INERTIA’S POPI NOTICE

1. INTRODUCTION

Inertia Ventures (Pty) Limited (“Inertia”) is committed to ensuring the privacy and integrity of information submitted by data subjects on our website. All information of a personal nature submitted or provided by data subjects will be treated with confidentiality and will not be disclosed to any person without express consent of the data subject concerned. However, any information provided or submitted by a data subject may be disclosed where such information is in the public domain or Inertia is obliged in terms of any law, order of court, legal process or other lawful reason to disclose such information.

This POPI Notice sets out how Inertia collects and processes your personal information so that it can complete business operations around financial analysis, services and graphical demonstrations and it also applies to the tech platform/website of Inertia.

2. WHAT PERSONAL INFORMATION WE COLLECT

1. User Information

Inertia’s sole purpose is to collect the information that you voluntarily submit while using the platform, to generate your financial overview. The information collected includes, but is not limited to the following:

• Personal information

• Full names, marriage details and birth date
• Email address and contact numbers

• Asset and investment information
• Any other information required by Inertia, your financial advisor or third parties in order to create and demonstrate your estimated financial future

2. Information from other sources

This may include:

• Referrals: Users providing information of a data subject in connection with referral programs.
• Third party links: You acknowledge that third parties may also collect your personal information. You agree that the information processing practices of those third parties are neither under our control nor regulated by this Privacy Notice and that we cannot accept liability for such practices. Please make sure that you are aware of third parties’ particular information processing practices
• Publicly available sources

3. HOW INERTIA USES YOUR PERSONAL INFORMATION

1. Providing services and features

Your information will only be used for the specific purpose for which it was intended. These may include:

• Creating an overview of your current financial situation and illustrate how the current investment strategy and financial decisions may affect the user’s retirement using the Inertia website, or any changes and edits thereto.
• Determining illustrative graphs for each data subject.
• Providing a digital financial journey for each data subject.
• Providing quotes for other financial service offerings.
• Processing your requests or instructions that are received digitally or through the support line.
• Record keeping.
• Legal proceedings.
• Complying with legal and regulatory requirements.

2. Safety and security

To maintain the security of our services, we may use your data in a safe and regulated manner.

3. Customer support

Inertia uses the information we collect to assist you when you contact customer support, including to:

• Investigate and address your issues, concerns and questions.
• Supporting your user journey and facilitating edits and inputs while demonstrating your financial overview on the Inertia platform.
• Monitoring and improving our response to support issues.

4. Communications from Inertia

Inertia may use information you provided to communicate with you, regarding marketing materials that are aligned to the needs determined from the Inertia platform.

Inertia may also use the information provided by you on the platform to promote and provide you with relevant financial service offerings, advertisements and content about our services.

4. HOW WE COLLECT PERSONAL INFORMATION

We may collect your personal information in several ways while interacting with the Inertia team. These may include:

• Through the website/tech platform where you proceed on the user journey by providing relevant information on appropriate pages.
• When you engage with the Inertia team or consultants to solicit Inertia products or services.
• When our support team responds to your enquiries and requests.
• When we obtain feedback from you about our products, services and tech platform.

We may also collect your personal information from third party sources and third parties including public databases, business partners with whom we offer co-branded services or engage in joint-marketing activities, and third parties that provide list enhancement or similar services, to the exten that this is permitted by applicable law.

5. LEGAL GROUNDS FOR PROCESSING

By virtue of your engagement with Inertia, you acknowledge that Inertia shall have the right to process personal information provided to Inertia by you or some other party, to enable Inertia to fulfil an obligation to you in terms of its financial planning offerings.

Personal information may also be used based on the legitimate interests pursued by Inertia, except where such interests are overridden by your interests or fundamental rights and freedoms which require the protection of your personal information.

In the event that you refuse to permit Inertia to utilize your personal information in the manner described in this Privacy Notice, Inertia will revoke your access to the use of its services.

6. TRANSFERS TO THIRD PARTIES

Inertia may share the information we collect with:

• The Enhance IFA Group Companies, which include:
• Peter Strydom Financial Services CC
• Enhance IFA Solutions (Pty) Ltd
• GSP Wilson (Pty) Ltd
• Integrious (Pty) Ltd

5. Inertia service providers and business partners

Inertia may provide information to its vendors, consultants, marketing partners, research firms and other service providers or business partners. This may include, for example:

• Payment processors and facilitators.
• Cloud storage providers.
• Marketing partners and marketing platform providers.
• Data analytics providers.
• Research partners.
• Vendors that assist Inertia to enhance the safety and security of its business activities.
• Consultants, lawyers, accountants and other professional service providers.
• Insurance and financing partners.
• Business partners.
• Platform software developers

6. Other entities for legal reasons or in the event of a dispute

Inertia may share your information if we believe it is required by applicable law, regulation, operating agreements, legal processes or government requests, or where the disclosure is otherwise appropriate due to safety or similar concerns.

7. With your consent

Inertia may share your information other than described in this notice if we notify you and you consent to the sharing.

7. CROSS-BORDER DATA TRANSFERS

Inertia currently has no reason to conduct cross border data transfers, however, if your data were to be subjected to cross-border data transfers, Inertia would implement the following process when making cross-border transfers of personal information:

• When personal information is processed in other countries, we will ensure that the level of protection of your personal information will be the same as or higher than in South Africa, as required in terms of South African law.
• Protection of this information will be a top priority.

8. RETENTION

We will keep your personal information only for as long as it is necessary to achieve the purpose for which it was collected or subsequently processed, unless the requirements are different, as in the instances set out below:

• Law: We are required or authorized by law to keep your personal information for a longer period.
• Lawful purposes: We require the personal information for lawful purposes relating to our functions or activities.
• Legal rights: We require the personal information to exercise or defend our legal rights.
• Statistics: We require the personal information for historical, statistical or research purposes (such information will be anonymized).
• Contractual: We require the personal information because of our contract with you.

Inertia may also retain certain information, of the data subject, who has taken up financial services through the platform. We retain such information for as long as required by law or for as long as they maintain paid-up subscriptions, premiums and the policy is in active status.

9. SECURITY OF YOUR PERSONAL INFORMATION

Inertia is committed to protecting your personal information from misuse, loss, unauthorized access, modification or disclosure by using a combination of physical, administrative and technical safeguards and contractually requiring that third parties to whom we disclose your personal information do the same. We will take all reasonable measures to ensure that the information you transmit to use using our website will remain confidential and protected from unauthorized access.

Keeping secure all the personal information associated with you is of the utmost importance to us. While we exercise great care in providing secure transmission of your personal information, no data transmission over the internet can be guaranteed to be 100% secure.

10. WEBSITE

By using the Inertia website/platform, you accept that your personal information may be disclosed to Inertia employees, service providers and partners and marketing agents where this information is necessary for them to offer, evaluate and enhance products and services offered on the Inertia website.

11. DIRECT MARKETING

As our client, we are allowed to send you marketing material relating to the financial services offered with the intent of you creating your financial/retirement estimations.

You may opt out of receiving further marketing materials from us at any time and manage your communication preferences by:

• Following the unsubscribe instructions included in each marketing email received from us; or
• Sending an email to support@inertiaplanning.com including your details and a description of the marketing material you no longer wish to receive from us. Your request will be actioned within 48 hours from receipt of correspondence.

If you opt out of receiving marketing-related communications from us, we may still send you administrative messages as part of your ongoing use of our website, solutions, products or services.

We do not provide your personal information to unaffiliated third parties for direct marketing purposes or sell, rent, distribute or otherwise make your personal information commercially available to any third party.

12. SOCIAL MEDIA

We operate and communicate through our designated social media channels, pages and accounts to inform, help and engage with our users. We monitor and record comments and posts made about us on these channels so that we can improve our services.

The general public can access and read any information posted on these sites. We are not responsible for any information posted on those sites other than the information posted by our designated officials.

We do not endorse the social media sites themselves, or any information posted on them by third parties or other users. When you engage with us through social media, your personal information may be processed by the site owner; this processing occurs outside of our control and may take place in a country outside of South Africa that may have different privacy regulations.

We regularly update and monitor our social media accounts as a communication platform to show where we can do better and share ideas. We try to join conversations whenever possible but cannot guarantee that we will read or reply to all messages sent to official Inertia social media accounts.

Consistent feedback and helpful suggestions will be given to the relevant people within the company for consideration, but we cannot guarantee that any feedback or suggestions will be acted upon by the Inertia team.

We align our content to the community standards that these social media platforms condone.

13. CHANGES TO OUR PRIVACY NOTICE

We may change this Privacy Notice at any time. The most updated version will always be available on the Inertia website.

14. YOUR RIGHTS

Upon your request, we will provide you with access to any personal information that we may hold. You may also request us to correct your personal information that we may hold. You can contact us on support@inertiaplanning.com to request access to your personal information or the correction of your personal information.

If you have any complaint about the way in which Inertia handles your personal information, you may lodge a complaint with Inertia directly by emailing support@inertiaplanning.com and indicating POPIA in the subject line.

Should you be unhappy about the way your complaint has been managed or you feel that your personal information has not been handled appropriately according to the law, you can contact the South African Information Regulator (inforeg@justice.go.za) and file a complaint with them.