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Privacy Notice

We are committed to protecting your privacy and ensuring that your personal information is collected and used appropriately, lawfully and transparently in compliance with the Protection of Personal Information Act.

This privacy notice explains:

This privacy notice also sets out various rights that you may exercise in respect of our use of your personal information. A fundamental right of which you should be aware of is you may ask us to consider any valid objection you may have to our use of your personal information where we process your personal information on the basis of our, or another person's legitimate interest.

Please read this privacy notice carefully to understand how we handle your personal information before you access or browse our website, or provide your personal information to us.

Who we are

Old Mutual Bula Tsela Retail Scheme (RF) Limited was established as a ring-fenced, special purpose vehicle through which qualifying members of the Black South African public could indirectly invest and hold shares in Old Mutual Limited, a leading financial services provider.

Overview

This privacy notice sets out how we ensure that your personal information is collected and used appropriately, lawfully and transparently. Our website may contain links to other third party websites. We have no control over how your data is stored, or used by other websites, and we advise you to check the privacy notices of any such websites before providing any data to them.

Our responsibilities

We are responsible for your data in relation to your use of this website, as a shareholder of the Company. Our registered address is Mutualpark, Jan Smuts Drive, Pinelands, Cape Town, 7405, South Africa and we are registered as a private company limited by shares, incorporated in the Republic of South Africa under registration number 2021/474341/07. We are the Data Controller of the personal information that we collect from you, and as such we control the way in which your personal information is collected and the purposes for which your personal information is used.

Our Transfer Secretary

Singular Systems (Pty) Ltd has been appointed as our Data Processor in relation to our shareholders.

What personal information we collect

We will, in all cases, keep your personal information only as long as is necessary for the purpose for which it was collected, or for legal or regulatory reasons. Personal information is securely disposed of when it is no longer required to be held.

We collect personal information directly from you. For example, we ask for personal information at the start of our relationship (e.g. when you become a shareholder), and in subsequent communications in order to check your identity. This is a legal requirement and is important to help safeguard you and us against potential crime. We may also collect information about you from other sources such as external third parties and from cookies on our website.

Details of the key categories of personal information we collect are set out below, but please contact us if you would like more detailed information.

In relation to our shareholders

Our Transfer Secretary holds data relating to our shareholders. It is a legal requirement that your name, address and the number of shares you hold are made available on a Register of Members. Certain other information may be held by our Transfer Secretary to improve the service that they provide to you, such as bank details to enable the payment of dividends directly to your bank account.

This personal information about you will include:

your name
address and e-mail address
where relevant, your job title, your company name and your company's address
data provided when you correspond with us
any updates to data provided to us

In relation to our website

We collect information about how you logged on and off of our website, including your IP address, information about your visit, your device information and how you use our website. This will include the capture of your approximate location information - please see the Cookies Policy on our website for further information on this.

In relation to presentations on our website

Through third party service providers, we collect your information when you register to view a webcast, such as our financial results or annual general meeting. Our service providers will collect your location, name, company and email address and we will use these for the purposes of ensuring we adhere to compliance regulations prescribed by applicable law and regulation, and to maintain a database of those shareholders who prefer to communicate with us digitally.

In relation to our service providers

If you are a supplier to the Company (or an employee or other personnel of a supplier), we will hold information in relation to the persons who are engaged in the provision of those services to us, service related data, relationship management data, and other information that you might have provided to us, or which we may have collected from the company's website.

How we use your personal information

We process your information to perform our contract with you, to fulfil our obligations to our shareholders and to support and maintain that relationship, and to comply with legal obligations. We also use it:

For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, and to identify and implement business efficiencies.
To comply with any procedures, laws and regulations which apply to us this may include where we reasonably consider that it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so.
To establish, exercise or defend our legal rights - this may include where we reasonably consider that it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

In relation to our shareholders

If you are a shareholder, we will use your personal information:

to register you as a shareholder and maintain and keep this information up to date
to deal with any enquiries or issues you might raise
to provide you with relevant information, reports and communications
for other legitimate purposes connected with you as one of our shareholders

In relation to our website

When visiting our websites we will use your personal information:

to allow you to access and use our websites
to provide technical support
to provide you with the information that you request from us
to ensure the security of our services and our websites
to store information about your preferences
to recognise you when you return to our websites
for improvement and maintenance of our websites

Details relating to the usage of our websites by individuals will be anonymised as far as is reasonably possible and you will not be identifiable from the data collected.

In relation to our service providers

If you are a supplier (or an employee or other personnel of a supplier), we will use your information to manage and receive the services you provide, and to exercise our rights and obligations in respect of those services (including to confirm and process orders, for administration of accounts, and for tax and payment purposes).

Our legal basis for using your personal information

We can only use your personal information if we have a proper reason for doing so. We consider that the legal bases for using your personal information as set out in this privacy notice are as follows:

To comply with our legal and regulatory obligations
To perform a contract with you or to take steps at your request before entering into a contract
To respect your choice if we request your consent for specific processing
To use your personal information as is necessary for our legitimate interests or the legitimate interests of others. In some cases, we have identified where this is the case elsewhere in this privacy notice. Our legitimate interests include the following:
- to run and manage our business
- to provide information to our shareholders
- to perform checks (such as identification checks and other verifications in line with money laundering or other requirements) on those we interact with
- to operate our websites
- to select appropriately skilled and qualified suppliers
- to make and receive payments
- for internal group administrative purposes

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

Who we share your personal information with and why

To protect the rights of the Old Mutual Group and our staff, shareholders or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.

We share your information with trusted third parties, who perform tasks for us and help us to provide our products and/or services to you, and with other agencies where required by law, court order or regulation. These include:

Companies within the Old Mutual Group
Our Transfer Secretaries
A third party to verify your identity, in line with money laundering or other requirements
Organisations, including the police and fraud prevention agencies, to prevent and detect fraud
Regulatory or governmental agencies
Our service providers and sub-contractors, including but not limited to payment processors, and suppliers of technical and support services

Analytics and search engine providers that assist us in the improvement and optimisation of our website.

Any third parties with whom we share your personal information is limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy notice and applicable laws.

We will also disclose your personal information to third parties:

Where it is in our legitimate interests to do so to run and manage our business.
If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity.
In order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity.

Retention of your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed or as required by law or regulation. The length of time we retain personal information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

How we keep your personal information secure

In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information that you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk.

The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private.

For this reason, we are committed to protecting personal data from loss, misuse, disclosure, alteration, unauthorised access, unavailability and destruction and we take all reasonable precautions to safeguard the confidentiality of personal data, including through use of appropriate organisational and technical measures. Organisational measures include physical access controls to our premises, implementing internal policies and staff training and ensuring confidentiality obligations are imposed on our employees and third parties. Technical measures include requiring passwords for access to our systems, and the use of encryption and anti-virus software. We are committed to ensuring the confidentiality of the personal information that we hold and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.

Use of cookies

Our website uses cookies. A cookie is a piece of data stored on your computer's hard drive that identifies your computer while you are using our site.

Cookies have a number of uses, for example, cookies can be used for analytics purposes to estimate the number of users on our website. They may also be used for other purposes, such as to maintain the security of the site and provide information on what we need to do to provide administration support to the website.

We provide specific details about the cookies we use and the reasons for using these cookies is in our Cookie Policy to enable website visitors to make an informed decision when using our website. In respect of third-party cookies, we have no control over how third-party cookies act, or whether that third party uses any other cookies. We advise you to check the privacy notices of any such third parties before providing any data to them.

Your rights

We may request you provide us with information necessary to confirm your identity before responding to any request you make. If an exception applies, we will tell you this when responding to your request.

You have the right to ask us:

For a copy of the personal information we hold about you: You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us and details about how and why it is being used.
To update or correct your personal information: You have a right to request an update to any of your personal information that is out of date or incorrect.
To delete your information, to the extent permitted by law: You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances.
To restrict processing of your personal information where appropriate: You have a right to ask us to restrict the way that we process your personal information. To update or correct your personal information.

In certain circumstances, you also have the right to:

Withdraw your consent for the processing of your personal information: if we are relying on consent and have no other legal grounds for processing your personal information, you can withdraw your consent.
Object to the processing of your personal information: You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest, or where we use your personal information for profiling purposes.
Object to automated decision making and profiling.
Data portability: Where we use your personal information on the basis of your consent or performance of a contract, you have a right to ask us to provide your personal information to a third party provider of services.

We will consider all such requests and provide our response within a reasonable period of time (and in any event within the period allowed by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example, if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

We may request you to provide us with information necessary to confirm your identity before responding to any request you make. If an exception applies, we will tell you about it when responding to your request.

Transfers of personal information

If we work with third parties in countries outside the EU, we ensure that these are countries that the European Commission has confirmed have an adequate level of protection for personal information, or the third party receiving the personal information has provided adequate safeguards and agrees to treat your information with the same level of protection as we would and as is required by applicable law

The personal information we process may be used, stored and/or accessed by staff working for us, other members of the Old Mutual or third party partners providing services to us, or performing services on our behalf. Further details on to whom your personal information may be disclosed are set out above.

When we contract with third parties, we require that they have appropriate security, privacy and confidentiality measures in place to ensure that personal information is kept secure.

How to contact us

For users in the European Union, you have a right to complain to the data protection authority in the European Union country where you usually live or work if you think that your information has been misused. The UK Information Commissioner's Office website is available at https://ico.org.uk. Alternatively, you may seek a remedy through local courts if you believe your rights have been infringed upon.

If you would like any more information about the way we use your information, or if you wish to exercise the rights listed above, please contact us using the details below:

Annemi Slabbert
Old Mutual Group Information Officer
Old Mutual Limited
Jan Smuts Drive
Pinelands
South Africa
Email: aslabbert@oldmutual.com

You have a right to complain to the Information Regulator if you think that your information has been misused. The contact details are:

https://inforegulator.org.za/
Tel: 0800 017 160
Landline 010 023 5200
Email: enquiries@inforegulator.org.za

Changes to our Privacy Policy

We may change this privacy notice from time to time. We will post any changes on our website.

Please check back frequently to see any updates or changes to our privacy notice. By continuing to use our website and interact with you are confirming that you have read and understood the latest version of our privacy notice.

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