1. Introduction
This manual is published by ImaliFin Pty Ltd under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). It also covers the processing details required by the Protection of Personal Information Act 4 of 2013 (POPIA).
It explains:
- which records ImaliFin Pty Ltd holds;
- how to ask for them;
- what it costs;
- when a request may be refused.
ImaliFin Pty Ltd is a credit provider registered with the National Credit Regulator (NCRCP22668). The records about your loan application and your loan are ImaliFin Pty Ltd's records, and a request for them comes to ImaliFin Pty Ltd under this manual. ImaliFin Pty Ltd uses VulaCheck's lending software; VulaCheck processes these records only on ImaliFin Pty Ltd's behalf, as its operator.
2. Company details and Information Officer
Send every request under this manual to the Information Officer.
| Item | Details |
|---|---|
| Company | ImaliFin Pty Ltd |
| Registration number | 2025/426129/09 |
| NCR registration number | NCRCP22668 |
| Physical and postal address | 78 Rothchild Road, Roodepoort, Johannesburg, Gauteng, 1728 |
| Phone | +27734626608 |
| Website | https://imalifin.vulacheck.com |
| Information Officer | SANDILE GAZU |
| Information Officer email | sandilegazu@hotmail.com |
| General enquiries | Partner@imalif.co.za |
3. The Information Regulator's guide
The Information Regulator publishes a guide under section 10 of PAIA. The guide explains how to use PAIA and POPIA. It is available in all official languages on the Regulator's website, or from the Regulator directly.
| Item | Details |
|---|---|
| Address | Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191 |
| Phone | 010 023 5200 |
| Toll free | 0800 017 160 |
| General enquiries | enquiries@inforegulator.org.za |
| PAIA complaints | PAIAComplaints@inforegulator.org.za |
| POPIA complaints | POPIAComplaints@inforegulator.org.za |
| Website | inforegulator.org.za |
A copy of the guide can also be inspected at ImaliFin Pty Ltd's office during business hours.
4. Records available without a request
Anyone can read these records on imalifin.vulacheck.com without making a PAIA request (section 52):
- Privacy Policy;
- Terms and Conditions;
- POPIA notice;
- how to complain;
- this PAIA manual;
- loan information and cost examples;
- contact and branch details.
5. Records kept under other laws
ImaliFin Pty Ltd keeps records as required by the laws listed below. Where a law gives a right of access, a request under that law may be quicker than a PAIA request.
- National Credit Act 34 of 2005 and its regulations: credit applications, affordability assessments, credit agreements, statements and the records the Act requires a credit provider to keep
- Companies Act 71 of 2008
- Income Tax Act 58 of 1962
- Tax Administration Act 28 of 2011
- Protection of Personal Information Act 4 of 2013
- Electronic Communications and Transactions Act 25 of 2002
- Consumer Protection Act 68 of 2008
- Where ImaliFin Pty Ltd employs staff: the Basic Conditions of Employment Act 75 of 1997, the Labour Relations Act 66 of 1995, the Employment Equity Act 55 of 1998, the Unemployment Insurance Act 63 of 2001, the Skills Development Levies Act 9 of 1999 and the Compensation for Occupational Injuries and Diseases Act 130 of 1993
This list is not complete.
6. Records ImaliFin Pty Ltd holds
The table lists the subjects of the records ImaliFin Pty Ltd holds. A record being listed does not mean access will be given; section 9 sets out the grounds for refusal.
| Subject | Records |
|---|---|
| Applicants and borrowers | Loan applications, identity documents, payslips and bank statements, credit bureau reports, affordability assessments, credit agreements and signatures, debit order and collection records, payments and statements, correspondence and call records |
| Compliance | Returns to the National Credit Regulator, reports to credit bureaus, complaint records, audit records |
| Company | Incorporation documents, the share register, directors' resolutions, statutory returns |
| Finance and tax | Annual financial statements, accounting records, invoices, tax returns, bank records |
| Suppliers | Agreements with service providers and operators, purchase records |
| Staff, where employed | Employment contracts, payroll and tax records, leave records |
7. How ImaliFin Pty Ltd processes personal information
This section gives the details POPIA requires in a PAIA manual. The Privacy Policy and POPIA notice have the full detail.
Purposes of processing
- To assess loan applications, including the credit and affordability checks the National Credit Act requires.
- To make, manage and collect loans, and to keep the records the law requires.
- To report to credit bureaus and regulators as the law requires.
- To prevent fraud and verify identity.
- To contact applicants and borrowers about their applications and loans and, with consent, about other products.
People whose information is processed, and what
| People | Information |
|---|---|
| Applicants and borrowers | Names, ID numbers, contact details, employment and income, bank details, credit records, loan and payment history |
| People who ask to be called back | Name, phone number, consent record |
| Staff and agents | Names, contact details, user activity |
| Suppliers | Contact and contract details |
Who receives it
| Recipient | Purpose |
|---|---|
| Credit bureaus | Credit checks, and the reporting the National Credit Act requires |
| VulaCheck (Pty) Ltd | Lending software, as ImaliFin Pty Ltd's operator |
| Payment and collection providers | Paying out loans and collecting instalments |
| SMS and email providers | Sending messages about applications and loans |
| Regulators and authorities | Where the law requires it |
Cross-border transfers
Some processing by ImaliFin Pty Ltd's software provider takes place in the European Union and the United States. ImaliFin Pty Ltd relies on section 72 of POPIA for these transfers: binding agreements that give adequate protection, transfers needed to perform the contract, or consent.
Security
ImaliFin Pty Ltd protects personal information with:
- encryption in transit and at rest;
- role-based access;
- audit logging;
- encrypted backups;
- security monitoring.
These measures are reviewed regularly.
8. How to request a record
To request a record, send Form 2 to the Information Officer at sandilegazu@hotmail.com. You can get Form 2 from the Information Regulator's website.
- Fill in Form 2.
- Describe the record clearly.
- Say how you want access, for example a copy by email.
- Give the right you want to exercise or protect, and explain why the record is needed for it (section 53).
- Attach a copy of your ID. If you are asking for someone else, attach proof that you may act for them.
- Pay the request fee if one applies (see the table). ImaliFin Pty Ltd will send its banking details.
- ImaliFin Pty Ltd decides within 30 days. It may extend this once, by up to 30 more days, and will tell you why (sections 56 and 57). If you get no answer in time, the request is treated as refused (section 58).
If you only want to confirm whether ImaliFin Pty Ltd holds your personal information, there is no charge (POPIA section 23). To see your own loan documents, such as your agreement and statements, you can also sign in to your account.
Fees for requests to private bodies (Information Regulator, PAIA fee structure)
| Item | Fee |
|---|---|
| Request fee (not payable for a request for your own personal information) | R140.00 |
| Search and preparation, after the first hour | R145.00 per hour, up to R435.00 |
| Deposit, where the search takes more than 6 hours | One-third of the access fee |
| Copy or printout, A4 | R2.00 per page |
| Copy on a flash drive or CD you provide | R40.00 |
| Copy on a CD ImaliFin Pty Ltd provides | R60.00 |
| Transcription of audio, A4 | R24.00 per page |
| Postage | Actual cost |
9. Grounds for refusal and remedies
ImaliFin Pty Ltd may refuse access only on the grounds in Chapter 4 of Part 3 of PAIA, which include:
- protecting another person's privacy (section 63);
- protecting commercial information of ImaliFin Pty Ltd or a third party (section 64);
- breaching a duty of confidence owed to a third party (section 65);
- endangering the safety of individuals or property (section 66);
- legally privileged records (section 67);
- ImaliFin Pty Ltd's commercial and financial information, where disclosure would cause harm (section 68).
Where part of a record can be released, ImaliFin Pty Ltd will release it and hold back only the protected part.
If your request is refused
ImaliFin Pty Ltd has no internal appeal. Within 180 days of the decision, you may:
- complain to the Information Regulator at PAIAComplaints@inforegulator.org.za; or
- apply to a court (sections 77A and 78).
10. Where to find this manual and updates
This manual is published at imalifin.vulacheck.com/paia. A copy is free from the Information Officer and can be inspected at ImaliFin Pty Ltd's office during business hours.
ImaliFin Pty Ltd reviews this manual at least once a year, and whenever its details or processing change. Each version shows its version number and effective date.