Who we are
CKG Holdings (Pty) Ltd, trading as First Impressions (registration number 2022/842803/07), is the responsible party for personal information collected through the websites and channels described below. We run online comparison and enquiry sites that connect consumers with insurers and financial services providers. We are not an insurer or a Financial Services Provider and do not give financial advice.
Information Officer: Grant Edmeades | [email protected]
Physical address available on request from [email protected].
Scope
This policy applies to personal information collected by First Impressions through all websites, landing pages, social media lead forms (such as Facebook and Instagram lead forms) and SMS campaigns operated by us or on our behalf. A current list of our websites is available at first-impressions.co.za/our-sites.
What we collect
- Contact details: name, surname, mobile number and, on some forms, email address.
- Quote details: answers about the product you're enquiring about, for example your vehicle, pet, medical aid or cover needs, insurance and claims history, and income band or budget.
- Your choices: providers you select, preferred call time, and whether you opt in to future offers.
- Technical information: IP address, device and browser, approximate location, pages visited, and advertising click and campaign identifiers.
Where it comes from: mostly from you, on our forms. We also receive campaign identifiers from advertising platforms, lead form submissions you make on Facebook or Instagram, enquiries from SMS campaigns run on our behalf, and feedback from providers on the outcome of your enquiry.
We do not ask for your ID number on our websites. If you enquire through an SMS campaign, the campaign provider may ask for it where the insurer needs it to give you a quote. We pass it only to that insurer, and use it to work out age group and gender for combined reporting.
Required fields: your name and mobile number are required for us to pass your enquiry to a provider. Without them, we can't arrange a quote.
Why we use your information
| Purpose | Lawful basis (POPIA s11) |
|---|---|
| Passing your enquiry to the provider(s) you selected or that can quote you, so they can contact you | Your consent |
| Matching you to suitable providers using your answers (see "Automated decisions") | Your consent |
| Passing your details to a provider for a related product, if you ask for that quote after your enquiry | Your consent |
| Sending you future insurance offers by SMS or WhatsApp, only if you opted in | Your consent |
| Sending you an SMS confirming your enquiry | Our legitimate interest in confirming your request |
| Measuring and improving our advertising, including combined (not individual) age and gender reporting | Our legitimate interest |
| Confirming with providers whether enquiries were valid and resulted in a quote or sale | Our legitimate interest |
| Preventing spam, bots and fraudulent submissions | Our legitimate interest |
| Meeting legal obligations and handling your requests and complaints | Legal obligation |
Automated decisions: our forms use simple rules, such as income band and vehicle details, to decide which providers can quote you. If none can, we tell you on screen. You can ask for a person to review this by emailing [email protected].
How we ask for your consent
We only pass your details to providers if you agree on the form where you enter them. The consent wording is shown directly above the button you press to submit, names who may contact you (or links to our partner list), and you agree by pressing that button.
Providers will contact you by phone about your quote. Some may first send you an SMS to let you know to expect their call. We and our providers never send quotes by email or SMS. Where a provider offers online quoting, we may also give you a link to continue your quote on their website, for example outside business hours. You choose whether to use it.
Future offers by SMS or WhatsApp need a separate, optional box, which is never pre-ticked. Not ticking it does not affect your quote.
We keep a record of your consent: the wording shown, the page and the date and time. You can withdraw consent at any time (see "Your rights"). Withdrawing does not affect anything done lawfully before you withdrew.
Who we share it with
- Insurance and financial services providers for the product you enquired about, listed on the partner list for that product. If you select specific providers, only those receive your details. Your details may be shared with up to two providers.
- Brokers named on the partner list, who may place your enquiry with the insurers listed next to them.
- Our service providers, who process information for us under contract and may not use it for their own purposes: website and form hosting, lead management, customer relationship management, security and infrastructure, SMS delivery, and analytics and advertising.
- Authorities, where the law requires it.
Providers pay us for the enquiries we pass to them. We only share your details with providers on the partner list, and never with anyone else for their own marketing.
Information sent outside South Africa
Some of our service providers store or process information outside South Africa, including in the United Kingdom, Europe, the United States and Asia. We only allow this where POPIA section 72 permits it, for example where the recipient is bound by a law or agreement giving protection substantially similar to POPIA.
Cookies
We use cookies and pixels from Google, Meta and TikTok to measure our advertising. You can block them in your browser settings.
How long we keep it
We keep your enquiry details for 36 months. After that we delete your name and contact details and keep only anonymised information for reporting. If you opt out, we keep only your phone number so we don't contact you again.
Security
We protect your information with encrypted connections, multi-factor authentication on all our systems, access controls and contracts with our service providers. If your information is compromised, we will notify you and the Information Regulator.
Your rights
You can ask to see, correct or delete your information, object to its use, or withdraw consent, by emailing [email protected]. We respond within 30 days. You can also complain to the Information Regulator at inforegulator.org.za or [email protected].
Children
Our sites are for people aged 18 and over. We do not knowingly collect information about children.
PAIA manual
Our PAIA manual is available at first-impressions.co.za/paia-manual.
Changes
We review this policy annually. The version and effective date above show when it last changed.