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PRIVACY NOTICE

This Privacy Notice explains how Sanlam Investments East Africa (“the Company”) collects,
uses and discloses your personal data, and your rights in relation to the personal data it holds.
In this Privacy Notice, “us”, “we” and “our” refers to the Company.
If you are providing any information to Sanlam Investments East Africa Limited, this company will be the data controller or data processor of your personal
data and is subject to the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and Data Protection Act 2019.

YOUR RIGHTS

Under the GDPR and Data Protection Act 2019 you have the following rights including:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To require that we cease processing your personal data if the processing is causing you damage or distress; and
  • To require us to erase your personal data;
  • To require us to restrict our data processing activities;
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
  • To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Data Privacy Coordinator via email: privacyofficer@sanlameastafrica.com.

HOW WE COLLECT YOUR DATA

We may collect your personal data in a number of ways, for example:

  • From information you provide to us when you meet with one of our employees or when we communicate with you by telephone, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When we complete due diligence on you, including vetting and background screening during the onboarding process;

THE CATEGORIES OF THE DATA WE COLLECT

We may collect the following categories of data about you:

  • Personal Data (including but not limited to name and contact information); and
  • Sensitive Personal Data

THE BASIS FOR PROCESSING YOUR DATA, HOW WE USE THAT DATA AND WHOM WE SHARE IT WITH

We may process your personal data because it is necessary for our legitimate interests.

This may include sharing your personal data with the following:
  • other companies in our Group; and
  • third party service providers as may be necessary.
We may also process your data for compliance with a legal obligation which we are under:
  • To perform our contractual obligations to you. This may also entail sharing your personal data with companies, which assist us in performing our contractual obligations.
  • To meet our regulatory obligations, with regard to conducting due diligence. In this respect, we may share your personal data with the following:
  1. With relevant regulators where we are required to do so; and
  2. third party service providers as may be necessary.

In sharing your personal data for the reasons set out elsewhere in this Privacy Notice, we may need to transfer it to other Group companies, which provide the same or a similarly adequate level of protection for your personal data as is provided within the jurisdiction in which the Company is incorporated.
However, these companies are subject to our Group-wide data sharing arrangements which offer a common level of protection across the Sanlam Group.

RETENTION OF YOUR DATA

We may retain your personal data only as long as may be reasonably necessary for the purposes for which the personal data is processed and afterwards in accordance with the Company’s legal and regulatory obligations, including but not limited to the Company’s record retention policy.