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.
Data privacy and data protection is important to 33 Actuarial and Advisory and this Policy sets out the POPIA
principles in line with existing FAIS requirements to ensure the safekeeping of all Data by 33 Actuarial and
Advisory and Persons/ Employees/ Parties (as applicable). This Policy applies to all Data obtained via
products, services, websites, events operated by 33 Actuarial and Advisory or by any other means.
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.
33 Actuarial and Advisory has appointed an Information Officer, Eddie Theron, who is a director and
shareholder at 33 Actuarial and Advisory. Eddie will be responsible for ensuring that 33 Actuarial and
Advisory has been properly informed and trained on ensuring the safekeeping and protection of Information
in 33 Actuarial and Advisory and that the required processes are implemented to ensure compliance. The
Information Officer can be contacted at Tel: 082 219 8080 or Email: eddie@33actuarial.com.
The type of Information 33 Actuarial and Advisory collects will depend on the purpose for which the Data is
collected and used. 33 Actuarial and Advisory will collect the necessary Information from Data Subjects for
various purposes, including the following:
• rendering suitable services for e.g. financial services (including the rendering of advice and
intermediary services) and administrative services to Data Subjects;
• improving services and product offerings to Data Subjects;
• providing information and resources most relevant and helpful to Data Subjects;
• appointing suitable individuals/ companies to provide financial services/ products to Data Subjects;
• ensuring compliance with legislation that requires specific information to be collected.
Data Subjects have the right to request a copy of the Information that 33 Actuarial and Advisory hold on
them or their business. Should a Data Subject wish to obtain any such information, the Data Subject may
request it by contacting the Information Officer on the details provided above. Any such access
request may be subject to the payment of an allowable administration fee.
33 Actuarial and Advisory will not disclose or share Information relating to any Data Subject unless:
• it is specifically agreed with the Data Subject
• it is already publicly available or in the interests of the public
• required in terms of Law or if 33 Actuarial and Advisory believes in good faith that the Law requires
disclosure thereof.
33 Actuarial and Advisory’s PAIA Manual (in terms of the Promotion of Access to Information Act, 2 of 2000)
sets out the process for access by third parties to a Data Subject’s Information kept by 33 Actuarial and
Advisory, and the instances in which it may be refused.
33 Actuarial and Advisory collects Information in various ways e.g. directly from individuals (for example,
when purchasing a financial product, registering an account, using a product, or signing up for a
newsletter), from employers, publicly available information, through cookies, and/or similar
technology.
Where possible, 33 Actuarial and Advisory must inform Data Subjects which information they are legally
required to provide to 33 Actuarial and Advisory and which information is optional.
With the Data Subject’s consent, 33 Actuarial and Advisory may supplement the information with other
information received from other companies and/or organizations such as the South African Revenue
Services (SARS) in order to enable 33 Actuarial and Advisory to render suitable and proper services to Data
Subjects.
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. 33 Actuarial and Advisory will keep this information in a contact
database for future reference, as needed.
33 Actuarial and Advisory may use certain Information provided by Data Subjects to offer them further
services that 33 Actuarial and Advisory 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 33 Actuarial and Advisory, IT may unsubscribe from the
services or contact the Information Officer at the contact details provided above.
33 Actuarial and Advisory may track information about a Data Subject’s usage and visits on 33 Actuarial and
Advisory’s website. This Information may be stored in usage or web server logs, which are records of the
activities on 33 Actuarial and Advisory’s services, products and/or sites. 33 Actuarial and Advisory’s servers
automatically capture and save such Information electronically. Some examples of the Information that may
be collected include the Data Subject’s:
• Unique Internet protocol address
• Name of the Data Subject’s the unique Internet Service Provider
• The city, state, and country from which a Data Subject accesses 33 Actuarial and Advisory’s website
• The kind of browser or computer used
• The number of links clicked within the site
• The date and time of visits to the site
• The web page from which the Data Subject arrived on 33 Actuarial and Advisory’s site
• The pages viewed on the site
• Certain searches/queries conducted on the site via 33 Actuarial and Advisory’s services, products
and/or Websites.
The information collected in usage or web server logs help 33 Actuarial and Advisory to administer the
services, products and sites, analyse its usage, protect the product and/or website and content from
inappropriate use and improve the user's experience.
In order to offer and provide a customized and personal service through 33 Actuarial and Advisory’s products
and websites, 33 Actuarial and Advisory may use cookies to store and help track information about the Data
Subject. A cookie is a small text file sent to the Data Subject’s device that 33 Actuarial and Advisory uses to
store limited information about the Data Subject’s use of the services, products or website.
33 Actuarial and Advisory uses cookies to provide the Data Subject with certain functionality (such as to
enable access to secure log-in areas and to save the Data Subject having to re-enter Information into
product, services or website forms) and to personalize 33 Actuarial and Advisory’s services, products or
website content. Without cookies, this functionality would be unavailable.
33 Actuarial and Advisory may retain personal information for purposes of reporting, administration,
monitoring its website or to communicate with Data Subjects. Information may be retained only to serve
the purpose of collecting the Information and be deleted/destroyed once the purposes has been fulfilled,
subject to subject to other regulatory requirements where Information is to be kept for a specific prescribed
period. Information and records of a personal nature of Clients and/or Employees will be stored for a period
of 5 years before being destroyed.
Data Subjects are required to inform 33 Actuarial and Advisory should there be any changes to the
Information kept by 33 Actuarial and Advisory. A Data Subject may request 33 Actuarial and Advisory to
correct, amend, update or delete its Information at any time when applying or making use of any financial
products or services of 33 Actuarial and Advisory, by contacting the Information Officer at the contact details
provided above. 33 Actuarial and Advisory will take all reasonable steps to confirm the Data Subject’s
identity before making changes to Information.
33 Actuarial and Advisory will take all reasonable precautions to protect Information from loss, misuse,
unauthorized access, disclosure, alteration, and destruction. 33 Actuarial and Advisory will not sell, rent, or
lease mailing lists with Information to third parties and will not make a Data Subject’s Information available
to any unaffiliated parties, except for approved agents, suppliers, and contractors, or as otherwise
specifically provided for, as agreed with the Data Subject in writing or as required in terms of any Law.
33 Actuarial and Advisory may disclose Information of a Data Subject or Information about a Data Subject’s
usage of 33 Actuarial and Advisory’s financial services, financial products, websites, or mobile applications
to unaffiliated third parties as necessary to enhance services, financial product experience to meet 33
Actuarial and Advisory’s obligations to content and technology providers or as required by law, subject to
agreements in place that provides for the protection of Information of Data Subjects.
33 Actuarial and Advisory has implemented appropriate security measures to help protect Information
against accidental loss and from unauthorized access, use, or disclosure. 33 Actuarial and Advisory stores
Information about Data Subjects in a restricted access server with appropriate monitoring and uses a variety
of technical security measures to secure Information, including intrusion detection and virus protection
software. 33 Actuarial and Advisory may also store and process Information in systems located outside 33
Actuarial and Advisory premises or the Data Subject’s home country. However, regardless of where storage
an processing may occur, 33 Actuarial and Advisory takes appropriate steps to ensure that Information is
protected as required under relevant Data Protection/Privacy laws.
The Data Subject’s access to some of 33 Actuarial and Advisory’s services and content may be password
protected and non-disclosure of such usernames and passwords are required to ensure the safekeeping of
the Data Subjects Information. It is recommended that the Data Subject sign out and close the browser of
the account or service at the end of each session.
33 Actuarial and Advisory is legally obliged to provide adequate protection of Information, hold and prevent
unauthorised access and use of Information, 33 Actuarial and Advisory is therefore committed to ensure
that all Information of the Data Subject (FSP, Clients and/or Employees) will be kept safe and secure and not
be disclosed to any unauthorized third parties, without the consent of the relevant Data Subject. 33 Actuarial
and Advisory may from time-to-time transfer Information within and between various worldwide locations
in compliance with the country of origin’s regulations and this Policy.
Persons/ Employees/ Parties (as applicable) are not allowed to disclose any Information to any unauthorized
third party as it may lead to a breach, disciplinary action and possible dismissal.
33 Actuarial and Advisory takes reasonable steps to protect Personal Information, which is held in a
firewalled server. 33 Actuarial and Advisory can however not guarantee the security of information
transmitted to it electronically from Data Subjects and they do so at their own risk. 33 Actuarial and Advisory
maintains administrative, technical and physical safeguards to ensure protection of information against loss,
misuse or unauthorized access, disclosure, alteration or destruction of the information provided to 33
Actuarial and Advisory by the Data Subject or you’re the Data Subjects employer.
33 Actuarial and Advisory seeks to ensure compliance with Data Protection/Privacy regulations, laws and
industry best practices in respect of the security of a Data Subjects Personal Information. and despite 33
Actuarial and Advisory’s best endeavours to ensure protection of information. Where the Data Subject is
located in another country with other data protection/privacy laws, 33 Actuarial and Advisory may transfer
Personal Information to such other countries, but they may not always guarantee the same level of
protection for Personal Information as the one in which the Data Subject resides (despite 33 Actuarial and
Advisory’s best endeavours to ensure protection of Information. By providing information to 33 Actuarial
and Advisory, the Data Subject consents to these transfers.
By signing this document, I authorise the organisation’s approval and adoption of the processes and
procedures outlined herein.
