Privacy & POPI Policy

1. DEFINITIONS AND INTERPRETATION

1. 1.1 "Personal Information" refers to any information that identifies or can be used to identify an individual, including but not limited to names, contact numbers, demographic information, and any other information that can be linked to a specific person.
2. 1.2 "Processing" means any operation or set of operations performed on personal information, whether automated or manual, including collection, storage, use, disclosure, deletion, or destruction of such information.
3. 1.3 "Responsible Party" refers to the entity that determines the purpose and means of processing personal information, in this case, STOICFX (PTY) LTD.
4. 1.4 "Client" refers to any individual or entity that engages with the services provided by STOICFX (PTY) LTD, including but not limited to users of the platform, potential clients, and existing customers.
5. 1.5 "Third Party" refers to any individual or organization that is not a party to this Policy and does not have a direct relationship with STOICFX (PTY) LTD, including but not limited to service providers, business partners, and external agencies.
6. 1.6 "Cookies" are small text files that are placed on your device when you visit our website, used to enhance your browsing experience and collect data about your usage patterns.
7. 1.7 "FSP" stands for Financial Services Provider, which in this context refers to STOICFX (PTY) LTD.
8. 1.8 "Data Subject" refers to an individual whose personal information is being processed by STOICFX (PTY) LTD.
9. 1.9 "Applicable Laws" refers to the legal frameworks governing the protection of personal information, including the Protection of Personal Information Act (POPIA) and any other relevant laws in the Republic of South Africa.
10. 1.10 "Policy" refers to this Privacy and Protection of Personal Information Policy, which outlines how STOICFX (PTY) LTD collects, uses, protects, and discloses personal information.
11. 1.11 "You" and "Your" refer to the individual or entity accessing the services of STOICFX (PTY) LTD, including clients and potential clients.
12. 1.12 "We," "Us," and "Our" refer to STOICFX (PTY) LTD as the organization responsible for processing your personal information in accordance with this Policy.
13. 1.13 "Consent" refers to any freely given, specific, informed, and unambiguous indication of a Data Subject's wishes, which signifies agreement to the processing of personal information relating to them.
14. 1.14 "Legitimate Interest" refers to a lawful basis for processing personal information when it is necessary for the purposes of the legitimate interests pursued by STOICFX (PTY) LTD, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject.
15. 1.15 These definitions are provided to facilitate a clear understanding of the terms used in this Policy. Any interpretation of this Policy shall be guided by these definitions.

2. PERSONAL INFORMATION

1. 2.1 Personal information is collected only when individuals knowingly and voluntarily submit their details by signing up/registering on STOICFX (PTY) LTD's platform(s) and/or site(s). This information may be necessary to deliver specific services or to respond to requests and inquiries related to those services. Our commitment to transparency means that individuals will always be informed about the purpose of data collection.
2. 2.2 It is the intention of the Financial Services Provider (hereinafter referred to as "the FSP"), STOICFX (PTY) LTD to safeguard individuals' personal information, ensuring it is protected from any misuse or unauthorized access. This Policy is designed to align with the privacy laws applicable in the Republic of South Africa, reflecting our dedication to ethical data management practices.
3. 2.3 The FSP collects, stores, and utilizes personal information provided by both natural and juristic persons to deliver comprehensive financial services. By doing so, we aim to enhance customer experiences while ensuring that all data handling processes comply with relevant regulations and best practices in data protection.

3. USE OF INFORMATION

1. 3.1 STOICFX (PTY) LTD needs to collect personal and/or other information for the following purposes:
   1. For underwriting purposes;
   2. Assessing and processing claims;
   3. Confirming and verifying an individual's identity;
   4. For purposes of claims history;
   5. For the detection and prevention of fraud, crime, money laundering or other malpractice;
   6. Conducting market or customer satisfaction research;
   7. For audit and record keeping purposes;
   8. In connection with legal proceedings;
   9. Follow an individual's instructions;
   10. Inform an individual of services;
   11. Make sure the FSPs business suits the individual's needs.
2. 3.2 Personal information submitted by individuals is used solely for the purpose for which it was intended. This ensures that data handling aligns with the expectations of our clients and maintains the integrity of their information. Copies of any correspondence that may contain personal information are securely archived for record-keeping and backup purposes only, allowing us to maintain accurate records while safeguarding privacy.
3. 3.3 STOICFX (PTY) LTD is committed to upholding the confidentiality of personal information. We will not share an individual's information with any third parties without obtaining explicit consent, except where required by law for any legitimate purposes. This approach reinforces our dedication to protecting client privacy while ensuring compliance with relevant legal obligations. Our priority is to foster trust and transparency in all interactions.

4. HOW DO WE OBTAIN THE INFORMATION?

1. 4.1 STOICFX (PTY) LTD primarily collect your personal information directly from you to ensure accuracy and relevance. However, there are instances where we may obtain information from external sources, such as service providers who assist us in verifying your identity, processing payments, or enhancing our marketing efforts. Additionally, we may gather information from publicly available sources or third parties to better serve you and improve our offerings.
2. 4.2 If you provide us with, or allow us to obtain, personal information about someone else, you affirm that you have obtained their consent to share or collect this information in accordance with this Privacy Policy. You also confirm that you have informed them of their rights to access and request corrections to their personal information.
3. 4.3 Furthermore, we may collect information through cookies on our website to enhance your browsing experience and gather insights into how our services are used. For more details on our use of cookies and your options regarding them, please refer to Clause 7. Your privacy is important to us, and we are committed to handling your information responsibly.

5. WHAT INFORMATION DO WE COLLECT?

1. 5.1 The POPIA only applies where either the responsible party is domiciled in the Republic of South Africa or is using means in the Republic of South Africa. POPIA does not refer to the offering of goods or services or monitoring of individuals from abroad.
2. 5.2 As part of our procedures for onboarding and verification, we may gather personal information from You which may include, but is not limited to, the following:
   1. Contact Details: This includes information such as your name, email address, phone number, and physical address, allowing us to communicate effectively with you.
   2. Application Information: We may request details such as your date of birth, photo identification, identity documents, corporate documents for legal entities, sources of funds and wealth, banking information, tax details, account preferences, as well as the purpose or intent of your purchase. This also includes information related to your cryptocurrency wallet addresses to facilitate transactions securely;
   3. Device Information: We may collect technical details such as your IP address, device specifications, operating system, web log data, geographical location, and cookie information. This data helps us optimize our services for your device and enhance user experience;
   4. Engagement Information: This encompasses records of any interactions you have with us, including inquiries, feedback, and other forms of communication. This helps us understand your needs and improve our services;
   5. Marketing Preferences: We gather details regarding your preferences for receiving marketing communications, ensuring that we tailor our outreach in a way that aligns with your interests.
3. 5.3 Please keep in mind that you are not obligated to provide the requested information. However, if you choose not to disclose certain details, it may affect our ability to offer you specific information or limit your access to our platform and services. Your privacy and satisfaction are our priorities, and we strive to handle your personal information responsibly and transparently.

6. YOUR RIGHTS TO PERSONAL INFORMATION

1. 6.1 We retain your personal information for a period of seven (7) years from the date of your last interaction with us. This retention period allows us to comply with legal obligations, resolve disputes, and enforce our agreements. You have the right to request the deletion of Your personal information at any time.
2. 6.2 You have the following rights to your personal information:
   1. Right to Erasure: You have the right to request that we correct, destroy, or delete your personal information. We will process such requests as soon as reasonably practicable, ensuring that your data is handled in accordance with your wishes.
   2. Right to be Informed: You have the right to be informed about the personal information we collect, including the source of the data, the purpose for processing it, and whether providing this information is voluntary or mandatory. Additionally, we will clarify your rights regarding your personal information and how you can exercise them.
   3. Right to Object: You have the right to withdraw your consent at any time. To do so, simply submit Form 1 of the POPIA Regulations to us. We will honor your request promptly, ensuring that your preferences are respected.
   4. Right of Access: You are entitled to access your personal information that we process. Upon request, we will provide you with the relevant information within a reasonable timeframe, allowing you to understand how your data is being used.
   5. Right to Data Portability: You have the right to request the transfer of your personal information to another organization or directly to you. We will facilitate this process to ensure that you can manage your data as you see fit.
   6. Right to Complain: If you have concerns about our processing of your personal information, you have the right to lodge a complaint with a supervisory authority. We take such concerns seriously and are committed to addressing them in a timely and effective manner.

Your rights are integral to our commitment to protecting your personal information, and we are here to support you in exercising them.

7. COOKIES

1. 7.1 A "Cookie" is a small text file placed on your device that helps us enhance your browsing experience. In addition to cookies, we may collect and store approximate location data derived from your IP address or mobile GPS. It's important to note that while third-party advertisers on our site may also use cookies, we do not have control over their practices and cannot be held responsible for their actions.
2. 7.2 Cookies and similar technologies help us remember your browser or device between visits to our website. We utilize this technology for various purposes, including remembering your preferences and settings, enhancing security measures, analyzing traffic and usage trends, and assessing the effectiveness of our features and marketing efforts. The information collected may include details such as device type, usage date and time, referring websites, IP address, and advertising identifiers.
3. 7.3 By using our website, you consent to our use of cookies and similar technologies. You can manage your cookie preferences through your browser settings, allowing you to control which cookies are stored on your device. Your privacy is important to us, and we are committed to ensuring that your experience on our site is both secure and tailored to your needs.

8. PRIVACY OF MINORS

1. 8.1 Our services are not intended for individuals under the age of eighteen (18) years. We do not knowingly collect personally identifiable information from children. In accordance with Section 35 of the Protection of Personal Information Act (POPIA), the personal information of a child may be processed only if consent is obtained from a relevant competent person, along with other specified exceptions.
2. 8.2 If you are a parent or guardian and you believe that your child has provided us with personal information, we encourage you to contact us immediately. We take such matters seriously and will take appropriate steps to delete any information related to your child from our records. Protecting the privacy and safety of young individuals is a priority for us, and we are committed to ensuring that our practices align with legal requirements and best practices regarding the handling of minors' personal information. Thank you for your understanding and cooperation in this matter.

9. APPLICABLE LAWS

1. 9.1 This Policy will be governed by the laws of the Republic of South Africa.
2. 9.2 By engaging with our services, you consent to the jurisdiction of the South African courts for any disputes that may arise in connection with this Policy. This means that any legal actions or proceedings related to this Policy will be addressed in accordance with South African law and will be handled in the appropriate legal venues within the country.
3. 9.3 We encourage you to familiarize yourself with your rights and obligations under this Policy, as well as the relevant legal framework, to ensure a clear understanding of how any potential disputes will be managed. Thank you for your cooperation and trust in our commitment to uphold these standards.

10. SECURITY

1. 10.1 STOICFX (PTY) LTD strives to ensure the security, integrity and privacy of personal information submitted. The FSP will review and update its security measures in accordance with future legislation and technological advances. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure, however, the FSP will endeavour to take all reasonable steps to protect the personal information, which an individual submits to the FSP or to the FSPs online products and services. The FSP will always set the highest standards to ensure the integrity of their systems.
2. 10.2 The FSP may engage with other organisations to provide support services to the FSP. Third Parties are obliged to respect the confidentiality of any personal information held by the FSP. A Service Level agreement is in place with all Third parties to ensure adherence to all Privacy Policies.
3. 10.3 The FSPs employees are obliged to respect the confidentiality of any personal information held by the FSP. All employees are required to sign an employment contract which includes a confidentiality clause.
4. 10.4 The FSP will not reveal any personal information to anyone unless:
   1. 10.4.1 It is compelled to comply with legal and regulatory requirements or when it is otherwise allowed by law;
   2. 10.4.2 It is in the public interest;
   3. 10.4.3 The FSP needs to do so to protect their rights.
5. 10.5 The FSP endeavours to take all reasonable steps to keep secure any information which they hold about an individual, and to keep this information accurate and up to date. If at any time, an individual discovers that information gathered about them is incorrect, they may contact the FSP to have the information corrected.
6. 10.6 The FSP recognises the importance of protecting the privacy of information collected about individuals, information that is capable of identifying an individual (personal information).

11. OTHER WEBSITES

Our Service may contain links to other websites that are not operated by STOICFX (PTY) LTD. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

12. CHANGES TO THIS POLICY

We may update our Privacy Policy from time to time to reflect changes in our practices or legal requirements. Whenever we make significant updates, we will notify you by posting the revised Privacy Policy on this page. It is your responsibility to review the Policy regularly, particularly each time you use our website or access our platform and services. To ensure you are informed about the latest updates, please pay attention to the "Last updated" date at the top of this Privacy Policy.

We strongly encourage you to review this Privacy Policy periodically for any changes or updates. Any modifications to this Privacy Policy will take effect immediately upon being posted on this page. By continuing to use our services after changes have been made, you acknowledge your acceptance of the updated terms. Your understanding and awareness of our Privacy Policy are important to us, and we appreciate your cooperation in keeping yourself informed about how we handle your personal information.

13. CONTACT INFORMATION

Any questions relating to the FSPs privacy policy, or the treatment of an individual's personal data may be addressed to the contact details below:

Information officer: Zachary Estes
Telephone number: (031) 100 2202
Postal address: 47 BUCKINGHAM ESTATE, 26 LION STREET, STERREWAG, PRETORIA, GAUTENG, 01814.
Physical Address: 47 BUCKINGHAM ESTATE, 26 LION STREET, STERREWAG, PRETORIA, GAUTENG, 01814.
Email address: [email protected]
Website: https://stoicfx.com/