We are committed to protecting your privacy and ensuring that your personal information is processed properly, lawfully and in a transparent manner, in compliance with the Protection of Personal Information Act 4 of 2013.

This Privacy Notice explains how we obtain, use and disclose your personal information and aims to inform you of your rights and how to exercise them.

This Privacy Notice sets out:

1. Who we are
2. What personal information we collect and where we collect it from
3. The purposes for which we use your personal information
4. To whom we disclose your personal information
5. How we safeguard your personal information
6. Your rights to access, correct and delete your personal information
7. How to contact us
8. The Information Regulator’s contact details

Who we are

In this Privacy Notice, “Futuregrowth” or “we” refers to Futuregrowth Asset Management Proprietary Limited.

The information we collect

We collect and process your personal information mainly to provide the investment management services as contemplated in our agreements with you (and any services ancillary thereto, including part of our onboarding processes), to grant you access to our services and financial products, to help us improve our offerings to you and for certain other purposes explained below.  In order for us to do this, it is incumbent upon you to provide us with the personal information we request, failing which we cannot enter into a relationship with you, assist you, or fully comply with our contractual obligations to you.

When you provide us with information about third parties (for example your clients, service providers or parties related to you), we will process their personal information in order to give effect to our agreement and in order to pursue your and our legitimate interests.  We will furthermore process personal information for the purposes set out in this Privacy Notice.  You warrant that, when you give us personal information about third parties, this information is accurate and correct and you have received their permission for the purposes set out in this Privacy Notice of any other related purposes.

The type of information we collect will depend on the purpose for which it is collected and used, set out herein.  We will only collect information that we need for that purpose.

We collect information directly from you where you provide us with your personal information, for example when you apply for a product or services from us or when you submit enquiries to us or contact us.

We also collect information about you and/or your related parties from other parties, such as third parties, for example anti-money laundering.

We have a duty to take all reasonably practicable steps to ensure that your personal information is complete, accurate, not misleading and that it is updated on a regular basis.  To enable this, we will always try to obtain personal information from your directly and we will appreciate it if you would similarly ensure that your personal information processed by us, is up to date and accurate.  You can do this by engaging with any of the Futuregrowth contacts on our website.  Where we are unable to obtain personal information from you directly, we will make use of verifiable independent third party data sources.

Website usage information is collected by using cookies.  For more information on how we deal with cookies you can view our Privacy Policy on the Futuregrowth website.

Purpose for which we use your information

We will only use your information for the following purposes:

• To conclude a legal agreement with you and to perform the obligations required in terms of such agreement which includes, investment management services such as managing your portfolio, reporting to you and to keep you apprised on developments pertaining to your portfolio(s)
• To pursue our legitimate interests, which include:

1. Compiling relevant reports;
2. Complying with requests from any internal or external auditor, or any regulatory or supervisory body;
3. Compliance with any regulatory requirements and/or industry codes applicable to the financial services industry;
4. Corresponding with you;
5. Confirming and verifying our identity, address and banking details and maintaining the accuracy thereof;
6. Conducting the requisite client identification and verification process as required in terms of the Financial Intelligence Centre Act;
7. To conduct sanction screening against all mandatory and non-mandatory sanctions lists;
8. Detecting and preventing fraud, crime and money-laundering (or other malpractice);
9. Offering financial products and services to you;
10. Maintaining our business relationship with you;
11. Conducting market and/or client satisfaction research for statistical analysis;
12. Protecting your and/or our interests in legal proceedings;
13. Processing your marketing preferences (and where you have unsubscribed from certain direct marketing communications, keeping a record of your information and request to ensure that we do not send such direct marketing to you again); and
14. Resolving any complaint

Disclosure of information

We may disclose your information to our service providers where it is necessary to give effect to our obligations in terms of our legal agreements with you.

Information security

We are legally obliged to provide adequate protection for your personal information we hold and to stop the unauthorized access and use thereof.  We will, on an ongoing basis, continue to review our security controls and related processes to ensure that your personal information is secure.

Our security procedures and policies cover:

1. Physical security;
2. Computer and network security;
3. Access to persona information;
4. Secure communications;
5. Retention and disposal of personal information;
6. Acceptable usage of personal information;
7. Governance and regulatory aspects;
8. Monitoring access and usage of personal information; and
9. Investigating and reacting to security incidents.

When we contract with third parties, we will take steps to ensure that there are appropriate security, privacy and confidentiality obligations on third parties to ensure that personal information that we remain responsible for, is kept secure.

Changes to this Privacy Notice

Please note that we may amend this Privacy Notice from time to time.  Please check this website periodically to inform yourself of any changes.

How to contact us

If you have any questions about this Privacy Notice or believe that we have not adhered to it, or need further information about our privacy practices, please contact our Compliance Officer directly at Rkieser@futuregrowth.co.za.

Information Regulator

You have the right to lodge a complaint directly with the Information Regulator, at the following contact details:

Website: http://www.justice.gov.za/inforeg/index.html

General enquiries: inforeg@justice.gov.za

Complaints: complaints.IR@justice.gov.za