91 NINTH AVENUE, MORNINGSIDE, DURBAN, 4010

TEL : 031-303 1017 www.equine.co.za

PRIVACY AND DATA PROTECTION POLICY

1. INTRODUCTION

The FAIS Act provides for the protection of personal information of Clients; and The Protection of Personal Information Act, 2013 (“POPIA”) provides for 8 Data protection Information principles to apply with to ensure the protection of all data that relates to companies, staff and Clients. The Promotion of Access to Information Act, 2 of 2000 provides for access to such information and in which instances it may be refused.

2. PURPOSE

Data privacy and data protection is important to the FSP and this Policy sets out the POPIA principles in line with existing FAIS requirements to ensure the safekeeping of all Data by the FSP and its Key Persons/ Parties/ Employees (as applicable). This Policy applies to all Data obtained via products, services, websites, events operated by the FSP or by any other means.

3. DEFINITIONS

Information: means any Data relating to the Data Subject and include reference to personal information.  

Data Subject: means the person to whom the personal information relates and can include Clients, staff and/or Company information.

Processing: Any use by any means of a Data Subject’s Information.

4. The 8 POPIA PRINCIPLES TO PROTECT DATA

Principle 1: Accountability: The FSP must appoint an Information Officer who will be responsible for ensuring that the 8 POPIA information principles are implemented and enforced in the FSP.

Principle 2: Processing Limitation:  Only necessary Information should be collected, directly from the person to whom the Personal Information relates and with their consent and the processing should be for a lawful purpose.

Principle 3: Purpose specification: Personal Information should be collected for a specific purpose and the Data Subject must be made aware of the purpose for which it was collected.

Principle 4: Further processing limitation: Further processing of Personal Information must be compatible with the purpose for which the information was collected (Principle 3).

Principle 5: Information quality: Reasonable steps must be taken to ensure that all Information collected is accurate, complete, not misleading and up to date in accordance with the purpose for which it was collected (Principle 3).

Principle 6: Openness: The Party collecting the Information must be transparent and inform the applicable regulator if it is going to process the Information and ensure that the Data Subject has been made aware that his/her Information is going to be collected.

Principle 7: Security Safeguards: The integrity of the Information under the control of a party, must be secured through technical and operational measures. 

Principle 8: Data Subject Participation: Data Subjects have the right (free of charge) to request confirmation from the party that holds their Information on the details they hold, and may request for it to be amended/deleted.   

5. PRACTICIAL IMPLICATIONS OF THE POPIA DATA PROTECTION PRINCIPLES

Appointment of the Information Officer: CHRISTINE TERBLANCHE
The FSP has appointed an Information Officer who is a senior person in the FSP, who will be responsible for ensuring that the FSP has been properly informed and trained on ensuring the safekeeping and protection of Information in the FSP and that the required processes are implemented to ensure compliance. The Information Officer can be contacted at Tel: 031-3031017 or Email: christine@equine.co.za 

Information purpose: 
The type of Information the FSP collects will depend on the purpose for which the Data is collected and used. The FSP will collect the necessary Information from Data Subjects for various purposes, including the following: 

Access to Information:

Collection of Information: 
General: 

User Supplied Information: 
The Data Subject may be required to provide some personal information, for example, his/her name, address, phone number, email address, payment card information (if applicable), and/or certain additional categories of information as a result of using/ receiving financial services, purchasing financial products, and using websites and related services. The FSP will keep this information in a contact database for future reference, as needed.

Marketing: 
The FSP may use certain Information provided by Data Subjects to offer them further services that the FSP believes may be of interest to them or for market research purposes. These services are subject to prior consent being obtained from Data Subjects. If a Data Subject no longer wishes to receive further services or offers from the FSP, IT may unsubscribe from the services or contact the Information Officer at the contact details provided above. 

Usage and Web server logs: 

Cookies:

Retaining of Information:

Correcting/ Amending/ Updating/ Deletion of Information:

Information Security:

Signed and adopted by The Managing Member on ___7 JUNE 2021_____________________