We are committed to protecting your privacy and ensuring that your personal information is processed properly, lawfully and in a transparent manner, in compliance with the Protection of Personal Information Act 4 of 2013.

This Privacy Notice explains how we obtain, use and disclose your personal information and aims to inform you of your rights and how to exercise them.

This Privacy Notice sets out:

• Who we are
• What personal information we collect and where we collect it from
• The purposes for which we use your personal information
• To whom we disclose your personal information
• How we safeguard your personal information
• Your rights to access, correct and delete your personal information
• How to contact us
• The Information Regulator’s contact details

WHO WE ARE

In this Privacy Notice, “AIIM”, or “we” refers African Infrastructure Investment Managers Proprietary Limited and its affiliates, which includes the Old Mutual Group. “Old Mutual Group” refers to Old Mutual Limited and its subsidiaries.

THE INFORMATION WE COLLECT

We collect and process your personal information mainly to provide the investment management services as contemplated in our agreement(s) with you (and any services ancillary thereto, including as part of our onboarding processes), to grant you access to our services and financial products, to help us improve our offerings to you and for certain other purposes explained below. In order for us to do this, it is incumbent upon you to provide us with the personal information that we request, failing which we cannot enter into a relationship with you, assist you or fully comply with our contractual obligations to you. 

When you provide us with information about third parties (for example your clients, service providers or parties related to you), we will process their personal information in order to give effect to our agreement and in order to pursue your and our legitimate interests. We will furthermore process personal information for the purposes set out in this Privacy Notice. You warrant that, when you give us personal information about third parties, this information is accurate and correct and you have received their permission or, in respect of a person under 18 years of age, you confirm that a competent person consented, to the sharing of their personal information with us for the purposes set out in this Privacy Notice or any other related purposes.

The type of information we collect will depend on the purpose for which it is collected and used as set out herein. We will only collect information that we need for that purpose.

We collect information directly from you where you provide us with your personal details, for example when you apply for a product or services from us or when you submit enquiries to us or contact us.

We also collect information, including criminal information, about you and/or your related parties from other sources, such as:

• Third parties for the purposes listed below, for example credit reference, anti-money laundering and fraud prevention and law enforcement agencies.
• Other companies in the Old Mutual Group for the purposes listed below, or when we believe it will enhance the services and financial products we can offer to you, but only where you have not objected to such sharing. This includes supplementing the information that you provide to us with information we receive from other companies in the Old Mutual Group in order to offer you a more consistent and personalized experience in your interactions with Old Mutual, and to ensure that we have updated information about you.

We have a duty to take all reasonably practicable steps to ensure your personal information is complete, accurate, not misleading and that it is updated on a regular basis. To enable this, we will always try to obtain personal information from you directly, and we will appreciate it if you would similarly ensure that your personal information processed by us, is up to date and accurate. You can do so by engaging your AIIM stakeholder whenever your details change or by contacting us at privacy@oldmutualinvest.com. Where we are unable to obtain personal information from you directly, we will make use of verifiable independent third party data sources.

Website usage information is collected by using “cookies” which allows us to collect standard internet visitor usage information.  This includes information about how you logged on to and logged off from 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. For more information on how we deal with Cookies you can view our Cookie Policy here.

PURPOSES FOR WHICH WE USE YOUR INFORMATION

We will use your personal information only for the following purposes:

• to conclude a legal agreement with you and to perform the obligations required in terms of such agreement which includes, investment management services such as managing your portfolio, reporting to you, and to keep you apprised on developments pertaining to your portfolio(s).
• to pursue our legitimate business interests, which includes:
  • compiling relevant reports;
  • complying with requests from any internal or external auditor, or any regulatory or supervisory body,
  • compliance with any regulatory requirements and/or industry codes applicable to the financial services industry;
  • corresponding with you;
  • confirming and verifying our identity, address and banking details and maintaining the accuracy thereof;
  • conducting the requisite client identification and verification processes as required in terms of the Financial Intelligence Centre Act;
  • to conduct sanction screening against all mandatory and non-mandatory sanctions lists (in this instance, we may communicate such personal information to local and international regulatory bodies as well as to other entities in the Old Mutual Group (if you are matched to one of these sanctions lists);
  • detecting and preventing fraud, crime and money-laundering (or any other malpractice);
  • Offering financial products and/or services to you;
  • Maintaining our business relationship with you;
  • Conducting market and/or client satisfaction research for statistical analysis;
  • Protecting our and/or your interest(s) in legal proceedings;
  • processing your marketing preferences (and, where you have unsubscribed from certain direct marketing communications, keeping a record of your information and request to ensure that we do not send such direct marketing to you again); and
  • Resolving any complaint.

DISCLOSURE OF INFORMATION

We may disclose your personal information to our service providers who are involved in the delivery of the financial products and/or services to you. We have agreements in place to ensure that they comply with these privacy terms.

We may share your personal information with:

• Third parties for the purposes listed above, for example fraud prevention agencies, law enforcement agencies.
• Other companies / entities in the Old Mutual Group for the purposes listed above, or when we believe it will enhance the services and financial products we can offer to you, but only where you have not objected to such sharing.
• Other third parties from whom you have chosen to receive marketing information.

We may also disclose your personal information:

• Where we have a duty or a right to disclose in terms of law or industry codes; or
• Where we believe it is necessary to protect our rights.

INFORMATION SECURITY

We are legally obliged to provide adequate protection for the personal information we hold and to stop the unauthorised access and use thereof. We will, on an ongoing basis, continue to review our security controls and related processes to ensure that your personal information is secure.

Our security policies and procedures cover:

• Physical security
• Computer and network security;
• Access to personal information
• Secure communications
• Security in contracting out activities or functions
• Retention and disposal of personal information
• Acceptable usage of personal information
• Governance and regulatory aspects
• Monitoring access and usage of personal information
• Investigating and reacting to security incidents

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure.

We may wish to transfer your personal information to another country for processing or storage. We will ensure that anyone to whom we pass your personal information agrees to treat your personal information with the same level of protection as we are obliged to.

YOUR RIGHTS

We will take all reasonable steps to confirm your identity when you exercise your rights.

Access to information

You have the right to request a copy of the personal information we hold about you. You can engage your AIIM stakeholder directly to review your personal information or contact us at paia@oldmutual.com and specify what information you would like.

Please note that any such access request may be subject to a payment of a legally permissible fee.

Objection to processing

In certain cases, you have the right to object to the processing of your personal information.  If you want to object, please engage your AIIM stakeholder directly or contact us at privacy@oldmutualinvest.com.

Correction of your personal information

You have the right to ask us to update or correct your personal information. You may do this by engaging your AIIM stakeholder directly to review and change your personal information or by contacting us at privacy@oldmutualinvest.com.

Deletion of your personal information

You agree that we may keep your personal information until we destroy your information based on OMIG’s destruction standards.  You have the right to ask for deletion or destruction of your personal information – we will do that unless the law requires us to keep it or if we require retention for legitimate business purposes, in which event we will continue to protect such information as detailed above. You may do this by engaging your AIIM stakeholder directly or contacting us at privacy@oldmutualinvest.com.

Automated decision making

You agree that we may process your personal information by using automated means (without human intervention in the decision making process) to make a decision about you or your application for any product(s) and/ or service. You may query the decision made about you.

CHANGES TO THIS NOTICE

Please note that we may amend this Notice from time to time. Please check this website periodically to inform yourself of any changes.

HOW TO CONTACT US

If you have questions about this Privacy Notice or believe we have not adhered to it, or need further information about our privacy practices, please engage your AIIM stakeholder directly or contact us at privacy@oldmutualinvest.com.

INFORMATION REGULATOR

You have the right to complain to the Information Regulator, whose contact details are:

https://www.justice.gov.za/inforeg/

General enquiries: enquiries@inforegulator.org.za

Complaints: POPIAComplaints@inforegulator.org.za

Version 6, October 2021