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Home » Big Save Privacy Notice

Big Save Privacy Notice

BIG SAVE PRIVACY NOTICE (CUSTOMERS)

PART A: FOUNDATION

1. INTRODUCTION

  1. Big Save Group respects the privacy rights of its customers, employees, suppliers, service providers, business partners, loyalty programme members, website users, application users and all other persons whose Personal Information it Processes.
  2. Big Save Group is committed to Processing Personal Information lawfully, reasonably, transparently and securely in accordance with the Protection of Personal Information Act, 2013 (“POPIA”), the Promotion of Access to Information Act, 2000 (“PAIA”), the Consumer Protection Act, 2008 (“CPA”), the Electronic Communications and Transactions Act, 2002 (“ECTA”) and other Applicable Laws.
  3. This Privacy Notice explains how Big Save Group collects, uses, stores, shares, protects and otherwise Processes Personal Information within the Big Save Ecosystem.
  4. This Privacy Notice applies to Personal Information collected through, among other things:
    1. Participating Stores;
    2. the Big Save Loyalty and Rewards Programme;
    3. the Website;
    4. the Big Save App;
    5. Digital Channels;
    6. customer service interactions;
    7. competitions, promotions and campaigns;
    8. credit applications and account facilities;
    9. supplier and business partner relationships; and
    10. any other products, services, platforms, systems or business activities operated by or on behalf of the Big Save Group.
  5. By interacting with the Big Save Ecosystem, a Data Subject acknowledges that Personal Information may be Processed in accordance with this Privacy Notice and Applicable Laws.

2. PURPOSE OF THIS PRIVACY NOTICE

  1. The purpose of this Privacy Notice is to:
    1. explain how Personal Information is Processed by Big Save Group;
    2. inform Data Subjects of their privacy rights;
    3. explain the safeguards implemented by Big Save Group to protect Personal Information;
    4. explain how Personal Information may be shared, analysed, stored and utilised;
    5. explain how Customer Insights, Aggregated Data, Anonymised Data and related analytical outputs may be generated and used; and
    6. promote transparency, accountability and responsible information governance throughout the Big Save Ecosystem.

3. SCOPE AND APPLICATION

  1. This Privacy Notice applies to all Personal Information Processed by or on behalf of the Big Save Group.
  2. Depending on the nature of the relationship, one or more entities within the Big Save Group may act as a Responsible Party, Joint Responsible Party or Operator for purposes of Applicable Laws.
  3. This Privacy Notice must be read together with:
    1. the Big Save Loyalty and Rewards Terms and Conditions;
    2. the Big Save Standard Terms and Conditions of Sale;
    3. the Big Save Digital Platform Terms and Conditions;
    4. the Big Save Registered User Terms; 
    5. the Big Save Cookie Policy;
    6. the Big Save PAIA Manual; and
    7. any additional notices, consent forms, campaign rules, promotional terms or other privacy-related documents published by Big Save Group from time to time.
    8. Where a specific product, service, campaign, promotion, competition or platform contains additional privacy terms, those terms shall apply together with this Privacy Notice.

4. BIG SAVE PRIVACY PRINCIPLES

  1. Big Save Group is committed to the following information governance principles:
    1. Accountability;
    2. Lawful and Responsible Processing;
    3. Purpose Limitation;
    4. Data Minimisation;
    5. Transparency;
    6. Information Quality;
    7. Security Safeguards;
    8. Responsible Information Sharing;
    9. Respect for Data Subject Rights;
    10. Ethical Use of Analytics and Technology; and
    11. Continuous Improvement of Information Governance Practices.

5. DEFINITIONS

In this Privacy Notice, unless the context indicates otherwise:

  1. “Aggregated Data” means information derived from Personal Information, Loyalty Data, Transaction Data or other information that has been combined, summarised or grouped in a manner that does not identify a specific Data Subject.
  2. “Anonymised Data” means information that has been irreversibly de-identified so that a Data Subject cannot reasonably be identified, directly or indirectly.
  3. “Applicable Laws” means all laws, regulations, codes, directives and legally binding requirements applicable to the Processing of Personal Information and the operation of the Big Save Ecosystem, including POPIA, PAIA, the CPA and ECTA.
  4. “Big Save Ecosystem” means the collective products, services, stores, platforms, systems, applications, websites, loyalty programmes, digital channels, business operations, promotions, competitions, customer engagement initiatives and related activities operated by or on behalf of the Big Save Group from time to time.
  5. “Big Save Group” means Big Save Holdings Proprietary Limited and all of its current and future subsidiaries, affiliated entities, franchise operations, loyalty programme entities, service companies and related entities operating under the Big Save brand ecosystem from time to time.
  6. “Customer Insights” means information, observations, patterns, profiles, trends, preferences, segments, predictions or analytical outputs derived from Data Analytics or information Processed within the Big Save Ecosystem.
  7. “Data Analytics” means the analysis, modelling, evaluation, interpretation, measurement, reporting or assessment of information for operational, commercial, analytical, customer engagement, reporting, innovation, research or other lawful business purposes.
  8. “Data Product” means a report, insight, audience segment, analytical output, benchmark, trend analysis, market intelligence product, retail media output or similar information product generated from information Processed within the Big Save Ecosystem.
  9. “Data Subject” has the meaning assigned to it in POPIA.
  10. “Digital Channels” means the Website, Big Save App, online platforms, social media channels, electronic communication channels and other digital interfaces utilised by the Big Save Group from time to time.
  11. “Loyalty Data” means information relating to participation in the Big Save Loyalty and Rewards Programme, including membership information, Rewards activity, redemption activity, engagement activity and associated customer interactions.
  12. “Operator” has the meaning assigned to it in POPIA and includes any service provider, technology provider, cloud provider, analytics provider or other third party Processing Personal Information on behalf of the Big Save Group.
  13. “Personal Information” has the meaning assigned to it in POPIA.
  14. “Processing” has the meaning assigned to it in POPIA and includes collection, receipt, recording, organisation, storage, updating, retrieval, consultation, use, dissemination, sharing, analysis, anonymisation, restriction, destruction and deletion.
  15. “Programme Partner” means any supplier, manufacturer, advertiser, service provider, technology provider, rewards partner, marketing partner or other authorised third party participating in or supporting the Big Save Ecosystem.
  16. “Responsible Party” has the meaning assigned to it in POPIA.
  17. “Retail Media” means advertising, promotional, audience engagement, campaign measurement, customer targeting, reporting, analytics and related activities conducted within the Big Save Ecosystem for the benefit of the Big Save Group, suppliers, manufacturers, advertisers or authorised business partners.
  18. “Special Personal Information” has the meaning assigned to it in POPIA.
  19. “Transaction Data” means information relating to purchases, returns, refunds, basket composition, product selections, spending behaviour, store interactions, payment activity and related transactional activity within the Big Save Ecosystem.
  20. Words importing the singular include the plural and vice versa.
  21. Any reference to legislation includes any amendment, replacement or re-enactment thereof.
  22. Headings are included for convenience only and do not affect interpretation.

PART B: INFORMATION PROCESSING

6. INFORMATION WE COLLECT

  1. The categories of information Processed by Big Save Group will depend on the nature of the relationship, product, service, transaction, Programme activity or interaction involved.
  2. Big Save Group may collect and Process the following categories of information:
    1. Identity Information: Information used to identify a Data Subject, including names, surnames, identity numbers, passport numbers, dates of birth, gender and similar identifying information.
    2. Contact Information: Information used to communicate with a Data Subject, including telephone numbers, mobile numbers, email addresses, physical addresses, postal addresses and communication preferences.
    3. Account and Registration Information: Information relating to customer accounts, loyalty programme memberships, registrations, profile information, usernames, authentication credentials and account preferences.
    4. Loyalty Information: Information relating to participation in the Big Save Loyalty and Rewards Programme, including membership activity, Rewards earned, Rewards redeemed, promotions participated in, campaign participation and related engagement activity.
    5. Transaction Information: Information relating to purchases, returns, refunds, basket composition, product selections, spending behaviour, store interactions, payment activity and related transactional activity.
    6. Digital and Technical Information: Information relating to the use of websites, applications, systems and Digital Channels, including device information, browser information, operating systems, cookies, identifiers, IP addresses, usage activity and related technical information.
    7. Communications Information: Information contained in customer service interactions, enquiries, complaints, surveys, competitions, promotions, correspondence, social media interactions and other communications.
    8. Location Information: Where permitted by Applicable Laws and device settings, information relating to geographic location, store proximity, regional activity and location-based services.
    9. Marketing and Preference Information: Information relating to communication preferences, marketing preferences, consent elections, campaign participation and customer engagement preferences.
    10. Supplier, Business Partner and Commercial Information: Information relating to suppliers, service providers, business partners, operators, contractors, franchisees and other commercial relationships.
    11. Special Personal Information: Special Personal Information will only be Processed where permitted by Applicable Laws or where the necessary consent or other lawful basis exists.
    12. Big Save Group may also collect information required to comply with legal, regulatory, operational, fraud prevention, security, governance, accounting, audit or risk management requirements.
    13. Big Save Group undertakes to Process only such information as is reasonably necessary for lawful business purposes and the operation of the Big Save Ecosystem.

7. SOURCES OF INFORMATION

  1. Big Save Group may collect information directly from a Data Subject, indirectly through authorised third parties or automatically through the operation of the Big Save Ecosystem.
  2. Information may be collected directly from a Data Subject when:
    1. registering for the Loyalty Programme;
    2. creating an account;
    3. making purchases or transactions;
    4. participating in promotions, competitions or campaigns;
    5. applying for credit facilities;
    6. contacting customer services;
    7. completing surveys or forms;
    8. interacting through Digital Channels; or
    9. otherwise engaging with the Big Save Ecosystem.
  3. Information may be collected automatically through:
    1. the Website;
    2. the Big Save App;
    3. Digital Channels;
    4. cookies and similar technologies;
    5. transaction systems;
    6. loyalty programme systems;
    7. security systems; and
    8. other operational technologies utilised within the Big Save Ecosystem.
  4. Information may also be obtained from authorised third parties, including:
    1. Programme Partners;
    2. Operators;
    3. service providers;
    4. payment service providers;
    5. fraud prevention service providers;
    6. regulatory authorities;
    7. publicly available sources; and
    8. other lawful sources.
  5. Big Save Group may combine information obtained from multiple lawful sources in order to improve information quality, customer experience, fraud prevention capabilities, analytics, reporting and operational effectiveness.
  6. Where required by Applicable Laws, appropriate notice, consent or other lawful justification will be obtained before information is collected or further Processed.

8. PURPOSES OF PROCESSING

  1. Big Save Group Processes information for lawful business purposes connected to the operation, administration, development, improvement and protection of the Big Save Ecosystem.
  2. Depending on the circumstances, Big Save Group may Process information for one or more of the following purposes:
    1. Customer Relationship Management: To establish, maintain and manage relationships with customers, loyalty programme members, suppliers, service providers, business partners and other stakeholders.
    2. Product and Service Delivery: To provide products, services, rewards, promotions, competitions, benefits, customer support and other activities requested by or made available to Data Subjects.
    3. Loyalty Programme Administration: To administer the Big Save Loyalty and Rewards Programme, including membership management, Rewards administration, redemption processing, campaign management, customer engagement and Programme support.
    4. Transaction Processing: To facilitate purchases, returns, refunds, payments, deliveries, collections and related transactional activities.
    5. Customer Communications: To communicate with Data Subjects regarding accounts, transactions, Rewards, promotions, competitions, products, services, support requests, operational matters and other legitimate business activities.
    6. Personalisation and Customer Experience: To personalise customer experiences, promotions, communications, offers, content, recommendations and interactions within the Big Save Ecosystem.
    7. Customer Insights and Analytics: To perform Data Analytics, generate Customer Insights and better understand customer behaviour, purchasing trends, preferences, campaign effectiveness, product performance, operational performance and customer engagement.
    8. Business Intelligence and Reporting: To develop reports, benchmarks, dashboards, performance measurements, forecasts, statistical models and other analytical outputs that support operational, strategic and commercial decision-making.
    9. Product, Service and Platform Improvement: To develop, improve, test, optimise and enhance products, services, loyalty programmes, Digital Channels, systems, technologies, processes and customer experiences.
    10. Artificial Intelligence and Automated Technologies: To develop, train, test, validate, improve or utilise artificial intelligence, machine learning, predictive models, automation technologies and related tools in support of lawful business activities, subject to Applicable Laws.
    11. Retail Media and Audience Solutions: To facilitate advertising, promotional activities, campaign measurement, audience engagement, supplier insights, category management, customer engagement initiatives and related Retail Media activities within the Big Save Ecosystem.
    12. Data Products and Commercial Insights: To generate, analyse, develop, utilise and commercialise Customer Insights, Aggregated Data, Anonymised Data, Data Products and related analytical outputs for lawful business purposes.
    13. Fraud Prevention and Security: To prevent, detect, investigate and respond to fraud, theft, abuse, misconduct, cyber threats, security incidents and other unlawful activities.
    14. Legal and Regulatory Compliance: To comply with Applicable Laws, regulatory requirements, legal obligations, law enforcement requests, audit requirements, governance requirements and lawful instructions from competent authorities.
    15. Risk Management and Governance: To manage operational, legal, compliance, information security, financial and reputational risks and to support governance activities throughout the Big Save Group.
  3. Big Save Group will only Process Personal Information where an appropriate lawful basis exists under Applicable Laws.
  4. Big Save Group will not intentionally use Personal Information for purposes materially inconsistent with the purposes for which it was collected unless permitted by Applicable Laws or otherwise authorised by the relevant Data Subject.

9. LOYALTY PROGRAMME PROCESSING

  1. Participation in the Big Save Loyalty and Rewards Programme requires the Processing of information relating to membership, transactions, Rewards, promotions, campaigns, customer engagement and related activities.
  2. Big Save Group may Process Loyalty Data for purposes including:
    1. administering the Loyalty Programme;
    2. allocating, managing and redeeming Rewards;
    3. managing promotions, campaigns and competitions;
    4. communicating with Members;
    5. providing personalised offers, discounts and benefits;
    6. improving customer engagement and customer experience;
    7. measuring Programme effectiveness and performance;
    8. preventing fraud, abuse and misuse of the Programme; and
    9. supporting lawful operational, analytical and commercial activities connected to the Big Save Ecosystem.
  3. Loyalty Data may be combined with other information lawfully available to Big Save Group in order to improve customer experiences, operational effectiveness, analytics, reporting and Programme administration.
  4. Loyalty Data forms part of the broader information assets utilised by Big Save Group in accordance with this Privacy Notice and Applicable Laws.

10. CUSTOMER INSIGHTS, ANALYTICS AND DATA PRODUCTS

  1. Big Save Group may perform Data Analytics on information lawfully available to it in order to better understand customer behaviour, purchasing patterns, market trends, operational performance, campaign effectiveness and business opportunities.
  2. Through such Data Analytics, Big Save Group may generate Customer Insights, Aggregated Data, Anonymised Data, reports, benchmarks, forecasts, audience segments, trend analyses, market intelligence and other analytical outputs.
  3. Big Save Group may utilise such outputs for purposes including:
    1. improving products, services and customer experiences;
    2. enhancing the Loyalty Programme;
    3. supporting operational and strategic decision-making;
    4. developing new products, services and business initiatives;
    5. supporting Retail Media activities;
    6. providing insights to suppliers, manufacturers, Programme Partners and business partners; and
    7. developing and commercialising Data Products and related analytical outputs.
  4. Subject to Applicable Laws, Customer Insights, Aggregated Data, Anonymised Data and Data Products may be retained, utilised, licensed, commercialised, shared or otherwise exploited by Big Save Group for lawful business purposes. For the avoidance of doubt, Data Subjects do not acquire ownership rights in Customer Insights, Aggregated Data, Anonymised Data, Data Products or derivative analytical outputs generated by Big Save Group, provided that nothing in this clause limits any rights afforded to Data Subjects under Applicable Laws.
  5. Big Save Group will not intentionally disclose Personal Information that directly identifies a Data Subject through a Data Product unless permitted by Applicable Laws, authorised by the relevant Data Subject or otherwise lawfully permitted.
  6. Subject to Applicable Laws, Customer Insights, Aggregated Data, Anonymised Data, Data Products and related analytical outputs remain the property of Big Save Group.

11. ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING

  1. Big Save Group may utilise artificial intelligence, machine learning, predictive analytics, automation technologies and related tools in support of lawful business activities.
  2. Such technologies may be used for purposes including:
    1. customer engagement;
    2. personalisation of offers and communications;
    3. analytics and reporting;
    4. forecasting and planning;
    5. fraud detection and prevention;
    6. operational optimisation;
    7. customer service and support; and
    8. product, service and platform improvement.
  3. Big Save Group may use information lawfully available to it to train, validate, test, improve or operate such technologies, subject to Applicable Laws and appropriate governance controls.
  4. Where automated decision-making materially affects a Data Subject in circumstances regulated by Applicable Laws, Big Save Group shall comply with applicable legal requirements and safeguards.
  5. Big Save Group remains committed to responsible, transparent and ethical use of analytics, artificial intelligence and emerging technologies within the Big Save Ecosystem.

PART C: INFORMATION SHARING AND PROTECTION

12. INFORMATION SHARING

  1. Big Save Group may share information within the Big Save Ecosystem and with authorised third parties where reasonably necessary for lawful business purposes.
  2. Depending on the circumstances, information may be shared for purposes including:
    1. operating and administering products, services and programmes;
    2. loyalty programme administration;
    3. customer support and communications;
    4. analytics and reporting;
    5. fraud prevention and security;
    6. technology and system support;
    7. Retail Media activities;
    8. Data Product development;
    9. legal and regulatory compliance; and
    10. other lawful business purposes.
  3. Big Save Group does not sell Personal Information that directly identifies a Data Subject to third parties.
  4. Information may be disclosed where required by Applicable Laws, lawful authority, court order or regulatory requirement.
  5. All information sharing activities remain subject to Applicable Laws and appropriate governance controls.

13. OPERATORS, SERVICE PROVIDERS AND PROGRAMME PARTNERS

  1. Big Save Group may appoint Operators, service providers, Programme Partners and other authorised third parties to support the operation of the Big Save Ecosystem.
  2. Such parties may provide services including:
    1. technology services;
    2. cloud hosting services;
    3. data analytics services;
    4. customer communication services;
    5. payment processing services;
    6. loyalty programme services;
    7. marketing services;
    8. Retail Media services;
    9. artificial intelligence and automation services; and
    10. other operational or business support services.
  3. Big Save Group may permit such parties to Process information on its behalf where reasonably necessary to perform authorised services.
  4. Where required by Applicable Laws, Big Save Group shall implement appropriate contractual, operational and governance measures to protect information Processed by such parties.
  5. Big Save Group may also engage suppliers, manufacturers, advertisers, business partners and Programme Partners in connection with promotions, campaigns, customer engagement initiatives, Retail Media activities and Data Products.
  6. Subject to Applicable Laws, such activities may involve the sharing of Customer Insights, Aggregated Data, Anonymised Data, audience segments, campaign reporting, market intelligence and other analytical outputs.
  7. Big Save Group shall take reasonable steps to ensure that such activities do not intentionally disclose Personal Information identifying a Data Subject unless otherwise authorised by Applicable Laws.

14. INFORMATION SECURITY AND RETENTION

  1. Big Save Group is committed to protecting information through appropriate administrative, technical, physical and organisational safeguards.
  2. Security measures may include access controls, authentication controls, monitoring, encryption, governance processes, incident management procedures and other reasonable safeguards appropriate to the nature of the information concerned.
  3. No information system, communication channel or security measure can be guaranteed to be completely secure and Big Save Group cannot warrant absolute security.
  4. Big Save Group may retain information for so long as reasonably necessary to:
    1. provide products and services;
    2. administer the Loyalty Programme;
    3. comply with Applicable Laws;
    4. manage legal, regulatory and operational risks;
    5. resolve disputes;
    6. protect the rights and interests of the Big Save Group; and
    7. support lawful business operations.
  5. The closure of an account, termination of participation in a programme or cessation of a business relationship shall not necessarily require the immediate deletion of information.
  6. Subject to Applicable Laws, Customer Insights, Aggregated Data, Anonymised Data, Data Products and related analytical outputs may continue to be retained and utilised after the underlying Personal Information is deleted, anonymised or no longer actively Processed.
  7. Further information regarding security, retention and information governance practices may be made available by Big Save Group from time to time.

PART D: DATA SUBJECT RIGHTS, PREFERENCES AND CONTACT DETAILS

15. DATA SUBJECT RIGHTS

  1. Subject to Applicable Laws, a Data Subject may exercise rights relating to Personal Information Processed by Big Save Group.
  2. Such rights may include the right to:
    1. request access to Personal Information;
    2. request correction of inaccurate or incomplete Personal Information;
    3. request deletion or destruction of Personal Information where appropriate;
    4. object to certain Processing activities;
    5. withdraw consent where Processing is based on consent;
    6. lodge complaints regarding the Processing of Personal Information; and
    7. exercise any other rights available under Applicable Laws.
  3. Requests may be submitted using the contact details provided in this Privacy Notice or through such other channels as Big Save Group may make available from time to time.
  4. Big Save Group may require reasonable verification of identity before acting on a request.

16. MARKETING PREFERENCES AND CUSTOMER CHOICE

  1. Big Save Group may communicate with customers regarding products, services, promotions, campaigns, competitions, rewards, benefits and other legitimate business activities, subject to Applicable Laws.
  2. Where required by Applicable Laws, marketing communications will only be sent with the necessary consent or other lawful basis.
  3. Data Subjects may manage communication preferences, marketing elections, consent preferences and related choices through channels made available by Big Save Group from time to time.
  4. Certain operational, transactional, security, legal, regulatory or service-related communications may still be sent where permitted or required by Applicable Laws.

17. COOKIES AND SIMILAR TECHNOLOGIES

  1. Big Save Group may utilise cookies, pixels, tags, software development kits, analytics tools and similar technologies through the Website, Big Save App and Digital Channels.
  2. Such technologies may be used for authentication, security, functionality, analytics, performance measurement, personalisation, customer experience improvement, advertising and related purposes.
  3. Further information regarding the use of cookies and similar technologies is contained in the Big Save Cookie Policy.

18. COMPLAINTS AND INFORMATION REGULATOR

  1. Big Save Group encourages Data Subjects to raise privacy concerns directly with Big Save Group in the first instance so that reasonable efforts may be made to resolve such concerns.
  2. A Data Subject may also lodge a complaint with the Information Regulator or any other competent authority where permitted by Applicable Laws.
  3. Current Information Regulator contact details may be obtained from the official Information Regulator website or any successor authority established under Applicable Laws.

19. CHANGES TO THIS PRIVACY NOTICE

  1. Big Save Group may amend this Privacy Notice from time to time in order to reflect changes in business operations, technology, products, services, legal requirements, governance requirements or information processing activities.
  2. The latest version of this Privacy Notice shall be made available through the Website, Big Save App or such other channels as Big Save Group may determine from time to time.
  3. Continued interaction with the Big Save Ecosystem following publication of an updated Privacy Notice shall constitute acknowledgement of the updated Privacy Notice to the extent permitted by Applicable Laws.

20. CONTACT DETAILS

  1. Privacy, PAIA and Personal Information-related enquiries may be directed to the Information Officer or authorised representative of Big Save Group.
  2. The current contact details of the Information Officer, Deputy Information Officers and other privacy-related contact points may be published on the Website, contained in the PAIA Manual or otherwise communicated by Big Save Group from time to time.
  3. Requests, enquiries, complaints and notices relating to Personal Information may be submitted through the channels designated by Big Save Group for such purposes.

21. LAWFUL BASES FOR PROCESSING 

Big Save Group may Process Personal Information on one or more lawful bases recognised by Applicable Laws, including consent, contractual necessity, compliance with legal obligations, legitimate business interests, protection of legitimate interests of Data Subjects and other lawful grounds recognised by Applicable Laws.

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