LEGAL

DN INVEST PROPRIETARY LIMITED PRIVACY NOTICE 

Who are we? 

DN Invest Proprietary Limited (“DNI” or “we”) are a Responsible Party in terms of the Protection of Personal Information Act, No 4 of 2013 (“POPIA”) with respect to your Personal Information. We process all such Personal Information in order to enable us to do business with you. In this notice, “you” means you as an individual or in your representative capacity of a juristic person with whom we are dealing whose Personal Information we may need to collect and process for any of the purposes described below. 

What Personal Information is collected? 

Please note that in accordance with Section 18 of POPIA you are hereby expressly informed of the fact that when you provide services to, transact with, or otherwise deal with DNI (“DNI Dealing”) you may need to provide DNI with your Personal Information, which may include, but not be limited to – 

• full names; 
• identity numbers; 
• registration numbers; 

• financial information, including banking account information; 
• statutory information; 
• physical and postal address particulars; 
• telephone numbers; 
• biometrics; and 

• e-mail addresses. 

What do we do with your Personal Information and why do we collect it? 

We take the privacy of any data subjects with whom we engage very seriously and we only collect and process Personal Information for specific purposes which are connected to our legitimate business purposes, which we generally need in order to comply with our obligations towards you and also to comply with obligations which are imposed upon us in terms of applicable laws regulating us. The Personal Information you provide to DNI pursuant to your DNI Dealing is typically

processed for the following purpose(s), which purposes are connected to our legitimate business purposes – 

• to provide or manage any information pursuant to your DNI Dealing; 
• to establish your needs, requirements and preferences in relation to the products and/or services provided by any of our affiliates; 
• to identify your risk profile and make an election as to whether we wish to enter into a contractual relationship with you and if so, on what terms; 

• to allocate unique identifiers to you for the purpose of processing your Personal Information, securely storing, retaining, and recalling your Personal Information from time to time, regardless of whether you conclude an agreement with us; 
• for general administration purposes pertaining to your request/s and to reply to you when you contact us for support; 
• to transfer your Personal Information across the borders of South Africa to other jurisdictions should it be required in the legitimate pursuit of our business requirements; 
• to identify products and services offered by any of our affiliates which might be of interest to you, as well as to inform you of such products and/or services; 
• to investigate and attempt to resolve any queries, complaints or requests; 
• to verify that the personal information provided is true and accurate; and/or 
• to, unless you expressly “opt out”, process your Personal Information as defined above for the purposes of direct marketing and advertising to you of products and services provided by any of our affiliates in future. 

This notice applies to all data (including all Personal Information) past, present or future submitted by you to DNI or which we otherwise obtain pursuant to undertaking our normal business activities. 

Who do we share your Personal Information with? 

We are, from time to time, required to share your personal information with some of our suppliers, service providers and business partners. We use service providers and suppliers who we trust and who we have agreements with and they have agreed to keep your personal information secure and confidential, and to only use it for purposes which we have agreed to.  

Where do we store your Personal Information? 

All your personal information is stored securely by DNI through its servers, some of which may be cloud-based. In storing your Personal Information, we may transmit or transfer Personal Information

outside South Africa to a foreign country, as such, personal information may be stored on servers located outside of South Africa in foreign countries that have different data protection laws in place. We are comfortable that these foreign countries protect Personal Information to an extent that compares to the way in which we do, which is acceptable to us. If you are interested in who these suppliers are, you are welcome to ask us at any time, we will happily disclose this information to you upon request. 

What are your Rights? 

It is important that you know what your rights are with regards to our processing of your personal information and we want to make this clear to you also. Although we take steps to safeguard your personal information, process it lawfully and only share it with suppliers and service providers we trust, you have the following rights – 

• You can ask us at any time what personal information of yours we hold – we don’t have any hidden agenda here! 
• You can ask us what personal information of yours is, or was, shared with any of our suppliers, service providers, or any third parties – we will happily tell you! 
• You can ask us to update your personal information or even delete any information which is no longer accurate – we want to make sure your information is accurate and complete, but we need your help! 
• You can object to our processing of your personal information – we don’t want to process your information if you don’t want us to, but just bear in mind it may influence our ability to fulfil our obligations towards you! 
• You are more than welcome to lodge a complaint with the information regulator if you feel that we are not complying with POPIA – please do try and speak to us first, but this is a remedy available to you and we want you to know about it! 

 

The contact details of the Information Regulator are: 

The Information Regulator (South Africa) 

JD House 27 Stiemens Street Braamfontein Johannesburg, 2001 PO Box 31533 

Braamfontein, Johannesburg, 2107 E-mail: inforeg@justice.gov.za 

With that said, we have (and continue to) implement reasonable security measures and protocols to protect the personal information we hold. These measures are to protect any personal

information we hold from being disclosed without authorisation, from loss, damage, destruction or unauthorised access. As you will appreciate nothing is 100% secure in this day and age and therefore, we ask that if you suspect that either you, or we, have had an information security breach, please notify us immediately so that we can take action. You can do so by contacting our Information Officer whose information is set out below. 

If you need to speak with our Information Officer, feel free to contact him. Our Information Officer is Liam Heinzelmann and any queries or even questions you may have regarding this privacy notice and DNI’s POPIA compliance efforts can be directed to him at liamh@dninvest.co.za.