
Subjects from time to time, unless Lumunous Debt Counselling is permitted
or required to do so in terms of Applicable Laws or otherwise by law.
11. Lumunous Debt Counselling may from time-to-time Process Personal
Information by making use of automated means (without deploying any
human intervention in the decision-making process) to make decisions
about the Data Subject or their application. In these instances, Lumunous
Debt Counselling will take reasonable steps to information Data Subjects
thereof and it is specifically recorded that the Data Subject may object to
or query the outcomes of such a decision.
5. PERSONAL INFORMATION/PERSONAL DATA FOR DIRECT MARKETING PURPOSES
1. Lumunous Debt Counselling acknowledges that it may only use Personal
Information to contact Data Subjects for purposes of direct marketing
where Lumunous Debt Counselling has complied with the provisions of
POPIA and relevant Applicable Laws (where applicable) and when it is
generally permissible to do so in terms of Applicable Laws.
2. In the event that Lumunous Debt Counselling may lawfully direct market to
a Data Subject in terms of section 69 of POPIA, Lumunous Debt Counselling
will ensure that a reasonable opportunity is given to such Data Subjects to
object (opt-out) to the use of their Personal Information for Lumunous Debt
Counselling’s marketing purposes when collecting the Personal
Information and on the occasion of each communication to the Client for
purposes of direct marketing.
6. STORAGE AND RETENTION OF PERSONAL INFORMATION/PERSONAL DATA
1. Lumunous Debt Counselling will retain Personal Information it has
processed in accordance with its prevailing retention policies from time to
time, which retention policies will reflect the justified retention of any
Personal Information in terms of Section 14 of POPIA.
2. Personal Information will only be retained by Lumunous Debt Counselling
for as long as necessary to fulfil the legitimate purposes for which that
Personal Information was collected in the first place and/or as permitted or
required in terms of Applicable Law.
3. It is specifically recorded that any Data Subject has the right to object to
the Processing of their Personal Information and Lumunous Debt
Counselling shall retain and store the Data Subject’s Personal Information
for the purposes of dealing with such an objection or enquiry as soon and
as swiftly as possible.
7. FAILURE TO PROVIDE PERSONAL INFORMATION
1. Where Lumunous Debt Counselling is required to collect Personal
Information from a Data Subject by law or in order to fulfil a legitimate
business purpose of Lumunous Debt Counselling and the Data Subject fails
to provide such Personal Information, Lumunous Debt Counselling may, on
notice to the Data Subject, decline to render services without any liability to
the Data Subject.
8. SECURING PERSONAL INFORMATION
1. Lumunous Debt Counselling will always implement appropriate,
reasonable, physical, organisational, contractual and technological
security measures to secure the integrity and confidentiality of Personal
Information, including measures to protect against the loss or theft,
unauthorised access, disclosure, copying, use or modification of Personal
Information in compliance with Applicable Laws.
2. In further compliance with Applicable Laws, Lumunous Debt Counselling
will take steps to notify the relevant Regulator(s) and/or any affected Data
Subjects in the event of a security breach and will provide such notification
as soon as reasonably possible after becoming aware of any such breach.
3. Notwithstanding any other provisions of this Policy, it should be
acknowledged that the transmission of Personal Information, whether it be
physically in person, via the internet or any other digital data transferring
technology, is not completely secure. Whilst Lumunous Debt Counselling
has taken all appropriate, reasonable measures contemplated in clause
8.1 above to secure the integrity and confidentiality of the Personal
Information its Processes, in order to guard against the loss of, damage to
or unauthorized destruction of Personal Information and unlawful access to
or processing of Personal Information, Lumunous Debt Counselling in no
way guarantees that its security system(s) are 100% secure or error-free.
Therefore, Lumunous Debt Counselling does not guarantee the security or
accuracy of the information (whether it be Personal Information or not)
which it collects from any Data Subject.
4. Any transmission of Personal Information will be solely at the own risk of a
Data Subject. Once Lumunous Debt Counselling has received the Personal
Information, it will deploy and use strict procedures and security features
to try to prevent unauthorised access to it. As indicated above, Lumunous
Debt Counselling reiterates that it restricts access to Personal Information
to Third Parties who have a legitimate operational reason for having
access to such Personal Information. Lumunous Debt Counselling also
maintains electronic and procedural safeguards that comply with the
Applicable Laws to protect your Personal Information from any
unauthorized access.
5. Lumunous Debt Counselling shall not be held responsible and by
accepting any terms and conditions to which this Policy relates, any Data
Subject agrees to indemnify and hold Lumunous Debt Counselling
harmless for any security breaches which may potentially expose the
Personal Information in Lumunous Debt Counselling’s possession to
unauthorized access and or the unlawful processing of such Personal
Information by any Third-Party.
9. PROVISION OF PERSONAL INFORMATION TO THIRD PARTIES
1. Lumunous Debt Counselling may disclose Personal Information to Third-
Party service providers and any Lumunous Group Company where
necessary and to achieve the purpose(s) for which the Personal
Information was originally collected and processed. Lumunous Debt
Counselling will enter into written agreements with such Third-Party service
providers and Lumunous Debt Counselling Group Company, to ensure that
they comply with Applicable Laws pursuant to the Processing of Personal
Information provided to it by Lumunous Debt Counselling from time to
time.
10. TRANSFER OF PERSONAL INFORMATION OUTSIDE OF SOUTH AFRICA
1. Lumunous Debt Counselling may, under certain circumstances, transfer
Personal Information to a jurisdiction outside of the Republic of South Africa
in order to achieve the purpose(s) for which the Personal Information/Data
was collected and Processed including for Processing and storage by
Third-Party service providers.
2. If it is required, Lumunous Debt Counselling will obtain the Data Subject’s
consent to transfer the Personal Information to such foreign jurisdiction.
3. The Data Subject should also take note that, where the Personal
Information is transferred to a foreign jurisdiction, the Processing of
Personal Information in the foreign jurisdiction may be subject to the laws
of that foreign jurisdiction.
11. ACCESS TO PERSONAL INFORMATION
1. A Data Subject has the right to a copy of the Personal Information which is
held by Lumunous Debt Counselling(subject to a few limited exemptions as
provided for under Applicable Law).
2. The Data Subject must make a written request (which can be by email) to
the Information Officer designated by Lumunous Debt Counselling from
time to time and whose contact details can be sourced in Lumunous Debt
Counselling’s PAIA Manual.
3. Lumunous Debt Counselling will provide the Data Subject with any such
Personal Information to the extent required by Applicable Law and subject
to and in accordance with the provisions of Lumunous Debt Counselling’s
PAIA Manual (published in terms of section 51 of PAIA, which PAIA Manual
can be sourced either at Lumunous Debt Counselling’s premises upon
request or on Lumunous Debt Counselling’s Website.
4. The Data Subject can challenge the accuracy or completeness of
his/her/its Personal Information in Lumunous Debt Counselling’s records at
any time in accordance with the process set out in Lumunous Debt
Counselling’s PAIA Manual.
12. KEEPING PERSONAL INFORMATION ACCURATE
1. Lumunous Debt Counselling will take reasonable steps to ensure that
Personal Information that it Processes is kept updated where reasonably
possible. For this purpose, Lumunous Debt Counselling shall provide Data
Subjects with the opportunity to update their information at appropriate
times.
2. Lumunous Debt Counselling may not always expressly request the Data
Subject to verify and update his/her/its Personal Information and expects
that the Data Subject will notify Lumunous Debt Counselling from time to
time in writing:
1. of any updates or amendments required in respect of his/her/its
Personal Information;
2. where the Data Subject requires Lumunous Debt Counselling to
delete his/her/its Personal Information; or
3. where the Data Subject wishes to restrict the Processing of his/her/its
Personal Information.
13. COSTS TO ACCESS PERSONAL INFORMATION/PERSONAL DATA
1. In the event that a cost is applicable, the prescribed fees to be paid for
copies of the Data Subject’s Personal Information are listed in Lumunous
Debt Counselling’s PAIA Manual.
2. Lumunous Debt Counselling reserves the right to make amendments to
this Policy from time to time.
14. COMPLAINTS TO THE INFORMATION REGULATOR
1. If any Data Subject or Third Party is of the view or belief that Lumunous
Debt Counselling has Processed their Personal Information in a manner or
for a purpose which is contrary to the provisions of this Policy, the Data
Subject is requested to first attempt to resolve the matter directly with Debt
Rescue, failing which the Data Subject or Third Party shall have the right to
lodge a complaint with the Information Regulator, under the provisions of
POPIA.
2. The current contact particulars of the Information Regulator are:
The Information Regulator (South Africa)
Website: https://www.justice.gov.za/inforeg/index.html
JD House 27 Stiemens Street Braamfontein Johannesburg, 2001
PO Box 31533
Braamfontein, Johannesburg, 2107
15. CONTACTING US
1. All comments, questions, concerns or complaints regarding Personal
Information or this Policy, should be forwarded to Lumunous Debt
Counselling’s Information Officer at the following email address
– reception@lumunous.co.za.