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Privacy Policy

1. INTRODUCTION

This Privacy Policy should be read together with our Website Terms and Conditions. All terms and conditions, including defined terms, of our Website Terms and Conditions, are incorporated by reference into this Privacy Policy and have the same meaning unless the context indicates otherwise. In the event of any conflict between any terms in our Website Terms and Conditions and the terms of this Privacy Policy, this Privacy Policy shall prevail. If you or your organization has an individual agreement with us, that agreement may have privacy terms that also apply to the personal information you provide to us under that agreement. Please review the terms in that agreement as they may be different or more restrictive than the terms in this Privacy Policy.

2. GENERAL TERMS

Purpose of this Privacy Policy  Neoteric Kapital respects your privacy and is committed to protecting your Personal Information. This Privacy Policy aims to give you information on how Neoteric Kapital collects and processes the Personal Information you provide through your use of the Website or by way of your interaction with us. Please also use the Glossary below to understand the meaning of some of the terms used in this privacy notice. This website is not intended for children and we do not knowingly collect data relating to children.  This Privacy Policy is issued on behalf of the Neoteric Kapital so when we mention “ Neoteric Kapital”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company  responsible for processing your data. If you have any questions about this Privacy Policy, including any requests to exercise legal rights, please contact us at: Email:  info@neoterickapital.co.za  You may choose, however, to approach the South African Information Regulator instead at https://justice.gov.za/inforeg/.

  • Changes to this Privacy Policy and your duty to inform us of changes This Privacy Policy was last updated on 06 October 2020. It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
  • Third-party links The Website may, from time to time, contain links to and from the websites of our content creation, development and distribution networks and their affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Information to these websites

3. DATE WE COLLECT ABOUT YOU

Personal Information, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together follows.

  • Identity Data includes first name, last name and photograph.
  • Contact Data includes billing address, email address and any phone number used to call our customer service number.
  • Financial Data includes bank accounts, statements,  payment card details and other financial records.
  • Transaction Data includes details about payments from and to you and details of products and services you have purchased from us.
  • Technical Data includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. As well as information about your visit, including the full URLs, clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. We do not collect any Special Categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political persuasion, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  •  Acceptance required. We rely on consent as a legal basis for processing your Personal Information. You are therefore required to accept all the terms of this policy when you register for or use our website or any of our products or services. If you do not agree with anything in this policy, then where we need to collect Personal Information by law and you fail to provide that data when requested, we may not be able to evaluate an application from you or enter into a contract to provide products or services to you. Where we need to collect Personal Information under the terms of a contract, we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have with you. We will notify you if this is the case at the time. By using our products or services, you understand that we will collect and use your personal information as described in this Privacy Policy. You have the right to decline consent and/or if provided, to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you can request that we stop using your personal information for direct marketing purposes.

4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We use different methods to collect data from and about you including through:

  •  Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes Personal Information you provide when you register to use our Website, engage with learning content, purchase or subscribe to our products and services, search for a product, participate in discussion boards or other social media functions on our Website, enter a competition, promotion or survey, and when you report a problem with our Website.
  •  Automated technologies or interactions. We automatically collect Technical Data about your equipment, browsing actions and patterns as you use the Website. We collect this Personal Information by using cookies and other similar technologies.
  •   Third parties or publicly available sources. We also work closely with other third parties (including, for example, business partners, sub-contractors in technical and payment services, analytics providers, search information providers, credit reference agencies) and we may receive Personal Information about you from them where they are legally allowed to share your personal information with u

5. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

  • Where we need to perform the contract, we are about to enter into or have entered into with you or the operator of your Personal Information.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION

We have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data.

  • Marketing We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising:
  • Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
  • Opting out You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or. Where you opt out of receiving these marketing messages, this will not apply to Personal Information provided to us as a result of a product/service purchase, product/service experience or other transactions.
  • Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
  • Change of purpose We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. DISCLOSURES OF YOUR PERSONAL INFORMATION

We will not sell Personal Information and no Personal Information will be disclosed to anyone except as provided in this privacy policy. We may disclose your Personal Information if required:

  • by a subpoena or court order; or
  • to comply with any law. We may share your Personal Information:
  • with other companies within the Retail Capital Group;
  • with our service providers under contract, as permitted by law;
  • with credit bureaus to report account information, as permitted by law;
  • with social media platforms when you use tools or functionality on our website provided by those platforms (such as “recommend” or “share” buttons); and
  • with marketing partners where you register for events, webinars;
  • with public or government authorities to follow applicable law or to respond to legal process (like a subpoena). We also may share your personal information when there are threats to the physical safety of any person, violations of this Privacy Policy or other agreements, or to protect the legal rights of third parties, including our employees, users, or the public as required by law;
  • for business transactions like a merger, or sale of our assets, or as part of the due diligence for such contemplated transactions. If a corporate transaction occurs, we will provide notification of any changes to control of your personal information, as well as choices you may have;
  • with your consent. For example, with your consent, we post user testimonials that may identify you; and
  • with your employer or organization where you create an account or user role with an email address assigned to you as an employee, contractor or member of an organization, that organization may find your account and take certain actions that may affect your account.

We may need to disclose Personal Information to our employees that require the Personal Information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel. Any of our employees or personnel that handle your Personal Information will have signed non-disclosure and confidentiality agreements.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We execute regular penetration tests using third party software in order to continually test and indicate the strength of our technical defences. 

9. COOKIES & INFORMATION

Our website uses cookies to enhance our users’ experience with our website. Cookies are small packets of information placed on your device when you visit our website and/or engage in transactions with us. Cookies help us to tailor your experience to you as an individual user, allow us to recognize your when you re-visit our website, and assist us in keeping your account secure. By visiting our site and engaging in our services and/or purchasing our products, you are agreeing to the use of cookies and similar technologies for the purposes set forth in this policy. You can learn more about cookies by following these links:

https://www.whoishostingthis.com/resources/cookies-guide/

https://en.wikipedia.org/wiki/HTTP_cookie

http://www.whatarecookies.com

http://www.allaboutcookies.org/cookies/

Our website follows industry custom and practice with respect to the types of cookies we use and the technology inherent in the cookies we choose. The types of cookies we use will change as the technology and utility behind them advance Our use of cookies allows us to display advertising intended to be more relevant to our users as well as to identify return visitors to our website. We may also use cookies to collect aggregate data to help us improve the products and services we provide. We do not provide any of your personal information to advertisers without your consent.

You may control the use of cookies by us and other websites through your browser settings. Most browsers will allow you to turn off cookies. Our website, however, may not function as intended or provide you with as satisfying an experience should you choose to do so. Most browsers will also allow you to review and delete cookies, including those originating from our website. You should consult with your browser’s setting and help page to learn how to control cookies on your particular browser.

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