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Protection of Personal Information (POPIA) Policy

1. INTRODUCTION

The Protection of Personal Information Act No. 4 of 2013 (“POPIA”) gives effect to the constitutional right to privacy by safeguarding personal information and regulating the manner in which such information may be processed.

Habilis Capital (Pty) Ltd (“Habilis Capital”, “we”, “our” or “us”) recognises the importance of lawful and responsible processing of personal information in achieving its business objectives. As an authorised Financial Services Provider, we are legally obligated to protect personal information relating to our clients, employees, suppliers, and other stakeholders.

This Policy explains how we collect, use, disclose and protect personal information in accordance with POPIA.

This Policy outlines:

  • Who we are

  • What information we collect

  • How we use personal information

  • To whom we disclose personal information

  • How we safeguard personal information

  • Your rights regarding your information

  • How changes to this policy are managed

  • How to contact us
     

2. DEFINITIONS

For purposes of this Policy:

“Data Subject” means the person to whom personal information relates.

“Direct Marketing” means approaching a data subject, in person or via electronic communication, for the direct or indirect purpose of promoting or offering goods or services.

“Information Officer” refers to the person designated in terms of POPIA and the Promotion of Access to Information Act (PAIA) as responsible for ensuring compliance with applicable data protection laws.

“Personal Information” means information relating to an identifiable, living natural person and, where applicable, an identifiable juristic person, including but not limited to:

  • Identity numbers, contact details, and demographic information

  • Financial, tax, employment, or education information

  • Correspondence of a private or confidential nature

  • Opinions, preferences, or views of the data subject

  • Any identifying number, email address, physical address, or online identifier

“Processing” includes the collection, recording, organisation, storage, updating, retrieval, use, distribution, or destruction of personal information.

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3. WHO WE ARE

Habilis Capital (Pty) Ltd is a private company and an authorised Financial Services Provider (FSP 54814).

The objective of this Policy is to:

  • Protect Habilis Capital’s information assets from internal and external threats;

  • Ensure business continuity and minimise operational risk;

  • Protect the confidentiality, integrity and availability of personal information; and

  • Ensure compliance with POPIA and related legislation.

This Policy is available on our website and upon request from our Information Officer.

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4. PERSONAL INFORMATION WE COLLECT

We collect personal information directly from data subjects when:

  • You enter into an investment mandate with us;

  • You correspond with us;

  • You request information about our services;

  • You are employed by or contract with Habilis Capital.

The type of personal information collected depends on the purpose for which it is required. This may include:

  • Identity numbers, names, surnames and contact details

  • Banking details and financial information

  • Tax numbers and regulatory information

  • Employment-related information

  • Any additional information required to comply with regulatory and anti-money laundering requirements

We only collect personal information that is necessary and relevant to the purpose for which it is processed.

Marketing communications are only sent where consent has been provided.

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5. HOW WE USE PERSONAL INFORMATION

We process personal information strictly for lawful and legitimate purposes, including:

  • Managing investment mandates and portfolios

  • Processing transactions and instructions

  • Communicating with clients and stakeholders

  • Verifying identity and complying with FICA requirements

  • Detecting and preventing fraud

  • Complying with legal, regulatory and reporting obligations

  • Maintaining internal records

We do not process personal information for purposes unrelated to the reason for which it was collected.

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6. DISCLOSURE OF PERSONAL INFORMATION

Habilis Capital may share personal information with:

  • Regulatory bodies where required by law

  • Service providers and administrators (such as custodians, administrators, auditors or compliance providers)

  • Third parties with whom we have contractual relationships necessary to provide our services

All third parties are required to maintain confidentiality and comply with applicable data protection standards.

We may also disclose information where legally required or where necessary to protect our rights.

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7. SAFEGUARDING PERSONAL INFORMATION

Habilis Capital is committed to protecting personal information through appropriate technical and organisational measures.

Our controls include:

  • Secure IT systems and encrypted communications

  • Restricted access to personal data

  • Physical security measures

  • Monitoring and logging of access

  • Secure retention and destruction procedures

  • Confidentiality agreements with employees and service providers

Although we take reasonable steps to secure information, no electronic transmission can be guaranteed to be entirely secure. We therefore implement industry-standard safeguards to mitigate risk.

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8. ACCESS AND CORRECTION OF PERSONAL INFORMATION

Data subjects have the right to:

  • Access personal information held by Habilis Capital;

  • Request correction or updating of inaccurate information;

  • Object to the processing of personal information on reasonable grounds;

  • Request deletion of personal information where legally permissible.

We will take reasonable steps to verify identity before providing access or making changes to personal information.

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9. INFORMATION OFFICER DETAILS

Information Officer:
Kevin Pretorius
Munier Badat
Hemal Naran

Telephone: +27 01 492 6552
Email: info@habiliscapital.com

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10. COMPANY DETAILS

Habilis Capital (Pty) Ltd
Company Registration: 2023/220146/07
FSP Number: 54814
Email: info@habiliscapital.com
Telephone: +27 01 492 6552
Website: www.habiliscapital.com

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11. CHANGES TO THIS POLICY

This Policy may be reviewed and updated periodically to reflect legislative amendments, regulatory requirements, or operational changes.

The most current version will always be available on our website.

Where material changes occur, affected parties may be notified directly where appropriate.

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12. HOW TO CONTACT US

If you have questions regarding this Policy, wish to exercise your rights under POPIA, or believe your personal information has not been handled appropriately, please contact us:

Telephone: +27 01 492 6552
Email: info@habiliscapital.com

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