Privacy Policy

At Orchard Investment Management, accessible from http://www.orchard-im.co.za, one of our main priorities is the privacy of our visitors, clients, employees and service providers and have established a policy to maintain the confidentiality of information shared with us.

1.1    We, our, us or OIM: 

Orchard Investment Management (Pty) Ltd

Reg: 

Authorised FSP:

Address: 299 Dey Street, New Muckleneuk, Pretoria

1.2    Personal Information:

Information relating to an identifiable, living, natural person and where it is applicable, an identifiable, existing juristic person, including but not limited to your name, identity number, contact details, financial information, etc.

2. Application of Privacy Policy

The Privacy Policy applies to any website, application, form, document, product, or service which references this Privacy Policy. It applies to all clients, prospective clients, contractors, employees, and representatives of OIM, as well as any other party who interacts with GWA.

3. How We Collect Information

3.1  We collect information about you and any other person whose information you provide to us either directly or         indirectly as follows:

3.1.1 When you complete a product or service application, mandate, consent, contract, or form, whether electronically,         telephonically or on paper;

3.1.2 When you interact with us via our website or social media accounts.

3.1.3 From third party sources such as financial institutions, third party exchange services like Astute, public databases         and any other party to whom you have given consent to share your information with us.

4. What Information We Collect

4.1  The personal information collected and processed is dependent on your relationship with GWA. The information we        collect includes, among others the below:

4.1.1 Name, address, contact details, identity number, entity name, registration number, bank details, occupation, and       other financial information needed to provide effective and applicable financial advice and intermediary services to        you and to comply with relevant laws and regulations that govern us

4.1.2 Correspondence or enquiries from you and anyone acting on your behalf.

4.1.3 Correspondence with third parties in the course of performing our services or as required in terms of our business          relationship with you.

4.1.4 Copies of contracts or agreements concluded with us or through us in the use of our services.

4.1.5 Special personal information such as images of you, health information, credit reports and other information as         required for purposes of fulfilling our mandate or in terms of our relationship with you.

4.1.6 Recordings of telephone calls and virtual meetings, to ensure we act in accordance with your instructions, our         business relationship or any obligations we have in law.

4.1.7 If you are a contractor, employee or representative of OMI, we will gather information regarding your banking        details, employment history, qualifications, next of kin and any other information required to maintain and record         our business relationship with you.

4.2 We may require additional personal information in order for us to comply with our legal obligations in terms of the       Financial Intelligence Centre Act and other legislation. Should you fail to provide such information we retain the right       to cease further interaction with you, limit our service and take any further action as required in law.

4.3 You may provide personal information to us directly or indirectly, through an agent acting on your behalf, via an       enquiry through our website, a third-party website, telephone, email or other method of communication. Where you     provide the personal information of a third party, it is your duty to notify such party you have disclosed their       information to us and that it will be processed in accordance with this policy.

4.4 We may conduct online searches and obtain your personal information from public records such as CIPC, Deeds        Registries, and the Financial Intelligence Centre.

4.5 We will not request your personal information from third party exchange services such as Astute or another        Financial Services Provider unless you have consented thereto in writing.

4.6 If you give us your consent to process your personal information for a specific context, you may withdraw such       consent at any time. Where you have withdrawn your consent, this will not affect processing that took place prior to       such withdrawal.

4.7. Please note the supply of certain personal information is mandatory, in terms of law. You may refuse to provide us     with your personal information, however this may result in us not being able to provide you with a service or       terminating our business relationship

5. Use of Personal Information

We may process and use your personal information for the purposes below:

5.1.1  To provide financial advisory, planning, investment management and intermediary services.

5.1.2 To keep you informed of our services and products, market information and other news relevant to our services.

5.1.3 For record keeping and to comply with legislative requirements.

5.1.4 Verifying your identity, authority to act on behalf of a third party and screening against the sanction lists updated         by the Financial Intelligence Centre from time to time.

5.1.5 To comply with a lawful request by law enforcement agencies, regulatory bodies, a court orders or a similar         request where we are under a legal obligation to comply.

5.1.6 Conducting market research.

5.1.7 To evaluate and improve our service offering.

5.1.8 In cases where you withdraw consent to the processing of your data or have unsubscribed from receiving certain         marketing communication from us, we may retain your details to ensure such instruction is followed or to ensure         we do not send you such communication in future.

5.1.9 If you are an employee, representative, service provider or other party dealing with OMI, to comply with our         contractual obligations to you.

6. Disclosure of Personal Information

In order to provide our services we may need to disclose your personal information to third parties. Set out below are the circumstance under which your personal information may be shared with third parties:

6.1 Your personal information may be shared with our representatives and third party service providers who are       involved in the administration and delivery of our services.

6.2 To access your financial information held by third parties, where you have provided consent to do so.

6.3 To confirm your identity and/or authority to act on behalf of a third party or principal.

6.4 To comply with our legislative obligations and when we are legally obliged to provide such information.

6.5 We may need transfer your information to a representative, sub-contractor or third party located outside of South       Africa, in order to provide you with the service for which have been mandated. We will in such circumstances       require the information to be treated as confidential and with the utmost care and security as required in law.

7. Protection of Personal Information

We will treat all your personal information carefully and responsibly in accordance with relevant legislation. To ensure your personal information is safeguarded GWA has put electronic, physical and procedural measures in place. These measures include securely destroying hardcopy documents

and limiting access to your personal information to those who are involved, either directly or indirectly, in us fulfilling our mandate or obligations to you.

8. Business Sale

In the event that our business is sold, merged or wound up, your personal information may be disclosed to our advisors and any prospective purchaser and their advisors, and will be passed on to the new owners of the business.

9. Retention of Personal Information

How long we keep your information will depend on the purpose for which we use it. We will only retain your information for as long as is necessary for those purposes.

9.1  We are required to retain your information for the minimum periods required in terms of applicable legislation.

9.2 We may retain certain limited personal information indefinitely for record keeping and statistical purposes.

9.3  Should you object to the retention of your information, you may contact the information officer listed below.

10. Access to, Correction and Deletion of Personal Information

10.1 You have a legal right to request a record of the personal information we hold about you. We may charge the        prescribed fee, as allowed in law prior to releasing such information to you. Kindly see the PAIA Manual available on       our website for more information regarding such requests.

10.2 You may request that we correct or update any personal information we hold about you.

10.3 Should you fail to keep your information updated or provide inaccurate or incomplete information, we may limit our         service offering to you and in certain cases terminate our relationship with you.

10.4 Under certain circumstances you are entitled to request the deletion, destruction of your personal information or         object to the processing thereof. In such event kindly contact our information officer using the contact details         below.

11. Log Data

We may collect anonymous information when you visit our websites, to help it and us provide better customer service.

12. Disclaimer

We make no representations or warranties regarding the information on the website/s. We shall further not be liable for any damages to or viruses that may infect, your computer equipment or other property on account of accessing, using, browsing or downloading material from the website/s.

13. Changes to Privacy Policy

We may update this Policy from time to time. Change will be affected by posting the updated policy on our website. We urge you to review this policy regularly. The most updated version of this Policy will apply each time you access our website/s.

14. Contact Details

Should you have any questions, complaints or require further information relating to this policy, or the processing and use of your personal information, kindly submit it to the Information Officer using the details below:

Email: adri@gwa.co.za

Worldbank Office Park, Building C, 442 Rodericks Road, Lynnwood, Pretoria, 0081