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In accordance with disclosures required by data protection laws such as POPIA and GDPR the following information provides an overview of how we, Sanlam Global Investment Solutions (“SGIS”), use certain information we hold about individuals and companies (this is known as “personal data”), such as clients, authorised representatives, ultimate beneficial owners, guarantors, beneficiaries, and individual business contacts (all referred to below as “You” or “Your”). This notice also outlines Your rights under data protection law.
In data protection law terminology, such role lies with the data “controller”, namely:
Sanlam Global Investments Solution LtdVictoria Place31 Victoria StreetHamilton HM 10Bermuda
SGIS is required to handle (or “process”) Your personal data securely and otherwise in accordance with applicable data protection laws.
For the purposes of applicable data protection law, SGIS is typically the “data controller” of any personal information provided to us. Specifically, your data will be controlled by the SGIS that you have instructed, or that is providing services to or communicating with you. In certain circumstances, we may also act as a “processor” (meaning that we process personal data only in accordance with the directions of a data controller, or as otherwise permitted by law).
Please read the following information carefully to understand our views and practices regarding how we handle personal information.
Should You have queries or complaints about the way in which SGIS processes Your personal data, you may send an email to firstname.lastname@example.org.
SGIS may collect personal information from you in the course of our business, when you contact us or request information from us, when you instruct us to provide services, when you use our website, or as a result of your relationship with any of our personnel or clients.
The personal information that we process includes:
We may collect your personal information:
We collect most of this information directly from you, or through your use of our website. However, we may also collect data about you from a third party source, such as our clients, your employer, other parties to matters in which we are involved, platform operators for technology used in our business (e.g. webinar platforms), other organisations that you have dealings with, regulators or other government authorities, credit reporting agencies, information service providers, or from publicly available records.
The information you provide may be confidential, and we will maintain such confidentiality and protect your information in accordance with our professional obligations and applicable law. We have arrangements in place with personnel and service providers who may process your personal information, to ensure that confidentiality is maintained.
Whether we receive your personal data directly from you or from a third party, we will only use your personal information if we have obtained your consent, or if we have another lawful basis upon which to do so (e.g. for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into such contract; for compliance with a legal obligation on us; to protect your vital interests or those of another natural person; or for our own legitimate interests, or those of a third party, except where such interests are overridden by your own rights or interests).
The purposes for which we process your personal information are as follows:
The purposes for which SGIS uses and processes Your personal data are summarised below, together with the specific grounds under data protection law (see the bold bullet points) which allow us to do this:
Where necessary to fulfil Your instructions to us and for the other purposes outlined above, SGIS may share information about You with a range of recipients including (but not limited to) the following: credit reference agencies, background screening providers, financial institutions, funds, payment recipients, payment and settlement infrastructure providers, exchanges, regulators, courts, public authorities (including tax authorities), Sanlam Group entities and service providers, professional advisors, auditors, insurers and potential purchasers of elements of our business.
It may sometimes be necessary for us to share your personal information with other Sanlam offices or professional services firms around the world, who provide services to us or on our behalf. These procedures include contractual obligations to ensure that all such entities safeguard your personal information and use it only for the purposes that we have specified and communicated to you. When we transfer your information to other countries, we will use, share and safeguard that information as described in this Privacy Notice.
In general terms, we retain Your personal data if necessary, for the purposes for which We obtained it (see section 3 above). In making decisions about how long to retain data SGIS takes account of the following:
We may use Your personal data to give You information about products and services offered by us or our Sanlam Group affiliates that we think You may be interested in receiving. Where we consider it appropriate, and so far as compliant with marketing laws, we may contact You in this regard by email or telephone. We refer to Your right to object to marketing activity in the next section.
“Profiling” in the context of this notice is the use of an automated process to analyse personal data in order to assess or predict aspects of a person’s behaviour. SGIS does not use profiling.
Various rights may be available to you, depending on the circumstances and the applicable law. We summarise key rights likely to be available to most data subjects:
You are not required by law to provide us with Your personal data. However, if You refuse to do so, SGIS may not be able conduct further business with You. For example, in order to satisfy our anti-money laundering obligations, we must verify the identity of our clients. This inevitably requires us to collect certain personal data from current and prospective clients.
We may from time to time make changes to this Privacy Notice. Where these are likely to be material, we will communicate these in advance. Otherwise, these will become effective once the amended Privacy Notice is posted on our website. Please check back regularly to keep informed of updates to this Privacy Notice.