Privacy Policy
TODO(legal): review for POPIA compliance before publishing.
Last updated: April 2026
1. Introduction
At Adwells Group we value your privacy and are committed to protecting and responsibly processing your personal information.
This Privacy Policy sets out our principles and basic conditions for processing personal information, as well as the measures we have taken to ensure its security.
This Privacy Policy applies to our website https://creditgenius.co.za, as well as to our marketing communications related to the promotion of our services.
2. Contact details of the responsible party
Adwells Group OÜ (registration no. 17379392) (hereinafter “Adwells Group” or “we”) is the responsible party for the personal information we process, unless otherwise stated.
There are several ways to contact us, including by email or post.
Postal address: Aiandi tn 13/1, Tallinn 12918, Estonia
Email: hello@creditgenius.co.za
3. What information do we process, for what purposes, on what lawful basis, and for how long?
We act as the responsible party in respect of your personal information. This means we independently determine the purposes for which it is processed and select the corresponding processing services and tools.
| Data subject | Purpose | Personal information used | Source of personal information | Lawful basis under POPIA |
|---|---|---|---|---|
| Client | To confirm that the data subject is 18 or older (preliminary loan-application service to credit providers) | Date and year of birth | Directly from you | Performance of a contract |
| Client | To provide loan-application preparation services and submit the application to partner credit providers for a decision on approval or decline (preliminary loan-application service to credit providers) | Identity details: • Full name, • Date and year of birth, • SA ID number or passport number, • Gender. Contact information: • Email address, • Phone number, • Postal code, • Province, • City, • Street, • Street number, • Unit/flat number. Financial information: • Loan amount and purpose, • Income amount, • Source of income, • Monthly expenses, • Monthly housing payment, • Household income, • Household expenses, • Bank account number. Employment details: • Job title, • Employer name, • Employer industry, • Employment start date. Personal and family details: • Gender, • Marital status, • Number of dependants, • Housing status, • Housing contract start date. Education: • Educational details. Other financial obligations: • Information about other loans, • Amounts of other loans | Directly from you, or from third parties: partners — affiliates (when you use third-party loan-application services) | Performance of a contract |
| Client | To communicate the preliminary decline or approval of a loan application (preliminary loan-application service to credit providers) | Information about the preliminary decline or approval of a loan application | From third parties: partners — credit providers, credit intermediaries | Performance of a contract |
| Client | To compare and present to the client the credit offers obtained on their behalf (preliminary loan-application service to credit providers) | Information about the preliminary decline or approval of a loan application | From third parties: partners — credit providers, credit intermediaries | Performance of a contract |
| Client | To redirect the client to the credit provider for further processing of the selected loan (preliminary loan-application service to credit providers) | Information about the partner website to which the client/user is redirected; information about the preliminary decline or approval of a loan application | Generated when you interact with our website; from third parties: partners — credit providers, credit intermediaries | Performance of a contract |
| Client, User | To promote partner credit offers through the credit-offer showcase (preliminary credit-offer showcase service) | Click ID; information about the partner website to which the client/user is redirected | Generated when you interact with our website | Legitimate interest in maintaining or developing partnerships that provide business stability and additional value for users and clients |
| Client | To notify you of service progress via email, SMS or WhatsApp (preliminary loan-application service to credit providers) | Email address; phone number | Directly from you | Legitimate interest in improving service quality and in concluding and performing the contract with the client more efficiently |
| Client | To process a customer support request | Full name; email address; phone number; any other details you provide at your discretion or that the support team requests at its discretion | Directly from you | Performance of a contract |
| Client | To provide client feedback | Full name; email address; phone number; client feedback | Directly from you | Legitimate interest in receiving feedback and improving our service based on that feedback |
| Client, User | To manage and improve the client experience through better understanding of clients | Client ID; A/B test indicators; information about the partner website to which the client/user is redirected; action information; IP address; device ID, device type and model, mobile operating system (OS); information about the partner website from which the client/user was referred; information about credit offers received through the service | Generated when you interact with our website; received from your browser; received from third parties: partners — credit providers, credit intermediaries, and affiliate partners | Legitimate interest in improving the quality of our products and solutions |
| Client, User | To promote products and services through email marketing, push notifications, SMS and WhatsApp | Email address; phone number; push notification token | Directly from you; received from your browser | Consent |
| Client, User | To personalise advertisements | Advertising identifier | Received from your browser | Consent |
| Client, User | To ensure security and prevent fraudulent activity | IP address; device ID, device type and model, mobile operating system (OS) | Received from your browser | Legitimate interest in ensuring the security of our systems |
| Client, User | To protect our legitimate rights and the rights of third parties, to resolve disputes and legal claims | Information provided by you as part of the legal claim | Directly from you | Legitimate interest in protecting our rights and resolving disputes |
If you do not provide personal information whose processing is based on the performance of a contract, we will be unable to provide you with the service (preliminary loan-application service to credit providers) in accordance with the Terms of Use.
Why do we need a specific set of personal information?
We receive from our partners (credit providers and credit intermediaries) the required categories of personal information they need to make an appropriate decision about granting a loan. We need this set of personal information in order to submit it to partner credit providers and credit intermediaries and to receive their decision on approval or decline.
4. How long do we retain personal information?
We process your personal information until the purpose for which it was collected has been achieved.
5. Automated decision-making
We do not use automated decision-making, nor do we use your personal information to automatically evaluate aspects of your personality (automated profiling).
6. With whom do we share your personal information?
When we transfer personal information to third parties, we ensure that they have sufficient safeguards in place to implement appropriate technical and organisational measures. We transfer personal information to third parties with whom we have concluded appropriate agreements containing the required obligations relating to the protection of personal information.
When we need to transfer personal information to a third country, we transfer it to a country that ensures an adequate level of protection.
If we transfer data to a third country that does not ensure an adequate level of protection, we implement appropriate protective measures. In addition, we conduct a Transfer Impact Assessment (TIA) to evaluate the possibility of transferring personal information to third parties abroad.
We monitor compliance with personal information processing principles and the application of appropriate security measures by third parties. We ensure that cross-border transfer of personal information is limited to the purposes for which the data was collected.
The categories of companies to which data is transferred are set out below.
1. IT solution provider whose services we use for sending marketing emails
Country — Ireland
| Data subject | Purpose of transfer | Third-party role | Basis for engagement with third party |
|---|---|---|---|
| Client | To send marketing emails | Operator | Contract incorporating security measures |
2. IT hosting provider for the website
Country — USA (commercial organisation participating in the EU-US Data Privacy Framework), Belgium
| Data subject | Purpose of transfer | Third-party role | Basis for engagement with third party |
|---|---|---|---|
| Client, User | To operate the website | Operator | Contract incorporating security measures |
3. IT solution providers whose services we use for cookie analytics
Country — USA (commercial organisation participating in the EU-US Data Privacy Framework)
| Data subject | Purpose of transfer | Third-party role | Basis for engagement with third party |
|---|---|---|---|
| Client, User | Cookie analytics for business purposes | Operator | Contract incorporating security measures |
4. Partners — credit providers and credit intermediaries
Country — South Africa and other countries where our partners are registered
The full list of partners (credit providers and credit intermediaries) is available here.
| Data subject | Purpose of transfer | Third-party role | Basis for engagement with third party |
|---|---|---|---|
| Client | To provide credit offers to the client | Responsible party | Contract incorporating security measures |
7. Your rights
Under the Protection of Personal Information Act, 2013 (POPIA), you have the following rights in respect of your personal information:
Access
You have the right to obtain from us the following information:
- the purposes for which the information is processed;
- the categories of personal information involved;
- the recipients or categories of recipients to whom the personal information has been disclosed;
- the period for which the personal information will be stored, or the criteria used to determine that period;
- the existence of the right to request correction or deletion of personal information or to object to the processing of personal information;
- the right to lodge a complaint with the Information Regulator (South Africa);
- if the personal information was not collected from you, any available information about its source;
- the existence of automated decision-making, including profiling;
- the appropriate safeguards relating to cross-border transfers.
Correction
You have the right to request correction of inaccurate personal information about you. Taking into account the purposes of the processing, you also have the right to have incomplete personal information completed, including by way of a supplementary statement.
Deletion
You have the right to request the deletion of personal information about you without undue delay.
Restriction
You have the right to request restriction of the processing of your personal information.
Portability
You have the right to receive your personal information in a structured, commonly used and machine-readable format, and to transmit that information to another responsible party without hindrance, where technically feasible.
Objection
You have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal information about you that is based on legitimate interest or public interest. We will not process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
Withdrawal of consent
Where we process your personal information on the basis of consent, you have the right to withdraw your consent at any time. To exercise your right to withdraw consent, please contact us.
Lodging a complaint
Under POPIA you have the right to lodge a complaint with the Information Regulator (South Africa) if you believe your personal information has been processed in a manner that does not comply with POPIA.
Contact details — Information Regulator (South Africa):
Website: www.inforegulator.org.za
Email: inforeg@justice.gov.za
To exercise any of these rights, or if you have any questions about the protection of your personal information, please contact us at hello@creditgenius.co.za.
You may opt out of our marketing communications at any time by sending us a message at hello@creditgenius.co.za or by using the unsubscribe link we provide in our emails.
8. How is this document updated?
If there are material changes to this Privacy Policy, we may use any available means (push notifications, SMS or email) to notify you. This would be the case, for example, if we add new categories of personal information to be processed or new purposes for which the information is processed. You will be notified before any such changes take effect.
