Privacy Notice
What Personal Information does the Company require?
The 10X Personal Information Protection Policy governs the processing of your personal information by 10X Investments (Pty) Ltd and its subsidiaries, namely: 10X Fund Managers (RF) (Pty) Ltd and CoreSolutions Fund Managers (RF) (Pty) Ltd (collectively referred to herein as the (“Company”). You may view the 10X Personal Information Protection Policy by contacting the Information Officer at InformationOfficer@10x.co.za or on +27 21 409 2566.
“Personal Information” is defined in the Protection of Personal Information Act (Act no. 4 of 2013) (“POPIA”) as follows:
“Information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to –
- information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, wellbeing, disability, religion, conscience, belief, culture, language and birth of the person;
- information relating to the education or the medical, financial, criminal, or the employment history of the person;
- any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
- the biometric information of the person;
- the personal opinions, views or preferences of the person;
- correspondence sent by the person, that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
- the views or opinions of another individual about the person; and
- the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.”
“Processing” is defined in POPIA as follows:
“any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including -
- the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
- dissemination by means of transmission, distribution or making available in any form; or
- merging, linking, as well as restriction, degradation, erasure or destruction of information.”
The information we collect
The Company is a Responsible Party in respect of the Personal Information you (Data Subject) provide to the Company.
The Company will collect and process your Personal Information mainly to contact you for the purposes of understanding your requirements and delivering services accordingly. For this purpose, we will collect contact details including your name and organisation, identification number, residential/business operating address, South African Income Tax registration number, South African VAT registration number (if applicable per individual/legal entity), contact numbers, e-mail addresses, banking details, contact details, race, gender, marital status, nationality, and financial information.
The Company may collect information directly from you where you provide us with your personal details. Where possible, we will inform you what information you are required to provide to us and what information is optional.
Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.
How we use your information
The Company will use your Personal Information only for the purposes for which it was collected and agreed with you. In addition, where necessary, your information may be retained for legal or research purposes.
The Company needs your Personal Information to provide you with the following services:
- To establish a legal relationship with you;
- To populate the client account information required on the various on-boarding platforms to open your account; and
- To generate statements and capture contact information related to your investment account or policy;
- To confirm and verify your identity or to verify that you are an authorised user for security purposes;
- For the detection and prevention of fraud, crime, money laundering or other malpractice;
- To conduct market or customer satisfaction research or for statistical analysis;
- To provide you with newsletters, promotional material and other general information pertaining to your our funds;
- For audit and record keeping purposes;
- To comply with legal and regulatory requirements.
Where you provide your personal information in the context of a sale of one of our products or services, you agree to the Company sending you information on news, trends, services, events and promotions for our similar products or services, subject to your right to opt out of receiving such marketing at the time your information is collected and on each subsequent marketing communication thereafter. You may object to receiving direct marketing from the Company at any time by emailing our information officer: InformationOfficer@10x.co.za. Where you elect to exercise the right to opt out of direct marketing, please allow up to 30 days for 10X to effect the change.
How is your Personal Information processed?
Your Personal Information is processed at our Johannesburg office on the 4th Floor, Grindrod Tower, 8a Protea Pl, Sandown, Sandton, 2194 and at our head office on the 14th Floor, The Terraces, 34 Bree St, Cape Town City Centre, Cape Town, 8000. Your Personal Information is stored electronically at our offices.
Disclosure of information
We may disclose your Personal Information to our service providers who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with the privacy requirements as required by the Protection of Personal Information Act.
We may also disclose your information:
- Where we have a duty or a right to disclose in terms of law or industry codes;
- Where we believe it is necessary to protect our rights.
Information security
The Company is legally obliged to provide adequate protection for the Personal Information we hold and to stop unauthorised access and use of Personal Information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your Personal Information remains secure.
Our security policies and procedures cover:
- Physical security;
- Computer and network security;
- Access to personal information;
- Secure communications;
- Security in contracting out activities or functions;
- Retention and disposal of information;
- Acceptable usage of personal information;
- Governance and regulatory issues;
- Monitoring access and usage of private information;
- Investigating and reacting to security incidents.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that Personal Information that we remain responsible for, is kept secure.
We will ensure that anyone to whom we pass your Personal Information agrees to treat your information with the same level of protection as we are obliged to.
How long does the Company keep your Personal Information?
Under South African law, the Company is required to keep your Personal Information for a five (5) year period following the date of termination of the business relationship according to the Company’s Personal Information Retention Policy. After this period, your personal information will be irreversibly destroyed.
What are your rights?
You have a right to have your Personal Information processed in accordance with the conditions for lawful processing of your Personal Information which includes the right to be notified that your Personal Information is being collected or has been accessed or acquired by an unauthorised person.
You have the right of access to your Personal Information. Should you wish to access your Personal Information please contact our Information Officer by emailing InformationOfficer@10x.co.za. When requesting access to your Personal Information you will be required to provide us with a copy of your identity document to enable us to confirm your identity before disclosing details of your Personal Information.
You have the right to object in the prescribed manner to our processing of your Personal Information on reasonable grounds relating to your particular situation unless legislation provides for such processing.
Should you believe that any of your Personal Information held by the Company is incorrect or incomplete, you have the right to request to view this information, rectify it or have it deleted. Please contact the Company’s Information Officer on InformationOfficer@10x.co.za.
In addition, if you wish to complain about how the Company has handled your Personal Information, please contact the Information Officer on InformationOfficer@10x.co.za. The Company’s Compliance Department will investigate your complaint and contact you within two (2) business days of the complaint being lodged and work with you to resolve the matter.
If your query relating to your Personal Information is not, in your opinion, adequately dealt with, you can contact the Information Regulator on 012 406 4818 or inforeg@justice.gov.za to file an official complaint.