Last Updated: 15 January 2024

ABOUT US

Supercompare is a lead generation and direct marketing brand of 3 Way that connects people to products and services that adds value to their lives. We do this by partnering with product and services providers, third party providers, as well as marketplaces.

When you choose to obtain 3 Way’s products and services (“Services”) through the Supercompare platform, we will bring you the latest deals, specials, promotions and more, in various industries as set out, and will keep you in touch with some of most respected and top financial services, insurance, telecommunications, recruitment companies, and more, operating in the United States.

ABOUT THIS PRIVACY NOTICE

3 Way recognizes the importance of protecting personal information we may collect from you in compliance with all applicable U.S. federal and state laws. 

Our privacy notice (“Privacy Notice”) emphasizes our commitment to safeguarding and keeping secure your personal information. If you have questions or disagree with it please feel free to contact us before using our Services. This Privacy Notice applies to our Site and Services but not to third-party websites or services with different privacy policies.

We may update this Privacy Notice from time to time so please do check for changes.

BASIC INFORMATION

In this Privacy Notice, we use the terms “personal data” and “personal information” interchangeably. In this Privacy Policy “personal information” means information that can identify, relate to, describe, be associated with, or be reasonably capable of being associated with a particular consumer or household.

This Privacy Notice is incorporated into and made part of our Terms of Use.  

Our Privacy Notice covers the following topics:

1. When This Privacy Notice Applies
2. Personal Information – That We Collect OR That You Give to Us
3. Cookies and Similar Technologies
4. How We Use Personal Information We Collect
5. Who we share your Personal Data with
6. Direct Marketing
7. Our Legal Basis for Collecting Personal Information
8. Personal Information We Share
9. Our Retention of Your Personal Information
10. Your Privacy Rights and Choices
11. How We Protect Personal Information
12. Data Brokers
13. Changes to the Privacy Notice
14. How to Contact Us

By using the Site and our Services, you signify your acceptance of this Privacy Notice. If you do not agree to this Privacy Notice, please do not use the Site or our Services.

Irrespective of which country you live in, you authorize us to transfer, store, and use your personal information in the United States, and any other country where we operate including South Africa. .

1. WHEN THIS PRIVACY NOTICE APPLIES

Our Privacy Notice applies to your use of the Site and to all of the Services offered by 3 Way and its affiliates, including some 3 Way partners, and services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Notice.

2. PERSONAL INFORMATION  THAT WE COLLECT OR THAT YOU GIVE TO US

We collect information, including personal information, to provide better Services to you. Common examples of personal information include: full name, email address, cellphone number, digital identity, such as information about your device, and certain metadata.

Specifically, we may collect the following information, a portion of which is considered to be “personal information”:

• any information which you are asked for when registering to use or when otherwise using the Services;
• a list of the products, services you indicate an interest in or have made use of;
• your name and contact information, including email address and location;
• identity number or passport number;
• information relating to your use of our products and services;
• indications that you have opted-in to receive communications;
• information when you complete online forms (including call back requests), take part in surveys, competitions, promotions or sweepstakes;
• Information when you interact with us using social media; and
• information regarding your personal or professional interests, demographics, income, age, location, experiences with our products and contact preferences in order to provide you with further correspondence about our products and services.

You agree and acknowledge that you are supplying your personal information to us voluntarily. However, failure to provide us with the required personal information may result in you not being able to access the Services we provide.

In the event that we collect personal information from a third-party and not directly from you, we will always ensure that we have the relevant legal justification to do so, and the ability for you to opt-out of our further processing of such personal information.

We also collect certain personal information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as interacting with the Services on your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, and the referring web page and pages visited.  We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties.

3. COOKIES AND SIMILAR TECHNOLOGIES

We and our clients and partners use various technologies to collect and store information when you visit our Site or use our Services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services.

The technologies we use for this automatic data collection may include Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site. 

We may use cookie information and automatically collected information to: (a) personalize our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Services; (b) pre-fill forms; (c) provide customized advertisements, content, and information across your devices; (d) monitor and analyze the effectiveness of Services and third-party marketing activities; (e) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (f) track your entries, submissions, and status in any promotions or other activities.

4. HOW WE USE PERSONAL INFORMATION WE COLLECT 

We use the personal information we collect for several purposes, including enrolling you in our client programs, sharing information with our clients for product offerings, processing payments, marketing communication, providing requested information, credit checks, targeted advertising, customer care, record-keeping, improving our services, legal compliance, and more.

We may contact you through various methods unless you specify otherwise in writing. We do not share your information except as mentioned in this Privacy Notice, and some data may be processed by third-party systems in various locations.

We will ask for your consent before using personal information for a purpose other than those set out in this Privacy Notice.

5. WHO DO WE SHARE YOUR PERSONAL DATA WITH

We also may share personal information we collect from you in connection with your use of the Site or our Services, and we may additionally receive compensation from our clients when you agree to enroll in a client program or purchase a product or service from our clients.  Some of the personal information we share or sell includes SPI (e.g., sensitive personal information as defined under CCPA).  CCPA has broad definitions of “selling” and “sharing” and thus some of our business activities may fall under these classifications.

You can control and manage our ability to share or sell your personal information and SPI by  sending us an email to compliance@supercompare.us requesting us to restrict 3 Way’s ability to share your personal information.  See also our California Notice of Collection at www.supercompare.us/california-notice-of-collection for more information about your rights as a California resident, if applicable.

6. DIRECT MARKETING

We would like to provide you with information about new products, promotions, special offers and other information which we think you may find interesting. You agree that we may send you marketing communications (SMS, PCM, E-mail, AVM, WhatsApp, or telephonic calls) and / or put you in touch with clients, on the basis as set out in this Privacy Policy and our Terms of Use. This forms part of our Service offering.

You may opt-out of our direct marketing campaigns at any time, at which point we will not send you any direct marketing related to a specific service or associated campaign. Should you decide to opt out of all or any direct marketing received from us you can opt out at any time by clicking on the following link https://www.donotcall.gov/. You can also opt out by unsubscribing from emails or contacting us.

You may also register on the national do not contact list which can be found on www.dmasa.org.

If we are providing you with Services you will also be subject to the specific terms and conditions relating to the product or services you are being provided with and these terms will include additional information as to how we or any of our Clients may contact you.

If you are a new customer or you have previously asked us for information on our products or services, we may send you information on our range of products and services through our marketing communications unless you opt-out of or limit such communications.

7. OUR LEGAL BASIS FOR COLLECTING PERSONAL INFORMATION

Whenever we collect personal information from you, we may do so on the following legal bases:

1. Your consent to such collection and use;
2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
3. Our legitimate business interest where collecting or using personal information is necessary for:
   1. Product development and enhancement;
   2. Communications and marketing, including processing personal information for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
   3. Enhancement of our cybersecurity, including improving the security of our network and information systems; and other reasons.

8. PERSONAL INFORMATION WE SHARE

When We Share Your Personal Information.  We do not share personal data with companies, organizations and individuals outside of 3 Way unless one of the following circumstances applies:

1. With your consent. We will share personal information with our clients including companies, organizations or individuals outside of 3 Way when we have your consent to do so.
2. For providing our Services. We may share personal information with companies or organizations who provide or maintain our technology platforms or their components for the purpose of maintaining, supporting and protection these platforms.

We also disclose your Personal Information to:

• Our clients whose products and services you are considering or in which you are enrolling;
• Service providers and other third parties we use to support our business, including without limitation those performing core services (such as customer support services, customer relationship management, accounting, auditing, advertising, and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services;  

In such cases, service providers may use the personal information only as necessary to provide the services to us and are contractually required to keep your information confidential and secure.

Legal Reasons.  We may disclose your Personal Information for legal reasons such as to:

1. Fulfill any purpose for which you provide it;
2. Meet any applicable law, regulation, legal process or enforceable governmental request;
3. Enforce applicable agreement, including investigation of potential violations;
4. Detect, prevent, or otherwise address fraud, security or technical issues;
5. Protect against harm to the rights, property, assets or safety of 3 Way, our clients or the public, content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law;
6. For any other purpose disclosed when you provide the information; and,
7. When we obtain your consent to do so.

We do not knowingly collect, sell or share the personal information of individuals under 18 years of age.

9. OUR RETENTION OF YOUR PERSONAL INFORMATION

We may retain your personal information for a period of time consistent with the original purpose for collection.  For example, we keep your personal information for no longer than reasonably necessary for your use of our programs, Site, and Services and for a reasonable period of time afterward. We also may retain your personal information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

We retain your personal information even after your business relationship with us ends if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our agreements, or fulfill your request to “unsubscribe” from further messages from us.

10. YOUR PRIVACY RIGHTS AND CHOICES  

Data Transfers.  You acknowledge and agree that we may access and process personal information on a global basis as necessary to provide you with our Services in accordance with this Privacy Notice and our Terms of Use, and in particular that personal information may be transferred to and processed by 3 Way in the United States, South Africa and to other jurisdictions where 3 Way and its service providers have operations. Wherever personal information is transferred outside its country of origin, 3 Way and its service providers will ensure such transfers are made in compliance with the requirements of applicable data protection laws including the CCPA.

Should we process your personal information in countries outside of the United States which may not have the same data protection standards as the USA we will ensure your data is protected using approved standard contractual clauses or other appropriate data transfer mechanisms.

Privacy Rights Specific to California Resident under CCPA.  Under the CCPA, California residents have specific rights regarding their personal information. Please see our California Notice of Collection at www.supercompare.us/california-notice-of-collection;  This separate California Notice of Collection is an important part of our Privacy Notice and of our overall approach to transparency involving our personal information collection practices.

Exercising Your Rights

If you are a California resident who chooses to exercise your rights, you can submit a request via email to: compliance@supercompare.us.

You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.

Our Response to Your Request 

Upon receiving your request, we will confirm this by email, and we may need to verify your identity before granting you access or taking any actions. We will respond as soon as possible but no longer than 45 days from the date of the request. We may deny deletion requests for specific reasons such as security, legal obligations, research, or internal use aligned with your expectations. As at the date of publication of this Privacy Notice, thirteen U.S. states have comprehensive data privacy laws in place. We expect this list to grow and will update our Privacy Notice as and when more states adopt these.

11. HOW WE PROTECT PERSONAL INFORMATION

We employ robust technologies and policies to safeguard your data from loss, unauthorized access, alteration, or disclosure. Our security measures include encryption, firewalls, and SSL or HTTPS. Although we do take steps to protect your personal information, we cannot guarantee the security of your personal information and we have robust procedures for handling data breaches. In such instances, we will notify you and the regulators if and when required. Our staff is committed to maintaining privacy and security practices, and authorized personnel are bound by confidentiality obligations. While we do take precautions, internet transmission is not entirely secure, therefore you should protect your account with a unique and secret password or login method to prevent others from accessing your account.

12. DATA BROKER:

3 Way also may engage in certain commercial activities that qualify us as a “data broker” under California and other U.S. state laws.  We purchase lists that include personal information about individuals located in the United States.  We may share or resell those lists to our service providers who are providing marketing services for us on behalf of our clients.  If we are deemed to be a data broker under California and other U.S. state laws, we will comply all relevant requirements which may include registration of our business with specific state agencies (such as the California Attorney General’s office).

13. CHANGES TO THIS PRIVACY NOTICE

Our Privacy Notice may change from time to time. We will not reduce your rights under this Privacy Notice without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Notice in an archive for your review.

14. HOW TO CONTACT US

If you have any questions or comments about this Privacy Notice, please submit a request to compliance@supercompare.us. 

California Notice of Collection: www.supercompare.us/california-notice-of-collection. Please note this applies solely to California consumers.