Privacy Policy

Lockstep Investing (PTY) LTD Privacy Policy

Effective since: 01 January 2022

 

Lockstep Investing (PTY) LTD makes it a matter of utmost importance to respect the privacy of our potential and existing visitors, clients and users and we are committed to treating your Personal Information in the strictest confidentiality, in accordance with the information protection legislation in force, the present Privacy and Cookie Policy, and the applicable standards of fair information practices.

This Privacy Policy is intended to inform you, in a transparent manner, about the Personal Information Lockstep Investing (PTY) LTD collect, the purpose for collecting it, the way we use it and the rights you have regarding the processing of such Personal Information.

This policy applies specifically to our customers, applicants, suppliers, business partners, visitors of our website and/or persons who contact us (e.g., via contact form) regarding the provision of our products and services as described on our website.

You are not obliged to provide us with your Personal Information, however, understand that we are not able to provide you with our services in case you refuse to provide us with certain Personal Information.

Lockstep Investing (PTY) LTD, (“we”, “us”, “our”, “LI”, “the Company”), with registered office in 65 Wale Street, Cape Town, Western Province, South Africa, and with Registration Number: 2023/005729/07, takes responsibility for the Processing of your Personal Information as Responsible Party when we process Personal Information for the purpose of providing our services to our clients and customers (“User(s)”).

 

LI Processes Personal Information in accordance with the Protection of Personal Information Act 4 of 2023 (“PoPIA”).

“Personal Information” is defined in the Protection of Personal Information Act (Act no. 4 of 2013) (“POPIA”) as follows:

“Information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to –

• information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
• information relating to the education or the medical, financial, criminal, or the employment history of the person;
• any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
• the biometric information of the person;
• the personal opinions, views or preferences of the person;
• correspondence sent by the person, that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
• the views or opinions of another individual about the person; and
• the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.”

 

“Processing” is defined in POPIA as follows:

“any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including—

• the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
• dissemination by means of transmission, distribution or making available in any form; or
•  merging, linking, as well as restriction, degradation, erasure or destruction of information;

 

LI is a Responsible Party in respect of the Personal Information that the User(s) provide to the Company.

 

What Personal Information do we process?

• When you contact us as a potential User, make use of our website, products and/or services, solutions or portal(s), we may collect your contact details, such as your name and surname; cell phone number; email address, physical address and banking detail (all banking detail collected to pay for the membership is done via a Payfast plugin on LI`s website, stored by Payfast) LI does not under any circumstances have sight of nor Processes any Personal Information in respect of Users` banking detail.
• By contacting us through any medium, we collect information about your/our communication, including its content and technical details.
• Upon receipt of information about you from third parties, such as our partners, including but not limited to our customers, vendors, banks, and payment processors, we may collect the information contained in their message or communication.
• By applying for a job or if you wish to have a supplier relationship with us, we collect the information you provide us with, such as identity details, resume and cover letter, containing but not limited to your name, address, phone number, email address, matric certificate, national identification card or passport and payment details.
• By registering and/or creating an account on one of our portals, we collect your identification data (full names and surname, identity number, phone number, email address, address and country of residence) and information to maintain your account and provide you access to our portal(s) and customize services available thereon in the execution of the agreement we entered into.
• We use cookies to collect information about your use of our Website. Information collected, will include:
  • the type of domain with which the User connects to the Internet;
  • the IP address assigned to the User (when connected);
  • the date and time of access to the Website and other data related to traffic;
  • location data or other data relating to the communication;
  • the pages visited;
  • the type of browser used;
  • the platform and/or operating system used;
  • the search engine as well as the keywords used to find the Website.

 

Why do we collect your Personal Information?

 We need your Personal Information to provide you with the following services:

• To respond to your requests for information, products and services;
• To establish and/or maintain our contractual relationship;
• To provide you with the requested products, services and information;
• To provide you access to, customize and improve our services, portal(s) and (technical) solutions;
• To maintain your account and to provide you with support services;
• To comply with third-party requests/ where required to carry out contractual relationships with third parties;
• To comply with legal obligations;
• To keep you informed of any updates regarding our website, products, services, solutions and/or portal(s);
• For operational and legal reasons related to a potential supplier relationship;
• If you applied for a job opportunity, to evaluate your application.

 

Who has access to your Personal Information?

Only a specific part of LI’s trustworthy team has access to the Personal Information you provide us with.

Furthermore, we use suppliers and service providers, such as but not limited to computer security, digital solutions and web hosting services. These parties are legally obliged to ensure your privacy at all times and will only process data in accordance with our purposes.

Third- Parties

LI treats Personal Information as confidential and will not disclose or communicate the Personal Information of its Users to third parties under any condition other than those specified in this Privacy Policy, to achieve the objectives pursued or under the conditions in which the law requires it to do so.

No third-party providers have direct access to your Personal Information unless specifically required by law and satisfy client due diligence principles.

LI may communicate its Users` Personal Information to third parties to the extent that such information is necessary for the performance, execution and management of our contracts with our Users, including but not limited to reporting, support, marketing, computer security or offering specific other services. In such cases, these third parties will not communicate this information to other third parties, except in the following situations:

• communication of this information by such third parties to their suppliers or subcontractors is necessary for the performance of the contract;
•  such third parties are obliged by the regulations in force to communicate certain information or documents to the competent authorities.

 

The communication of this information to the aforementioned third parties shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.

LI will not sell, hire out or pass on your Personal Information to third parties, except in the situations described in this Privacy Policy or unless you explicitly provide your prior consent.

 

Direct Marketing

Your Personal Information will only be used for direct marketing purposes, based on your prior consent or based upon our legitimate interest if we have concluded an agreement with you.

Your Personal Information will not be used for direct marketing purposes for any services that would not be identical or similar to those to which you have already subscribed, unless you have previously explicitly consented to such use by ticking the boxes provided for this purpose (“opt-in”).

When you give LI your consent to use your Personal Information for direct marketing purposes, you also retain the right to revoke such consent at any time, upon request and free of charge. You may simply communicate your request by clicking the unsubscribe button below every promotional e-mail or by contacting us via the following email address: [email protected].

 

Legal obligations

In extraordinary circumstances, it may occur that LI is obliged to transfer your Personal Information following a court order, or in order to comply with imperative laws and/or regulations. LI will, if reasonably possible, try to inform you on beforehand unless revealing this information is subject to legal constraints.

 

How long do we keep your Personal Information?

Under South African law, we are required to keep your Personal Information for a five (5) year period following the date of termination of the business relationship according to the Company’s Personal Information Retention Policy. After this period, your Personal Information will be irreversibly destroyed. For more information on the Company’s Personal Information retention schedule, please refer to our Personal Information Retention Periods below:

LI will store your Personal data for the duration necessary to achieve the objectives pursued as specified in this Privacy Policy or for as long as this is essential for the contractual relationship.

LI may also store your Personal data after the termination of the contract, in order to comply with all applicable laws or as part of legal requirements.

 

Retention periods

Depending on the reason/purpose for which the Personal Information was collected and stored, we will retain your Personal Information as follows:

• As long as necessary for us to communicate with you, with a maximum of five (5) years after the first request or contact. In the case of a contractual relationship, we will keep your identity information for a maximum of ten (10) years after the end of the contractual relationship.
• For a maximum of five (5) years after the last qualitative contact.
• With regards to cookies, the retention period may vary depending on the specific cookie, ranging from the end of the session to two (2) years.
• For as long as necessary to comply with our legal obligations and only as long as legally permitted.

 

What are your rights?

Right of access and right to obtain a copy

The right to freely obtain access to Personal Information, as well as to be informed about the purpose of the processing, at any moment.

Right to rectification, erasure, or restriction

The right to request the restriction of processing of your Personal Information, if you think your data is inaccurate and you subsequently notified us about it or its erasure.

Right to object:

The right to object to the processing of your Personal Information when you have serious and legitimate reasons to do so and the right to object to its use for direct marketing purposes.

Right to information portability:

The right to obtain your Personal Information, which is processed by LI in a structured, commonly used format and/or to transfer this data to another data controller.

Right to withdraw consent:

When the processing is based on prior consent you have the right to withdraw this consent.

Automated decisions and profiling:

The right to request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

 

Exercising your rights:

You can exercise your rights by contacting us with a copy of the essential parts of your ID, such as name and date of birth, as attachment, at [email protected]; or

Should you believe that any of your Personal Information held by the LI is incorrect or incomplete, you have the right to request to view this information, rectify it or have it deleted. Please contact the Company’s Information Officer on should this be required.

In addition, if you wish to complain about how the LI has handled your Personal Information, please contact the Information Officer on [email protected]. The Company’s Compliance Department will investigate your complaint and contact you within two (2) business days of the complaint being lodged and work with you to resolve the matter.

If your query relating to your Personal Information is not, in your opinion, adequately dealt with, you can contact the Information Regulator on 012 406 4818 or [email protected] to file an official complaint.

This does not affect a procedure before the civil court. Following hereto, if you have suffered damages caused by the processing of your Personal Data, you can file a claim for damages.

 

Cookie Policy

What are cookies?

A “cookie” is a small file sent by LI’s server and placed on your computer’s hard drive. The information stored on these cookies can only be read by LI and only for the duration of the visit to the website.

 

Why do we use cookies?

Our website uses cookies and similar technologies to distinguish your preferences for use from those of other visitors and Users of our Website. This helps us to provide you with a better experience when you visit our website and also allows us to optimize our Website.

All websites are required to obtain your consent to the use or storage of cookies and similar technologies on your computers or mobile devices. This cookie policy gives you clear and complete information about the cookies we use and their purpose.

The cookies we use are safe. The information we collect using cookies helps us to identify any errors or to show you specific services that might be of your interest.

 

Types of cookies:

There are many different cookies that can be distinguished according to functionality, origin or storage period. Below you may find a general description of the most common types of cookies. Next, a detailed overview is given of the different cookies that are used on our website.

 

Necessary cookies:

These cookies are necessary for the website to function and cannot be disabled in our systems. They are usually set in response to actions taken by you, such as setting your privacy preferences, logging in or filling out forms. They are necessary for good communication and facilitation of page navigation (e.g. returning to a previous page, etc.).

 

Functional cookies:

These cookies increase the user-friendliness of the website by reminding you of your choices (e.g. language preference) and offering improved visitor and User functionality and personalisation. For example, these cookies allow certain settings to be personalised at your request. Non-acceptance of these cookies may affect the website’s performance and functionality and may restrict access to Website content. These cookies can be set by us or by third-party providers whose services we have added to our pages.

 

Analytic cookies:

These cookies collect information about the use of our website such as the number of visitors, the time visitors spend on a web page and any error messages. They help us improve the performance of the website. These cookies will not identify you.

 

Marketing cookies:

These cookies are used to deliver content that is more relevant to you. They can be used to deliver targeted ads or to limit the number of times you see an ad. These cookies can be used to remember websites that you have visited and share this information with other parties, including advertisers. These cookies may also be set by advertising partners through a website and used by those companies to build a profile of your interests and show you relevant ads on other sites.

 

Social Sharing Cookies:

We use some social sharing plugins, to allow you to share certain pages of our website on social media. These plugins place cookies so that you can correctly view how many times a page has been shared.

 

Third-party cookies:

First-party cookies are cookies that are sent from our servers or domains from which the requested service is offered. Third-party cookies are cookies that are sent to your browser from a server or domain that is not managed by us, but by a cooperating organization. Only these third parties have access to those cookies and the information collected by the cookie. If you would like to know more about these cookies, please refer to the policies that these parties offer on their respective websites. Please note that we have no influence on the content of their policy or on the content of these third-party cookies.

 

Your consent:

Upon your first visit to our website you will be asked to accept or refuse cookies. With this consent you agree to the different types of cookies we use.

 

Managing your cookies:

You can block cookies by altering your browser’s settings. The rejection of these cookies may inhibit some functionalities on the Website.

 

Safety and Confidentiality

LI has adopted safety measures which are suited on a technical, organizational and physical level to avoid the destruction, loss, forgery, adjustment, non-authorised access or the notification of the Personal Information by accident to a third party, as well as the non-authorised processing of these data. Should any of these events occur and affect your Personal Information, LI will inform you of the breach without undue delay, including a summary description of the potential impact and a recommendation on measures to mitigate the possible adverse effects of the breach.

LI shall not be liable in any way for direct or indirect damages caused by a wrongful or improper use of the Personal Information by a third party.

At the same time, you also share responsibility for maintaining the privacy and security of the Services, for example: by not allowing any third party to have insight in your confidential communication(s).

 

Applicable Law and Jurisdiction

This Privacy Policy is managed, interpreted and executed in accordance with South African law which exclusively applies to every potential dispute.

The courts and tribunals of South Africa have exclusive jurisdiction to settle any dispute arising out of or in connection to the interpretation or execution of the present Privacy Policy.

The access to/ use of our website, and the use of our services implies the User’s full and unreserved acceptance of this Privacy Policy as well as its General Terms of Use and the Cookie Policy. This means that you fully agree to how LI collects and processes your Personal Information.

The visitor and User(s) acknowledge having read the information above and authorize LI to process, in accordance with the provisions of this Privacy Policy, the Personal Information that the User(s) communicates to us, for the provision of our products and/or services.

This Privacy Policy is only valid for the pages hosted on our website and for the products and/or services we offer in accordance with our Terms of Use. It is not valid for the pages hosted by any third party to which LI may refer and whose privacy policies may differ. LI will therefore not be held responsible for any data processed by third parties in any way.

LI reserves the right to change, modify and update this Privacy Policy from time to time by posting a revised version on this website. Therefore, we recommend you regularly consult this Privacy Policy, to make sure that you are aware of all changes.

If you have any other questions, do not hesitate to contact us at the following address: [email protected]