PRIVACY POLICY 

“User” means the viewer or user of Investec’s Platforms. 

“Our” refers to Investec. 

“Platforms” means all our websites, mobile sites, social media platforms or any other technology or mechanism you may use to interact with us.  

“Investec” means the owner of the website, Investec Property Fund Limited, registration number is 2008/011366/06, registered in the Republic of South Africa and whose registered office is 100 Grayston Drive, Sandown, 2196. 

“We” Investec Property Fund Limited.  

This privacy policy sets out how Investec uses and protects any information that the User gives Investec when using its Platforms. 

Investec is committed to ensuring that the User’s privacy is protected. Should Investec ask the User to provide certain information by which the User can be identified when using the Platforms, such information will only be used in accordance with this privacy policy. “Website” means the website located at or accessed on this Platform as well as other Investec domains as may be available from time to time.

This Privacy Policy sets out what categories of personal information Investec may collect from the User when the User visits the website and its associated microsites (the “Website”) as well as how Investec processes that personal information. This Privacy Policy must be read in conjunction with our Data Protection Statement ( Data Protection Statement (investec.com) ).

If you have any questions about this Privacy Policy, please see contact details at the end of this page. Investec may amend this Privacy Policy from time to time, so you should check this page from time to time to ensure that you are aware of any changes that have been made. If we make material changes to this Privacy Policy, we will notify you by means of a prominent notice on the Website prior to the change becoming effective.

What we collect 

Investec may collect the following information: 

Personal information you volunteer or which we may infer.

Any domain name information that we collect is not used to personally identify you but is instead aggregated to measure the number of visits, average time spent on the Website, pages viewed. We use this information to measure the use of our Website and to improve its contents. However, additional services may be available if we have certain information about you. 

This includes any information that you provide to us directly: 

• when you use our services; 
• by completing forms on our Platforms, or those provided to you; 
• when you contact us, or we contact you and you provide information directly to us. 

We may collect the following information, including personal information:

• A list of the products and services you express an interest in when you use the Platform;
• Your name, surname, identity or passport number, date of birth and contact information, including email address and company details which you may submit to us when you interact with the Website; and
• Information regarding your personal or professional interests, demographics, experiences with our products and contact preferences in order to provide you with further correspondence about our products and services;
• Other information relevant to customer surveys and/or offers. 

If you do not provide the information we need, we may not be able to provide our services to you. Where you provide us with the personal information of third parties you should take steps to inform the third party that you need to disclose their details to us, identifying us. We will process their personal information in accordance with this Privacy Policy and our Data Protection Statement.

We may intercept and monitor your communications

To the extent permissible by law, Investec may implement systems designed to intercept and monitor your communications with Investec’s Associates. As part of this process of intercepting and monitoring these communications, we may record such communications for disclosure on the basis set out in this Privacy Policy.

Personal information we collect automatically

When you use the Platform, Investec automatically receives and records information on our server logs from your browser or mobile platform, including your location, IP address, cookie information, and the page you requested. We treat this data as non-personal information, except where we are compelled to do otherwise by law or legal authority.

Investec only uses this data in aggregate form and we may provide this aggregate information to our partners about how our customers, collectively, use the Platform, so that our partners may also understand how users make use of the Website.

Information from third-party sources 

We may receive additional information about you that is publicly or commercially available and combine that with the information we have collected or received about you through other forms of communication.

What we do with the information we gather 

Investec requires this information to understand the User’s needs and provide the User with a better service, and in particular for the following reasons: 

• To communicate with User’s and to provide the User’s with services requested and notify User’s about important changes or developments to these services; 
• Internal record keeping; 
• To provide User’s with services and product, or to fulfil our obligations toward User’s; 
• Improvement of our Platforms, products, and services; 
• To provide User’s with services User’s have requested and notify User’s about important changes or developments to these services;
• To respond to User’s inquiries and/or complaints or process your requests in relation to User’s information;
• To follow up as part of our customer care procedures;
• To update our records about User’s;
• To contact User’s for market research purposes and/or administer offers to User’s;
• To improve our products and services; 
• For fraud prevention and detection, and to comply with applicable laws and regulations;
• In relation to competitions and other promotions;
• To evaluate the effectiveness of our marketing and for research, training and statistical analysis with the aim of improving our services; and
• To make our Website easier for User’s to use and to provide User’s with access to certain parts of the Website;
• Investec may periodically send promotional emails about new products, special offers or other information which it thinks the User may find interesting using the email address which the User has provided; 
• From time to time, Investec may also use the User’s information to contact the User for market research purposes. We may contact you by email, phone, fax, or mail. We may use such information to customise the website according to your interests.

 Investec processes your personal information for the purposes outlined above where:

• The processing of the User’s personal information is necessary to perform a contract or enter into a contract with the User;
• The processing of your personal information is necessary for us to comply with legal and regulatory obligations; or
• The processing is necessary to support our legitimate interests in managing our business (or those of a third party) provided such interests are not overridden by the User’s interests and rights.

Your Right to Object  

Please note that you have a right to object to the processing of your personal information where that processing is carried out for our legitimate interests. Where required by applicable law, where we send you direct marketing, we will obtain your consent for this, which you may withdraw at any time.

Security 

We are committed to ensuring that the User’s information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information it collects online. 

Cookies – How we use cookies 

A cookie is a small file which asks permission to be placed on the User’s computer’s hard drive. Once the User agrees, the file is added, and the cookie helps analyse web traffic or lets the User know when the User visits a particular site. Cookies allow web applications to respond to the User as an individual. The web application can tailor its operations to the User’s needs, likes and dislikes by gathering and remembering information about the User’s preferences. 

We make use of traffic log cookies to identify which pages are being used. This helps analyse data about webpage traffic and improve the website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. 

The User can choose to accept or decline cookies. 

Investec will not use cookies to collect personally identifiable information about you. 

However, if you wish to restrict or block the cookies which are set by Investec websites, or indeed any other website, you can do this through your browser settings. The Help function within your browser should tell you how.

Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies.

Please be aware that restricting cookies may impact on the functionality of Investec websites.

If you wish to view your cookie code, just click on a cookie to open it. You’ll see a short string of text and numbers. The numbers are your identification card, which can only be seen by the server that gave you the cookie.

For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

Linking

We may link to other websites which are not within our control. Once you have left our Platform, we are not responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the privacy statement applicable to the third party’s website in question.

How we share the information of the User 

Investec will not sell or lease a User’s personal information to third parties without the User’s permission. Investec may share User’s information with:  

• • Investec affiliates, in other words, other companies in the Investec group; 
  • Other parties in response to legal process, laws, or when necessary to conduct or protect our legal rights;  
  • Selected third parties to provide us with services, including companies that provide us with technical support and assistance in respect of the Website, companies that provide back-office services, companies that provide hosting services or, that track the Website’s activities and analytics, and companies engaged to market and distribute Investec products and/or services;
  • Professional advisers, judicial, regulatory and law enforcement bodies; 
  • A third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganisation or otherwise; and 
  • Companies that provide services to us (companies that provide services to us or act on our behalf may have access to information about you. These companies are limited in their ability to use information they receive while providing services to us or you).

Retention of data 

Investec will retain User personal information only for as long as is necessary for the purposes set out in this privacy policy or to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.  

We may retain other data for internal analysis purposes. 

We are required to ensure that your personal information is accurate and maintained in a secure environment for a period of time no longer than necessary for the purposes for which we are processing your personal information. We generally keep personal information collected via the Website in accordance with the timeframes set out in any relevant legislation which applies to the personal information provided to us. However, in some cases we may need to keep personal information for longer (e.g., where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or dealing with complaints, legal challenges or prospective litigation).

Transfer of data 

• Investec is based in and operates from South Africa. Your information, including personal information, may be transferred to, and maintained on servers located outside of your country, where the data privacy laws, regulations and standards, may not be equivalent to the laws in South Africa. 
• We might transfer your personal information to places outside of South Africa and store it there, where our suppliers might process it. If that happens, we require our suppliers to apply the same standards as when we process your information in South Africa. 
• Your consent to this privacy policy followed by your submission of such information to us, represents your agreement to such transfer. 
• We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. 

Your rights 

You have the right to ask us not to contact you for marketing purposes. You can exercise this right at any time by using any of the various “opt-out” options that we will always provide to you when we communicate with you. We will not send you marketing messages if you tell us not to, but we will still need to send you service-related messages. 

You may request details of personal information which we hold about you under the Promotion of Access to Information Act, 2000 (“PAIA”). If you would like to obtain a copy of your personal information held by Investec, please contact our information officer as listed below. 

You have a right to object on reasonable grounds to the processing of your personal information where the processing is carried out to protect our legitimate interests or your legitimate interests unless the law provides for such processing. If you wish to exercise this right, please contact our information officer as listed below. 

Information Officer 

We have appointed an Information Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Information Officer. You have the right to make a complaint at any time to the Information Regulator of South Africa. 

Information Officer 

Email: dataprotectionsa@investec.com

Information Regulator of South Africa 

Tel: 012 406 4818 

Fax: 086 500 3351 

Email: compliants.ir@justice.gov.za