Privacy Notice

1. INTRODUCTION

1.2 Stratfinn carries on the business of financial advisory and compliance

1.3 Stratfinn is required, in certain instances, to process personal information. Accordingly, Stratfinn is required to protect the personal information as set out in the Protection of Personal Information Act 4 of 2013, including its Regulations (POPIA).

1.4 This notice constitutes Stratfinn’s policy statement to declare its commitment to comply with POPIA. Accordingly, it provides insights on how Stratfinn processes personal information of data subjects as set out in POPIA.

1.5 Stratfinn shall ensure that personal information is processed within the parameters of the law.

1.6 This notice must be read in conjunction with POPIA and its Regulations, where applicable.

2. OBJECTIVE

2.1. The objective of this notice is to give effect to POPIA and to provide clarity on the Following:

2.1.1. What personal information Stratfinn collects about a data subject;

2.1.2. How Stratfinn uses and protects the personal information of a data subject;

2.1.3. How long Stratfinn keeps the personal information of a data subject;

2.1.4. The rights of a data subject regarding their personal information; and

2.1.5. What the data subject should do if he/she does not want to provide Stratfinn with his personal information.

3. INTERPRETATION AND DEFINITIONS

In this notice:

3.1. Clause headings are for convenience and reference only and shall not be used in the interpretation thereof;

3.2. Any gender includes the other genders and a natural person includes a juristic person and vice versa;

3.3. All the annexures (if any) hereto are incorporated herein and shall have the same force and effect as if they were set out in the body of this notice;

3.4. The following words and/or expressions shall, unless the context indicates otherwise, bear the meaning assigned to them below and in POPIA;

3.4.1. “Cookie/s” (also called web cookie, Internet cookie, browser cookie, or simply cookie) is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing to inter alia remember stateful information (such as items added in the shopping cart in an online store) or to record the user's browsing activity;

3.4.2. “Data subject” means the person to whom Personal information relates;

3.4.3. “Employee” means a permanent, fixed-term or temporary employee of Stratfinn;

3.4.4. “Operator” means a third party that processes Personal information in terms of a mandate or contract with Stratfinn without coming under the direct authority of Stratfinn;

3.4.5. “Information officer” means the person appointed by Stratfinn from time to time, who is responsible for the monitoring of compliance, with the conditions for the lawful processing of Personal information; dealing with requests made to Stratfinn in terms of POPI; working with the Regulator in relation to investigations conducted in relation to prior authorisation by the Data subject and ensuring compliance by Stratfinn with the provisions of POPIA;

3.4.6. “Person” means any person, company, close corporation, trust, partnership or other entity;

3.4.7. “Personal information” shall mean the race, gender, sex, pregnancy, marital status, national or ethnic origin, colour, sexual orientation, age, physical or mental health, disability, religion, conscience, belief, culture, language and birth of a person; information relating to the education or the medical, financial, criminal or employment history of the person; any identifying number, symbol, email address, physical address, telephone number, location information, online identifier or other particular assignment to the person; the biometric information of the person; the personal opinions, views or preferences of the person; correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence; the views or opinions of another individual about the person whether the information is recorded electronically or otherwise.

3.4.8. “Privacy Notice or Notice” means this Notice as amended from time to time;

3.4.9. ‘‘Processing’’ means any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including—

(a) the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;

(b) dissemination by means of transmission, distribution or making available in any other form; or

4. PROCESSING OF PERSONAL INFORMATION

4.1. Personal information Stratfinn collects about a data subject and the basis thereof

4.1.1. The Personal information Stratfinn collects in the ordinary course of business includes:

4.1.1.1. only information that is adequate, necessary, and relevant to enable it to effectively render a service or assist in any manner required, such as the Data subject’s name, identity number (where applicable), registration number, Tax number, Data subject’s employees or its director’s Personal information, contact information etc;

4.1.1.2. electronic communications or any other information submitted to Stratfinn;

4.1.1.3. technical information, for instance through the use of cookies, such as activity data, such as when the Data subject completes a form on the Stratfinn website, subscribes to a newsletter, alerts or other services from Stratfinn;

4.1.1.4. information from the Data subject’s visits to the Stratfinn website, including the type of browser and operating system that the Data subject uses, access times, pages viewed, URLs clicked on, his IP address and the pages visited before and after navigating the Stratfinn website;

4.1.1.5. social media tracking pixels that allow platforms such as LinkedIn to interact with the Stratfinn website;

4.1.1.6. device information, including the unique device identifier, hardware model, operating system and version and mobile network information;

4.1.1.7. the Strafinn website uses various technologies including "cookies" which allow the website to recognise and respond to the Data subject as an individual. The Data subject can elect to accept or decline cookies. If a Data subject elects to decline cookies, not all elements of the website may function as intended, so his website experience may be affected.

4.2. Protecting the Data subject’s Personal information

4.2.1. Stratfinn uses a variety of security measures and technologies to help protect Personal information of a Data subject from unauthorised access, use, disclosure, alteration or destruction in line with applicable Personal information protection and privacy laws. For example, when Stratfinn shares the Personal information of a Data subject with external suppliers and/or operators, it shall put in place a written Data Processing Agreement which commits the suppliers and/or the operators to keep the Data subject’s Personal information confidential, and to put in place appropriate security measures to keep it secure.

4.2.2. The transmission to Stratfinn of information via the internet or a mobile phone network connection may not be completely secure and any transmission is at the Data subject’s risk.

4.2.3. Despite the security measures that Stratfinn has in place to protect Personal information of a Data subject (firewalls, password access and encryption methods), the Data subject acknowledges that it may be accessed by an unauthorised third party, e.g. as a result of an illegal activity.

4.2.4. From time to time Stratfinn may provide links to websites or mobile applications that it does not own or control. This Notice does not apply to those websites. If a Data subject chooses to use those websites, he must check the legal and privacy policies or statements posted on each website or mobile application he accesses to understand their privacy practices.

5. HOW DOES STRATFINN USE THE PERSONAL INFORMATION OF A DATA SUBJECT

5.1. Stratfinn may use the Personal information of a Data subject to provide the Data subject with information and services including:

5.1.1. tax services;

5.1.2. advisory services;

5.1.3. assurance services;

5.1.4. consulting services;

5.1.5. company services;

5.1.6. individual services;

5.1.7. marketing communications about Stratfinn products and services.

5.1.8. Stratfinn will obtain consent for marketing to the extent required by law.

5.2. Contact and interact with the Data subject, including to:

5.2.1. respond to requests from the Data subject; and

5.2.2. provide important notices and updates, such as changes to terms, policies, security alerts and administrative messages.

5.3. Operate Stratfinn’s business, including:

5.3.1. complying with applicable laws, regulations and guidance; and

5.3.2. complying with demands or requests made by regulators, governments, courts and law enforcement authorities.

5.4. Improve Stratfinn’s day-to-day operations, including:

5.4.1. for internal purposes such as auditing, data analysis and research to help Stratfinn deliver and improve its digital platforms, content and services;

5.4.2. to monitor and analyse trends, usage and activities in connection with Stratfinn products and services to understand which parts of Stratfinn digital platforms and services are of the most interest and to improve the design and content of those platforms;

5.4.3. to improve Stratfinn products and services and communications to the Data subject; and

5.4.4. to ensure that Stratfinn has up-to-date contact information for the Data subject, where applicable.

6. HOW LONG WILL STRATFINN KEEP PERSONAL INFORMATION OF A DATA SUBJECT

Stratfinn will always keep the personal information of a Data subject for the period required by law and where it needs to do so in connection with legal action or an investigation in which it is involved. Otherwise, Stratfinn will keep Personal information of a Data subject:

6.1. for as long as needed to provide the Data subject with access to services he/she or it has requested.

7. INSTANCES WHERE SHARING OF PERSONAL INFORMATION OF A DATA SUBJECT BYSTRATFINN IS PERMITTED

Stratfinn may share Personal information of a Data subject with the following third parties:

7.1. Agents and suppliers, including those who provide it with technology services such as data analytics, hosting and technical support;

7.2. Professional advisors, auditors and business partners;

7.3. Other third parties in connection with re-organising all or any part of Stratfinn’s business, provided that a Data Processing Agreement has been entered into.

7.4. Regulators, governments and law enforcement authorities

7.5. Personal information of a Data subject may be processed by Stratfinn and Stratfinn’s third party suppliers outside of the Data subject’s home country. Personal information laws in the countries to which the Personal information of a Data subject is transferred must be equivalent to, or as protective as, the laws in the Data subject’s home country.

8. THE DATA SUBJECT’S RIGHTS REGARDING HIS PERSONAL INFORMATION

The Data subject is entitled to:

8.1. request Stratfinn for access to Personal information Strafinn holds about him/her/it;

8.2. request the correction and/or deletion of his/her/its Personal information;

8.3. request the restriction of the processing of his/her/its Personal information, or object to that processing;

8.4. withdraw his/her/its consent to the processing of his Personal information (where Stratfinn is processing his Personal information based on his/her consent);

8.5. withdraw his/hers/its consent to receive marketing messages;

8.6. request for the receipt or the transfer to another organisation, in a machine-readable form, of the personal information that he/she/it has provided to Stratfinn; and

8.7. complain to his local data protection authority if his privacy rights are violated, or if he/she/it has suffered as a result of unlawful processing of his Personal information.

9. WHAT THE DATA SUBJECT SHOULD DO IF HE/SHE DOES NOT WANT TO PROVIDE STRATFINN WITH HIS/HER PERSONAL INFORMATION

9.1. Where a Data subject is given the option to share his/her/its Personal information with Stratfinn, he can always elect not to do so.

9.2. If a Data subject objects to the processing of his Personal information, or if he/she/it has provided his consent to processing and he later choose to withdraw it, Stratfinn will comply with the request in accordance with its legal obligations. Stratfinn’s legal obligations in respect of the withdrawn information shall therefore cease to exist.

10. IMPORTANT NOTICE TO DATA SUBJECTS

10.1. By visiting Stratfinn’s website and communicating electronically with Stratfinn, the Data subject consents to the processing, including transfer of his Personal information as set out in this Notice.

10.2. Stratfinn is continually improving its methods of communication and adding new functionality and features to its website. Due to these ongoing changes, changes in the law and the changing nature of technology, Stratfinn s data protection practices will change from time to time. If and when its protection practices change, Stratfinn will update this Notice to describe its new practices. The Data subject is encouraged to check it regularly

CONTACT US

For any questions or requests regarding this Notice or if a Data subject would like to exercise his/her rights including contacting the Information officer, please use the following contact information of the Information officer:

Domonique Ramos +27 76 285 8964