Elias Baloyi Advisory

This Notice aims to inform you about how we handle your personal information, including how we collect, use, store, share, update, and protect it. We will explain your privacy rights and the legal protections in place.

Where we facilitate the placement of Liberty Life products on your behalf, Liberty Life will act as the responsible party or data controller for the personal information processed in connection with those products. In our capacity as your appointed financial adviser, Elias Baloyi Advisory may also process your personal information to provide you with advice and related services.

Ensuring the privacy, confidentiality, and security of your personal information is a top priority for us. This commitment is crucial to maintaining your trust and meeting your needs effectively.

Personal information is any information from which you can be identified. The personal information we may collect about you includes:

• Name, age, gender, date of birth, and identifying numbers (e.g., ID number, tax number)
• Physical and postal addresses, email addresses, and contact numbers
• Online identifiers and online behaviour such as cookies and IP addresses
• Engagements with us including use of products or services, transactions, requests, queries, and complaints
• Banking and financial information with regard to financial behaviour, goals, needs, income, assets, liabilities, and retirement goals
• Employment history, tax residency status, and beneficiary details
• Other personal information including biometric details, race or ethnic origin, nationality, marital status, and medical and health history, where relevant to the financial products or advice required

Collection Methods

We collect your personal information directly from you through in-person meetings, telephone conversations, or online channels such as our website, contact forms, or social media platforms (e.g., Facebook Lead Forms).

Direct Collection

When you engage our advisory services, contact us, or provide information through our website or social media channels, we collect your personal information directly from you.

Third-Party Involvement

To fulfil our responsibilities as an Appointed Representative of Liberty Life, we may collect and share your information with selected third parties. These include:

• Liberty Life, as the Authorised Financial Services Provider and registered long-term insurer through whom products are placed
• Regulatory bodies, including the Financial Sector Conduct Authority (FSCA) and the South African Revenue Service (SARS)
• Member companies of the Standard Bank Group
• Credit bureaus and other authorised financial services providers for the prevention of fraud
• Technology and platform service providers who support our website and business operations

We collect your personal information for the purposes set out in this Notice or otherwise communicated to you.

We aim to provide you with personalised financial advice and services to meet your needs. We may process your personal information for any of the following reasons:

Contract Requirements

We may process your personal information where it is required to conclude or perform under a client engagement, financial needs analysis, or product application, including:

• Providing financial advice and structured retirement and investment planning
• Facilitating the opening and administration of financial product accounts through Liberty Life
• Communicating with you regarding your products or services
• Providing you with further information that you request regarding your financial products or advisory services

Lawful Obligations

We may process your personal information to comply with legal and regulatory requirements, including:

• Completing due diligence, onboarding, and FICA compliance checks
• Complying with risk management and regulatory requirements under FAIS, FICA, and POPIA
• Detecting, preventing, and reporting money laundering, fraud, or other potentially illegal activity
• Regulatory reporting obligations

Legitimate Interest

We may process your personal information in the regular management of our practice, including:

• Maintaining and improving our advisory processes and service delivery
• Responding to client enquiries and recording these interactions for analysis and improvement
• Meeting record-keeping obligations as required by FAIS
• Conducting research and analysis to assess product suitability for your needs

Consent

In addition to the above, we may process your personal information where you have given us your specific consent. We will not share your personal information with anyone outside our practice or our service providers without your permission, unless:

• We are required to do so by law or by a court order
• It is in the public interest
• We need to do so to protect our rights
• There is a legitimate purpose for the sharing

We store your personal information as required by law. Specifically:

• Client financial records are retained for a minimum of 5 years in accordance with FICA and FAIS recordkeeping requirements
• Inquiry and lead data is retained for up to 12 months if no ongoing client relationship is established
• Website analytics and cookie data is typically retained for up to 24 months

After the applicable retention period, your personal information will be securely deleted or anonymised.

Sometimes we, or Liberty Life and its service providers, will process your personal information in countries other than South Africa, either to carry out your instructions or for ordinary business purposes. These countries may not have the same level of data protection as South Africa.

In such cases, we will only process your personal information with your consent. Where necessary, we will require the party to whom we transfer your personal information to agree to our privacy principles, associated policies, and practices, in accordance with POPIA Section 72.

For more detail on how Liberty Group processes information across its international operations, please refer to the Liberty Group Privacy and Security Notice at www.liberty.co.za/legal.

We are committed to protecting your personal information. We implement all reasonable controls to secure access to your data. When third parties are involved in processing your information, we ensure they are contractually obligated to follow appropriate security practices.

As a representative of Liberty Life, we also benefit from and are bound by Liberty Group’s comprehensive Group-wide policies and procedures dedicated to safeguarding personal information, including encryption methods that align with international standards for all online transactions and interactions.

Please contact us immediately if you suspect any unauthorised access to or use of your personal information.

In the event of a data breach involving your personal information, we will:

• Notify the Information Regulator as soon as reasonably possible after becoming aware of the breach
• Notify you if the breach is likely to result in harm to you, in accordance with POPIA Section 22
• Take prompt steps to contain the breach and prevent further harm

We use cookie technology on our website. A cookie is a small piece of text saved on your internet browser when you use our website. Cookies make it easier for us to give you a better experience online. You can stop your browser from accepting cookies, but if you do, some parts of our website may not work correctly.

To use or store cookie types that are not required for the functioning of the website, we will obtain your consent first. We use the following types of cookies:

When you engage with us through our social media channels (e.g., Facebook), your personal information may be processed by the social media platform owner. This processing is outside our control and may occur in a country with different data protection laws. We recommend that you read the privacy terms and conditions of any social media platform before sharing personal information on it.

Our social media accounts are not appropriate forums to discuss your personal financial products or arrangements. We will never ask you to share personal information, account, or policy information on social media platforms. We may, however, ask you to message us privately through one of our official social media channels.

If you give us permission, we may use your personal information to tell you about products, services, and relevant financial updates from us or Liberty Life that may interest you.

If you no longer wish to be contacted for marketing purposes, you may opt out at any time by:

• Following the unsubscribe instructions contained in any marketing communication you receive from us
• Contacting us directly using the details in Section 13
• Contacting Liberty Life’s customer servicing centre on 0860 456 789

We value your trust and want you to be familiar with your rights. You have the right to:

To exercise any of these rights, please contact our Information Officer using the details in Section 13.

The Promotion of Access to Information Act (PAIA) gives effect to the constitutional right of access to information held by a private body for the exercise or protection of any right.

All Liberty clients are allowed access to their own information without having to use the formal PAIA request procedure. This includes access to policy documents, account information, personal records, and voice recordings. Clients should contact the relevant Liberty call centre or department directly for this purpose.

Any person who wishes to access information that belongs to Liberty or any of its other clients must follow the formal PAIA request procedure below.

All PAIA requests must be directed to:

If you have any questions about this Notice, wish to exercise your rights in relation to information held by Elias Baloyi Advisory, or believe we have not adhered to this Notice, please contact our Information Officer:

We may update this Privacy and Security Notice from time to time to reflect changes in our practices, Liberty Life’s requirements, or applicable law. All changes will be published on our website with a revised “Last Updated” date. The latest version will replace all earlier versions.

For queries regarding this Notice, you may also email Liberty Life’s privacy team at privacy@liberty.co.za.