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1.1This notice applies to you if you are:
1.1.1a visitor to our websites:
1.1.1.1www.sasfin.com;
1.1.1.2https://www.sasfin.com/wealth;
1.1.1.3https://wealth.sasfin.com;
1.1.1.4https://beyond-online.sasfin.com;
1.1.1.5https://www.sasfinforex.co.za;
1.1.1.6https://www.sunlyn.co.za; and
1.1.1.7the SWIP platform available at https://wealth.sasfin.com/Portal/SWIPFNA.aspx ("the Websites"); or
1.1.2a customer of Sasfin.
2.1"Personal Information" has the definition set out in the Protection of Personal Information Act 4 of 2013, that is, information which relates to you as an identifiable natural person or juristic person, including, but not limited to:
2.1.1information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
2.1.2information relating to the education or the medical, financial, criminal or employment history of the person;
2.1.3any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
2.1.4the biometric information of the person; and
2.1.5the personal opinions, views or preferences of the person.
2.2Personal Information excludes:
2.2.1information that has been made anonymous so that it does not identify a specific person;
2.2.2permanently de-identified information that does not relate or cannot be traced back to you specifically;
2.2.3non-personal statistical information collected and compiled by us; and
2.2.4information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this notice).
3.1Information you provide to Sasfin:
3.1.1The Personal Information we collect and process may include, but is not limited to:
3.1.1.1lists of the products and services in which you express an interest when you use the Website;
3.1.1.2your name, identity number, passport number, contact information, postal address, street address and email address, company registration number and VAT number which you may submit to us when you interact with the Website;
3.1.1.3information regarding your personal or professional interests, demographics, experiences with our products and contact preferences;
3.1.1.4your contact information when you apply for a position through our recruitment portal (such Personal Information may include your name, identity or passport number, email address, physical address, telephone numbers, information relating to your occupation, gender and any documentation required for purposes of recruitment); and
3.1.1.5all your relevant details for purposes of an application for one of our products or services.
3.2We may also collect special personal information depending on the services that you require. This special information may include but is not limited to financial, demographic, religious, medical, criminal and employment information.
3.3Information Sasfin automatically collect about you:
3.3.1When you use Sasfin’s Website, Sasfin may automatically collect and store certain information about you. This includes, but is not limited to the following:
3.3.1.1technical information, including your Internet Protocol (IP) address which is used to connect your computer to the Internet, operating system and browser type and platform for system administration; and
3.3.1.2information about your use of our Website including details of your visits such as pages viewed and the resources that you accessed. Such information includes traffic data, location data and other communication data.
3.4When you respond to direct marketing from Sasfin, we collect your publicly available information.
3.5When you request our services, you may be asked to provide us with additional information.
3.6We strive to collect only that Personal Information which is necessary for the intended purpose of the collection.
3.7We will use this Personal Information to fulfil your account, provide services and information to you as we reasonably think appropriate and for any other purposes set out in this notice.
4.1We use your information to provide you with a better service and in particular for the following reasons:
4.1.1to provide you with services you have requested and notify you about important changes or developments to these services;
4.1.2to provide you with further information about our products and services;
4.1.3to respond to your inquiries and/or complaints or process your requests in relation to your information;
4.1.4to follow up as part of our customer services procedures;
4.1.5to update our records about you;
4.1.6for internal record keeping;
4.1.7to contact you for market research purposes and/or administer offers to you;
4.1.8to improve our products and services;
4.1.9for fraud prevention and detection, and to comply with applicable laws and regulations;
4.1.10in relation to competitions and other promotions;
4.1.11to evaluate the effectiveness of our marketing and for research, training and statistical analysis with the aim of improving our services; and
4.1.12to make our Website easier for you to use and to provide you with access to certain parts of the Website.
4.2We will not retain your Personal Information for longer than is necessary to achieve the purpose for which we collected it, unless there is a lawful basis or legal requirement for us to retain your Personal Information for a longer period.
5.1We may disclose your Personal Information to the following third parties:
5.1.1other companies in the Sasfin group of companies;
5.1.2selected third parties to provide us with services, including companies that provide us with technical support and assistance in respect of the Website, companies that provide back-office services, companies that provide hosting services or that track the Website’s activities and analytics, and companies engaged to market and distribute Sasfin products and/or services;
5.1.3professional advisers, judicial, regulatory and law enforcement bodies.
5.2We require that our service providers take appropriate, reasonable, technical and organisational measures to keep your Personal Information secure.
5.3In addition, our service providers may not use or disclose Personal Information for any purpose other than providing the services on our behalf.
5.4We may also disclose your Personal Information if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation.
6.1We will take all appropriate, reasonable, technical and organisational measures to safeguard your Personal Information to prevent loss of, damage to or unauthorised destruction of your Personal Information or unlawful access to or processing of your Personal Information.
6.2We authorise access to Personal Information only for those employees who require it to fulfil their job responsibilities.
6.3We implement disaster recover procedures where appropriate.
7.1Our Website uses cookies to improve your browser experience.
7.2First party cookies contains a randomly generated number and allows the browser to remember your selections. It expires when you close the browser and contains no Personal Information.
7.3Third party cookies are used to collect anonymous Website statistics such as the number of visitors in a month, average duration of visits and popular pages viewed. This data is used to review and improve our Website.
We may transmit or transfer Personal Information outside of the country in which it was collected to a foreign country and process it in that country. Personal Information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting Personal Information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your Personal Information in a foreign country whose laws regarding processing of personal information may be less stringent.
9.1You may request details of Personal Information which we hold about you under the Promotion of Access to Information Act, 2 of 2000.
9.2Fees to obtain a copy or a description of Personal Information held about you are prescribed in terms of this Act.
9.3Confirmation of whether or not we hold Personal Information about you may be requested free of charge.
9.4If you would like to obtain a copy of your Personal Information held by Sasfin, please review our Promotion of Access to Information Act Manual located at www.sasfin.com/legal/regulations
9.5You may request access to any of your Personal Information that is held by us at any time and for any purpose, including to request that we correct your Personal Information if it is inaccurate or delete the Personal Information if we are no longer required to retain it by law or for a legitimate purpose.
9.6Requests to access Personal Information held on you in accordance with this notice can be made to privacy@sasfin.com.
10.1You must accept all the terms of this notice when you request our services. If you do not agree with anything in this notice, then you may not request our services.
10.2You may not access our Website or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.
10.3By accepting this notice, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
10.4You may only send us your own Personal Information or the information of another data subject where you have their permission to do so.
We may change the terms of this notice at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the Website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the Website and our services. If you continue to use the Website or our services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.