Paul’s Homemade (PTY) LTD t/a Paul’s Homemade Ice Cream takes your privacy and the security of your information seriously.
When we obtain information about you through your use of our website, located at www.paulshomemade.com (“Website”), including through your use of our online platform service (“Platform Service”), we will adhere to the principles and procedures set out in this Privacy Policy.

For the avoidance of doubt, the whole of this Privacy Policy is incorporated by reference into the general website terms and conditions governing your use of the Website (“Terms and Conditions”). This means that the Privacy Policy forms part of the Terms and Conditions.
By using the Website, you are accepting the terms of this Privacy Policy and you consent to the collection, processing, further processing and storage of your information (including your personal information) as contemplated herein


You understand that we are entitled to change or amend this Privacy Policy at any time.
You must check this Privacy Policy regularly in order to remain informed of any changes we may have made to it since the last time you checked.

By providing us with your information and/or by using the Website and/or the Platform Service after we have made changes to this Privacy Policy, you will be regarded as having accepted these changes.

This Privacy Policy was last updated on 25 May 2020.


“Personal information” is information that can be used to identify you.

This would include (among other things) your name, your contact and address details (residential and email), your identity or passport number, your date of birth, your bank account or financial details and your personal correspondence, as well as any “personal information” that may be contained in documents or material we request from you. Information which is not capable, or which is no longer capable, of identifying you as a person is not “personal information”.

In the case of a legal person (such as a company), personal information would include the entity’s full legal, registered name, registration number, country of registration and the names and other personal details of the entity’s directors and employees.

The personal information we collect from you is required by us in order to provide you with the services we offer. While you may choose not to provide us with the personal information we request, we will then not be able to provide you with all of the services we offer.

We may also collect information about your visits to the Website, and about your actions, transactions and experiences in making use of the Website or the Platform Service.

Finally, we may also collect non-personal information from you.


Personal information that we collect about you comes mainly from information and documents or material that you provide to us voluntarily of your own accord (including, for example, when you take part in any online surveys we may conduct from time to time on the Website or in relation to the Platform Service).

We also collect (and use and store) scoring information from registered credit bureaus, including data in respect of your existing debts and financial obligations. This data assists us in (among other things) effectively applying our affordability assessment criteria when a user applies for credit via the Platform Service.

Additional information may also be voluntarily provided by you to us, either directly or indirectly, where you choose to link your profile in respect of the Platform Service to your social networking profiles, such as Facebook, Instagram or Twitter.

If you contact us or communicate with us in connection with your use of the Website and/or of the Platform Service, we will keep a record of our communications with you. Such a record may contain your personal information.

Information we collect about your visits to the Website and about your actions, transactions and experiences in making use of the Website and/or the Platform Service will be collected by using “cookies”.


“Cookies” are small data files that are stored on the hard drive of your computer by your browser. Each time you visit the Website, cookies will collect information about your visit (including your browsing patterns) and about your computer (including your internet protocol (IP) address, browser and operating system).

Cookies cannot collect personal information about you. They are used purely to allow us to offer you a better online experience of the Website and our services.

Please note that it is possible for you to change your computer’s browser settings so as to disable the use of cookies. We would advise that you do not do this, however, as this could affect the manner in which you are able to use the Website on your computer. Unless you have adjusted your browser settings to refuse or disable cookies, our system will automatically issue cookies when you access the Site.
Please note that our advertisers, as well as other organisations or service providers that upload information to the Website, may also make use of cookies. You understand and acknowledge that we have no control over cookies used by third parties.


To operate the Website, we also make use of the services of the IT security service provider. Any communication between us and takes place solely to avert fraud in the use of the Website.

With the assistance of cookies and tracking technologies, Google gathers and processes specific data from our users in anonymized form about the equipment in the terminal device used by the user (“Google-Specific Data”), raw data from the TCP/IP connection, and data about use of the Website. For technical reasons, Google also gathers and processes the IP address of the user’s device, but the address is encoded at Google within seconds. The information is stored at Google in a database for fraud prevention.

If the user registers for use of the Website, we call up a risk assessment that was stored in the Google database for the terminal device used by the user. That risk assessment is based, among other factors, on information about (i) whether the user’s terminal device is presently communicating, or has communicated in the past, via a proxy connection, (ii) whether the terminal device has recently connected via different Internet service providers, (iii) whether the terminal device presents or has presented a frequently changing georeference, (iv) how many Internet transactions have recently been carried out via the device (we cannot, however, tell what kind of transactions were involved), and (v) how probable it is that the terminal device on file in the [insert name of provider] database is in fact the user’s. This risk assessment helps us to prevent attempts at fraud on the Website. We do not, however, use the data as the sole criterion for completing or terminating a registration, or in determining whether to publish a loan application and its details via the Platform Service.

We furthermore send data to Afrihost if we know that a user has committed or attempted to commit fraud against us. Only this fact, as well as the user’s Google-Specific Data, is transmitted to Afrihost, but not the name, address or similar contact data of the user.


Through our use of cookies as explained, we collect and analyse data (information) regarding our users’ routine visits to the Website.
We use this data to monitor which areas of the Website are most frequently visited in order to assist us in improving the Website, our services (including the Platform Service) and our general business offering to you.

The data described is at all times pooled or aggregated data, which means that the individual information, behaviour or patterns of a particular person cannot be identified.


You understand and acknowledge that information you choose to transmit or send over the internet can never be completely secure. While we do our best to protect your personal information, you understand and acknowledge that we cannot absolutely guarantee the security of information you upload to, or send via, the internet.

Once we receive your information, we have strict security standards and procedures in place to help prevent any unauthorised access to your information. Where we are required to hold or to make paper (hard) copies of any document you send to us, or of any document otherwise containing your information (including your personal information), such copies will either be:

  • stored in a secure storage facility and archived, when necessary, in a similar manner; or
  • scanned into our secure electronic systems (with the original paper copies then being destroyed) and, when necessary, archived in a similar manner.

All personal information provided online/electronically by you to us will be stored and, when necessary, archived in a secure manner.
Once received by us, your information will be accessible only to our authorised employees or agents, and we confirm that all of our employees, agents, service providers and marketing partners are bound by strict privacy and security standards as well as by confidentiality undertakings.

Where we elect to register you for use of the Platform Service, we will issue you with unique login credentials. In order to access and make use of the Platform Service after your successful registration, you will need to make use of your email address and a password chosen by you.

You undertake to keep your password safe and secure at all times and not to share it with or disclose it to anyone else. If you become aware that your password has been disclosed, or become known, to a third party, you undertake to notify us immediately and to change your password immediately by using the functionality available to you on the Platform Service.


Paul’s Homemade Ice Cream is committed to keeping the information that we collect or obtain from you secure and confidential.
Personal information we collect about you will be used by us in the ordinary course of our business, for the purpose or purposes for which we tell you that such information will be used (whether in this Privacy Policy, in the General Terms and Conditions for the Website Usage, or elsewhere) or for any other purpose that is permitted or required by the laws that are applicable to us and to our business.
When you register for use of the Platform Service, you must pay attention to the circumstances in which we will use your information.
Without taking away from the generality of this, and in addition, we will use your personal information:

  • where you have given us your permission to do so (including by your acceptance of the General Terms and Conditions for the Website Usage), for any particular purpose;
  • to comply with any legal or regulatory obligation imposed on us (including the prevention of money laundering and fraud);
  • to communicate with you or to notify you of changes to the Website or services (including the terms or policies applicable to your use of the Website or the Platform Service);
  • to provide you with services on your request, including but not limited to technical or other customer support services in relation to the use of the Website or the Platform Service;
  • to keep you informed in relation to services, products or other matters that may be of interest to you, including marketing and promotional matters (unless you have told us that you do not want to be kept informed of any such matters); or
  • to ask you to participate in service satisfaction or other surveys (unless you have told us that you do not want to participate in such surveys).


We will not sell or exchange your personal information to or with anyone.
When you register for use of the Platform Service, you must pay attention to the circumstances in which we might disclose your information to third parties.
We will also disclose information, including personal information, to third parties:

  • where we have your permission to do so;
  • when we are required to do so by a court order or by any regulatory authority;
  • where we are required to do so in order to comply with our legal and regulatory obligations in terms of any legislation or regulation applicable to us and our business;
  • in order to exercise, protect and defend our rights and property (including our intellectual property);
  • in order to conduct credit or affordability assessments associated with our business and as required under the National Credit Act, where applicable (including disclosure to registered credit bureaus for this purpose);
  • where such disclosure is in the public interest;
  • in the case of the sale/transfer, or proposed sale/transfer, of our business (or the assets of our business) to any third party, in which case we may disclose your personal information to any proposed buyer of our business (or business assets); and/or
  • where we cease our business operations for any reason whatsoever, in which case we may disclose your personal information to certain third parties for the purpose of continuity.

In each instance set out above, and where applicable, we will take all reasonable steps to ensure that your personal information is treated securely by the relevant third party and in accordance with the principles contained in this Privacy Policy.


Where we collect information from you for a particular purpose, we will keep or retain that information only for so long as is necessary in respect of that purpose.

We may retain some of your information for administrative purposes, to enable us to communicate with or contact you, or to monitor the Website and the Platform Service, and you expressly consent to this.

If you tell us that you do not want us to keep your information in order to allow us to contact you in the future, we will respect your request.


You may choose not to receive certain information from Paul’s Homemade Ice Cream.

While this may mean that you will not receive information that may be of interest or use to you, we will respect your wishes not to receive direct marketing communications. You are entitled to email us at info@paulshomemade.com and specify that you would like to be removed from the Paul’s Homemade Ice Cream email database.

You will also be provided with an “unsubscribe” link in any email marketing communications we may send you, where you choose to remain on our database for marketing purposes. If you choose to click on this “unsubscribe” link, we will remove you and your details from our marketing database.

Access to Information

The Promotion of Access to Information Act was enacted to give effect to the constitutional right of access to any information held by any private or public body that is required for the exercise or protection of any rights.

If you have any questions about this Privacy Policy, please email us on info@paulshomemade.com.