“Affordable pricing and protection”

Privacy Statement


1. Introduction
Atlehang Life (“the Company”, “we”, “our”, “us”) subscribe to the provisions of the Protection of Personal Information Act No 5 of 2013 (POPIA) and therefore respects the right to privacy and confidentiality of your Personal Information (as defined in the POPIA) and is committed to protecting your privacy and to ensure that your Personal Information is collected and used properly, lawfully and transparent. Under the provisions of the POPIA, we are required to explain to our suppliers why we collect information about you; how we intend to use that information; how we will safeguard it; how long we will keep it; how we will destroy it; and whether we will share your information with anyone else. Your Personal Information will be treated in a secure and confidential manner and only as set out below or otherwise notified to you in writing and in accordance with this Privacy Statement.

2. What is Personal Information
Personal Information is defined by the POPIA as information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to-

(a) 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;
(b) information relating to the education or the medical, financial, criminal or employment history of the person;
(c) any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
(d) the biometric information of the person;
(e) the personal opinions, views or preferences of the person;
(f) 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;
(g) the views or opinions of another individual about the person; and
(h) 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;

A person to whom the Personal Information relates is called the Data Subject.

3. What type of Personal Information do we collect?
The Personal information that is collected by Atlehang Life from the Data Subject can include; Personal Details – name, identity number, age, gender, date of birth, nationality, occupation, lifestyle, the current status of health, medical history and any existing conditions of each person insured.

Contact information – email address, phone number, physical and postal address.

Online information
– for example, cookies and IP address (your computer’s internet address), if you use our websites, apps and/or social media channels.

Financial information
– banking details, information regarding your income, expenses, assets, liabilities, investments, retirement and other financial provisions in the context of providing financial advice and intermediary services.

Contractual information
– details about the policies you hold and with whom you hold them.

3.1 How we process your Personal Information
Atlehang Life will process your Personal Information lawfully and in a manner that does not infringe on the privacy of the data subject. Your Personal Information will only be processed for the purpose set out in paragraph 4 below and your Personal Information will only be processed if the data subject or a competent person if the data subject is a child consent to the processing. Atlehang Life will treat the information as private and confidential and will not share your Personal Information without your consent.

4. Why do we process your Personal Information?
Atlehang Life (Pty) Ltd is a licensed micro-insurance company and an authorised financial services provider. In order to provide financial services and services that are required by clients, it has to process the Personal Information as mentioned in paragraph 3 above.

Section 1 of the POPIA defines Processing as any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including-

(a) the collection, receipt, recording, organisation, collation, storage, updating or
modification, retrieval, alteration, consultation or use;
(b) dissemination by means of transmission, distribution or making available in any other
form; or
(c) merging, linking, as well as restriction, degradation, erasure or destruction of
The Personal Information that you give to us will be used for the following purposes as permissible by the applicable laws and as it relates to the rendering of financial services to you-
(d)to provide you with our financial products and services, and maintain our relationship
with you;
(e) to provide you with financial advice and intermediary services;
(f) to conclude and administer your application, which may include underwriting;
(g) to execute a transaction in accordance with your request;
(h) to assess, check, and process claims;
(i) to meet our contractual obligations with you or take steps necessary for the conclusion
of a contract with you;
(j) for reporting to regulatory authorities including applicable industry codes of conduct,
in compliance with applicable laws, (including the Financial Sector Conduct
Authority, Prudential Authority and Financial Intelligence Centre);
(k) to undertake credit reference searches and/or verification when establishing
(l) for the identification and prevention of unlawful activity, fraud, money laundering
and loss, including as part of party due diligence required under applicable laws and
in terms of our internal processes;
(m) to record and/or monitor and have access to your telephone calls (i.e. voice
recordings), correspondence and electronic communications to/with us (or any of our
employees, agents or contractors) in order to accurately carry out your instructions
and requests, to use as evidence and in the interests of crime prevention;
(n) for audit and record-keeping purposes;
(o) for purposes of proof and legal proceedings;
(p) to enhance your experience when interacting with Atlehang Life and to help us
improve our financial services to you;
(q) to conduct market research and provide you with information about our products and
services from time to time via email, telephone or other means (for example, invite
you to events); and
(r) for any purpose related to and compatible with the above.

5. Special Personal Information
Atlehang Life may process Personal Information falling into a Special Personal Information category as per section 26 of the POPIA, however, such processing is subject to the provisions of the POPIA. Special Personal Information includes information concerning-

(a) the religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life or biometric information of a data subject; or
(b) the criminal behaviour of a data subject to the extent that such information relates

(i) the alleged commission by a data subject of any offence; or
(ii) any proceedings in respect of any offence allegedly committed by a data subject or the
disposal of such proceedings.
Atlehang Life will only process your Special Personal Information under the following
(a) if you have consented to the processing thereto.
(b) if the processing is needed to create, use or protect a right or obligation in law.
(c) if the processing is for statistical or research purposes.
(d) if the special personal information was made public by you.
(e) if the processing is required by law.
(f) if racial information is processed and the processing is required to identify you.

6. How does Atlehang Life collect your Personal Information?
The collection of Personal Information takes the following form

6.1 Sales Stage – application form that you will complete either in full or partially at the sales stage whether in person or electronically.
6.2 Claims Stage – claim form that you will complete in person or electronically.
6.3 Third Party – applications made through our intermediaries who render financial services on our behalf.
6.4 Collection by Third Parties Atlehang Life uses certain social networking services such as Facebook, LinkedIn, and Twitter to communicate with the public and Atlehang Life clients. When you communicate with Atlehang Life through these services, that social networking service may collect your personal information for its own purposes. These services may track your use of our digital channels on those pages where the links are displayed. If you are logged into those services (including any Google service) while using our digital channels, their tracking will be associated with your profile with those service providers. These services have their own privacy policies which are independent of Atlehang Life’s privacy policies and practices. Please ensure that you fully acquaint yourself with the terms of any such third-party privacy policies and practices.

7. Sharing of Personal Information
To facilitate, administer and manage your insurance policy, Atlehang Life may have to share your Personal Information with third parties that form part of the distribution channel within Atlehang Life. The purpose for sharing your personal information will include-

(a) for delivery and/or administration of financial services;
(b) for purposes that are set out in paragraph 4 above;
(c) for reinsurance purposes;
(d) for reporting to law enforcement agencies, and regulatory authorities when required
by law;

Where the third parties act as an “Operator” they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes. In this case, your Personal Information will only be disclosed to these parties to the extent necessary to provide the required services and the third party will be obliged to use that Personal Information only for the purposes it was initially processed for. Third parties with whom Atlehang Life shares your Personal Information will undergo a due diligence process, a safeguard measure to ensure they process any information disclosed to them in accordance with the contractual relationship we have with them and applicable law, including with respect to data confidentiality and security. Where appropriate, the third parties set out above have agreed to confidentiality restrictions and use any Personal Information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us.

8. Storage and Retention of Personal Information
Atlehang Life endeavours to ensure that Personal Information is kept as current as possible, and that irrelevant or excessive data are deleted as soon as reasonably practicable. Atlehang Life generally retains Personal Information for as long as it reasonably considers necessary for achieving the purposes set out above and as is permissible under applicable laws. We will, in any case, retain your Personal Information for as long as there are statutory retention obligations or potential legal claims that are not yet time-barred. You may request us to delete your Personal Information, this will be carried out unless there is a statutory obligation that requires us to keep your information for a specific period. We will, however, destroy the record of your information beyond reconstruction when that period comes to an end. It is your responsibility to ensure that your data is complete, accurate and up to date.

9. Security of Personal Information
Atlehang Life is committed to protecting the confidentiality and security of the Personal Information you share with us. We have implemented generally accepted standards of technology and operational security (e.g., encryption, breach notification plan, regular audits and inspections) in order to protect Personal Information from loss, unauthorised access, misuse, alteration or destruction. Only authorised persons are provided access to Personal Information; such individuals have agreed to maintain the confidentiality of this information. Although we use appropriate security measures once we have received your Personal Information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect Personal Information, but we cannot guarantee the security of data transmitted to or by us. Atlehang Life will advise the Information Regulator (established in terms of section 39 of the POPIA) and you when there’s been an actual or a threat to access and process the Personal Information that is in its possession by an unauthorised party.

10. Transfer of Personal Information

  • Outside the Republic of South Africa (RSA) Atlehang Life can send Personal Information to another country to be processed and can process information received from countries outside the RSA. This includes countries that do not have laws that provide specific protection for Personal Information. Where we collect your Personal Information within the RSA, transfer outside the RSA will only be done if:
  • The recipient is subject to a law, binding corporate rules or a binding agreement which upholds principles for reasonable Processing of the information that is substantially similar to the conditions contained in POPIA and includes provisions that are substantially similar to those contained in POPIA relating to the further transfer of Personal Information from you to third parties who are in another country.
  • You have consented to the transfer of your Personal Information to that country
  • The transfer is necessary for the performance of a contract between you and Atlehang Life, or the implementation of pre-contractual measures taken in response to your request or
  • The transfer is necessary for the conclusion or performance of a contract concluded in your interest between Atlehang Life and a third party, or the transfer is for you and it is not reasonably practicable to obtain your consent to that transfer, and if it were reasonably practicable to obtain such consent, you would be likely to give it.11. Your Rights as a Data Subject
    With regard to your Personal Information, Section 5 of the POPIA gives you, the Data Subject the right to:
  • not have your Personal Information processed in an unlawful manner,
  • be notified that your Personal Information is being processed,
  • not have your Personal Information processed without your consent,
  • object to the Processing of your Personal Information,
  • be given the details of the principal party that is in possession of your Personal Information,
  • update your information as to when a change occurs,
  • have your Personal Information protected from access by unauthorised parties,
  • be notified when unauthorised parties have gained access to your Personal Information,
  • request the deletion, destruction of your Personal Information,
  • be given access to the record that has your Personal Information,
  • be advised of the period for which your Personal Information will be kept, and
  • have your Personal Information destroyed when the purpose for which it was collected is met.12. Contact Us
    Please contact us at the following contact details when you want to exercise a legal right in relation to your Personal Information or an inquiry if you have a question or complaint about the handling of your Personal Information.

    You may also contact us using the following details:
    Information Officer: Dr Lawrence Konyana
    Atlehang Life
    57 Western Service Road
    Tel: 011 083 5013


TCF Policy

1. Introduction …………………………………………………………………………………………………………………… 2
2. Policy Statement …………………………………………………………………………………………………………….. 3
3. Application of the Policy ………………………………………………………………………………………………….. 4
4. TFC Fairness Outcomes ……………………………………………………………………………………………………. 4
5. Policy Review …………………………………………………………………………………………………………………. 8
6. Non-Compliance …………………………………………………………………………………………………………….. 8
7. Policies and Procedures …………………………………………………………………………………………………… 9

1. Introduction
Atlehang is a micro insurer and an authorised Financial Service Provider (FSP) and micro insurer that is committed to customer satisfaction by treating all our customers fairly. We are committed to providing innovative systems, unparalled service expertise, enabling efficient solutions for our clients and partners. Our mission is to be a recognized and respected Micro Insurer and our Treating Customers Fairly (TCF) policy is an integral part of that objective. We strive to consistently deliver fair outcomes and enhanced service quality to our clients, based on a culture of transparency and putting the customer first.

The Treating Customers Fairly (TCF) initiative is a key component of the Financial Sector Conduct Authority’s (FSCA) broader consumer protection and market conduct mandate. TCF aims to be a holistic and coordinated consumer protection regulatory framework that applies consistently across the financial services sector and is designed to address the specific conduct risks appropriate to the sector. It is an outcomes-based regulatory and supervisory approach designed to ensure that regulated financial institutions deliver specific, clearly set-out fairness outcomes for financial customers. TCF’s approach seeks to ensure that fair treatment of customers is embedded within the culture of financial institutions. TCF uses a combination of market conduct principles and explicit rules to drive the delivery of clear and measurable fairness outcomes.

What TCF is not:
• TCF does not mean creating satisfied customers.
• A satisfied customer could still be treated unfairly and simply not know it.
• TCF does not mean that every company must offer the same level of service.
• Our different ways of doing things create healthy competition.
• TCF does not mean that customers are no longer expected to make decisions or take
responsibility for these decisions.

What TCF is about
TCF is simply about three factors tied together in a causal loop with each activity impacting the next.
• Improved customer confidence.
• Appropriate products and services.
• Enhanced transparency and discipline

TCF is aimed at achieving six very specific desired outcomes that concern the customer. TCF requires regulated companies to be able to provide evidence or demonstrate these desired outcomes at every stage of the product life cycle. TCF principles must be driven by the company’s culture and the way it does business as opposed to a set of defined rules. FSPs should always apply these principles keeping the customer in mind.

2. Policy Statement
Our clients are at the very heart of all that we do, and we are fully committed to providing the highest standards of client service and advice. Our customers are our most valuable asset, and our aim is to ensure we deliver user-friendly, robust, reliable and cost-effective insurance services and products. As a part of our overall approach, we are fully committed to treating our clients fairly and as such we endeavour to meet their expectations of high-quality service.

2.1 Atlehang Life Core Values
At Atlehang Life we are guided by the following values
1. Integrity: Integrity is a core value that guides our actions and actions with our customers. We
uphold strong moral and ethical principles, honesty and consistency in actions and decisions.
2. Excellence: Excellence is achieved through our stive for the highest quality in all aspects of products,
services, and interactions. This is done by ensuring that customers receive prompt and accurate
compensation in times of need.
3. Passionate: The team at Atlehang always demonstrates enthusiasm and dedication in providing the
best possible service and solutions to customers
4. Innovative: We are consistently seeking new and creative ways to improve products, services and
customer experience.
5. Trustworthy: We are reliable, dependable and consistent in delivery our services

This TCF policy is centred around the guidance provided by the FSCA and our External Compliance Officer, to ensure that we consistently deliver fair outcomes to our clients throughout the product life cycle and take responsibility for the actions of the company and staff (at all levels) providing an enhanced service and product quality to clients.

3. Application of the Policy
This Policy applies to all permanent and temporary employees, directors, officers, representatives, agents and independent intermediaries and contractors (“Employees”) of Atlehang.
4. TFC Fairness Outcomes
The FSCA has outlined six key outcomes, which are central to the TCF initiative:
Figure 1 Regulatory Framework

4.1 Outcome 1: Customers are confident that they are dealing with firms where the fair treatment of customers is central to the firm culture.
4.1.1 Atlehang Board of Directors have adopted the TCF Policy to ensure that the organisation’s business practices are fully governed by a culture of TCF. The Market Conduct Department is responsible for the implementation and enforcement of the TCF Policy, principles and objectives.
4.1.2 All the employees of the FSP must adhere to the TCF Policy, principles and requirements. 
In addition, Atlehang is required to measure themselves against a stringent set of standards set out in the Atlehang TCF Self-Assessment tool, which aligns with the FSCA Self-Assessment Questionnaire. The results of the TCF Assessment will be shared with all Risk and Compliance Committee to ensure that Atlehang not only understands how they fare against the standards but are also able to identify conduct risk associated with their practices and remedy this to improve poor customer outcomes that may result due to poor conduct or lack of oversight.
4.1.3 The remuneration of employees will be linked with the reaching of TCF objectives. Disciplinary processes will be instituted in cases of non-compliance should it be necessary.
4.1.4 The Compliance Officer will conduct compliance monitoring of all relevant legislations and TCF to determine the compliance and implementation progress with TCF. The report will be submitted to the Risk and Compliance committee and also shared with relevant Executive Management.
4.1.5 TCF shall be a standing agenda point at all our Executive Committee meetings.
4.1.6 TCF training and awareness programmes of applicable legislation such as the Financial Advisory and Intermediary Services (FAIS) Act, Financial Intelligence Centre Act (FICA), Long-term Insurance Act including PPRs, and Protection of Personal Information Act (POPIA) will be developed; and employees will be required to attend such training programmes on an annual basis.
4.1.7 Atlehang will do due diligence on other businesses before contracting with them to ensure that the TCF principles are adhered to.
4.2 Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified customer groups and are targeted accordingly.
4.2.1 We extensively consider the profile of our clients when designing our products ensuring that customers’ needs are at the forefront of our product design and development process. The product is analysed to ensure that it is suitable for a particular market segment and satisfies the needs of that market segment.
4.2.2 Atlehang has processes in place to ensure that all products are signed off before being sold to the market to ensure that they meet the needs of the targeted group.
4.3 Outcome 3: Customers are given clear information and are kept appropriately informed before, during and after the time of contracting.
4.3.1 Customers will be given clear information and be kept appropriately informed before, during and after the time of contracting. Atlehang’s employees shall ensure that all communication to customers is clear and not misleading. The customers shall be guided about the information required by product suppliers.
4.3.2 Atlehang shall ensure that all required disclosures are made to a customer as prescribed in the Policyholder Protection Rules of Long-Term Insurance. In addition, the Financial Advisory and Intermediary Services (FAIS) Act and the General Codes of Conduct associated with various categories of licenses also govern the FSP’s way of engagement with our customers in relation to transparency and disclosures through the policy life cycle with the company.
4.3.3 Atlehang has defined due diligence strategies and processes associated with customer engagement across all stages of the customer’s journey with intermediaries relationships. We shall ensure that all independent intermediaries adhere to the disclosure requirements and that all information that needs to be communicated to policyholders is done so clearly through conducting regular independent audits.
4.4 Outcome 4: Where customers receive advice, the advice is suitable and takes account of their circumstances.
4.4.1 Atlehang shall adhere to the requirements of Section 8 of the FAIS General Code of Conduct, which states that an FSP must do a suitability analysis prior to providing a client with advice. We shall ensure that our representatives always understand the customer’s needs and their financial situation to ensure that we are able to make appropriate financial recommendations. Atlehang shall ensure that the record of advice complies with the FAIS General Code of Conduct and contains all required disclosures.
4.4.2 Advisors shall be trained to ensure they have adequate knowledge of the products and services that Atlehang provides. Advisors shall be provided with all information they need to advise on our products and services.
4.4.3 Atlehang has put in place robust intermediary agreements to ensure that intermediaries who provide advice to customers understand what their obligations are and regular audits will be conducted to ensure adherence to the agreement and relevant legislation.
4.5 Outcome 5: Customers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect.
4.5.1 Atlehang’s products must perform as they have led their customers to expect, and the associated service must be of an acceptable standard. Processes are in place to mitigate the risk that products and services are unable to satisfy the reasonable expectation of customers.
4.5.2 Representatives are trained to ensure that when engaging with customers, they do not deviate from Atlehang’s product offerings, but disclose correct information about our products and services.
4.5.3 We have processes to monitor and act on feedback, complaints and suggestions received from our clients or employees that identify the need for improvements in types of services or service standards.
4.5.4 Atlehang has developed an advertising framework to ensure that customers are not provided with misleading information or misrepresented facts. This Framework governs the way of work within the business and sets out the processes, regulatory requirements and minimum standards which need to be complied with by all stakeholders when marketing Atlehang’s products.
4.5.5 Atlehang has a Market Conduct Department that is responsible for the implementation of the requirements set out in this Policy. Every business unit with Atlehang must implement the principles of TCF in all their activities, ensuring that TCF is embedded throughout the lifecycle of products offered on our licenses.
4.6 Outcome 6: Customers do not face unreasonable post-sale barriers to change products, switch providers, submit a claim or make a complaint.
4.6.1 Customer satisfaction is a fundamental part of Atlehang’s culture, and we believe that our customers’ experience throughout their journey with us must be of a standard and quality which does not prejudice the customer in any manner whatsoever. We have committed to developing strong overarching governance frameworks which detail the standards and
requirements related to claims and complaints.
4.6.2 There are no unreasonable post-sale barriers submit a claim or make a complaint. Atlehang has adopted a complaints management framework which is aimed at ensuring that customers’ complaints are resolved properly and promptly. We are committed to continuously monitoring management information relating to complaints to identify trends of poor customer treatment and to implement corrective measures to ensure that clients do not face any post-sales barriers when dealing with the organisation.
4.6.3 In addition, we monitor claims and complaint data to ensure that agreed turnaround times and minimum service standards are adhered to.
5. Policy Review
This Policy will be reviewed and revised every two years or in line with the current business planning process, or when necessary, at earlier intervals due to significant changes internal or external to Atlehang Life. This document may also be reviewed or updated subsequent to audits of any nature.
6. Non-Compliance
Atlehang Life views any non-compliance to this policy as well as any non-compliance with its obligations in terms of legislation in a serious light. Any deliberate action by its employees to contravene this Policy will be subject to disciplinary action. All non-compliance with this policy will be included in the regular risk reporting process.

7. Policies and Procedures
Atlehang Life has a number of policies and procedures that are relevant to the fair treatment of clients and these are (this is not an exhaustive list):
• Conflicts of Interest Policy
• Complaint Management Framework
• Claims Management Framework
• Risk Management and Compliance Programme
• Data Protection Policy
• Compliance Framework and Manual
• Enterprise Risk Management Framework
• Recruitment and Competence Policies