Capital Legacy Solutions (Pty) Ltd, Capital Legacy Fiduciary Services (Pty) Ltd and Capital Legacy Board of Executors and Trust Company (Pty) Ltd, Quill Consulting (Pty) Ltd and Sanlam Trust (Pty) Ltd, located at 1st Floor, Roland Garros, The Campus, 57 Sloane Street, Bryanston 2191 (“Capital Legacy”) respect and acknowledge the importance of protecting your Personal Information. This Privacy Notice sets out how Capital Legacy will process your Personal Information in the ordinary course of conducting its business and it also applies to Capital Legacy’s website.
What personal information we collect
Capital Legacy collects the information that you voluntarily submit, including the following:
- Personal Information – your full names, sex, gender, address, smoking status, highest education, identity number or passport number, employment number monthly income, banking details, email address, telephone number, cellular number, language preference, medical or health information (where applicable);
- Distribution of your Estate – special bequests and residue;
- Last wishes (optional);
- Organ donor registration (optional);
- Nominations for Executors, Trustees, and Guardians;
- Testamentary drafting notes (optional);
- Nomination of Beneficiaries, including Children’s details (if applicable);
- Intermediary and fulfilment preferences;
- Asset and liability values that make up the total value of your Estate;
- Online information - for example, cookies and IP address (your computer’s internet address), if you use our websites, apps and/or social media channels.
- Any other information required by Capital Legacy, suppliers, insurers, or third parties in order to provide you with an accurate analysis for Estate planning, produce a Legacy Blueprint™ Planner, and issue a policy or process a claim.
We may collect information that you submit when you contact customer support or provide feedback.
We acknowledge that information about your health is special personal information as defined in the Protection of Personal Information Act. Please be assured that we will use that information strictly in accordance with applicable laws and for insurance purposes only to the extent that it is necessary for us to formulate the terms of the insurance contracts, dealing with changes to any policy and/or dealing with claims).
Information from other sources.
This may include:
- users providing your information in connection with referral programmes;
- users requesting services for you or on your behalf;
- publicly available sources;
- data aggregators;
- Credit bureaus;
- Fraud prevention agencies;
- marketing service providers.
How Capital Legacy uses your Personal information
Providing services and features
Your information will only be used for the purposes for which it was intended. These may include:
- drafting a Last Will and Testament, Codicil, or any amendments thereto;
- financial needs analysis;
- issuing a or providing a product or service and generally carrying out the transaction requested;
- managing and servicing your policy;
- processing your requests or instructions;
- to undertake credit reference searches and/or verification;
- assessing and processing claims;
- claims history and reporting;
- detection of fraud, crime, money laundering or other malpractice;
- conducting market or policyholder research and ensuring that the product and services remain relevant;
- provide you with information about our products and services from time to time via email, telephone or other means;
- auditing and record keeping;
- legal proceedings; and
- complying with legal and regulatory requirements.
Safety and security
We may use your data to help maintain the security of our services.
Capital Legacy uses the information we collect to assist you when you contact customer support, including to:
- investigate and address your concerns;
- managing and servicing your policy;
- monitor and improve our response.
Communications from Capital Legacy
Subject to applicable laws, Capital Legacy may use information to communicate with you, regarding marketing materials.
Capital Legacy may also use the information to promote and provide you with relevant adverts and content about our services.
How we collect personal information
We may collect your Personal Information in a variety of ways when you interact with us, including:
- a completed Application Form that gets completed and signed by you for processing;
- when you engage with us to solicit our products or services;
- when we respond to your enquiries and requests;
- as a result of communications between you and financial advisors or representatives;
- when we obtain feedback from you about our services; and
- when you access and use our websites.
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 extent that this is permitted by applicable law.
Where you provide Personal Information to us about third party individuals (e.g., information about your spouse, civil partner, child(ren), dependants or emergency contacts), where appropriate, you should ensure that such individuals are made aware of how their Personal Information will be used by us, by providing them with a copy of this Privacy Notice or otherwise making them aware of the manner in which we will use their Personal information
Legal Grounds for Processing
By virtue of your engagement with Capital Legacy, you acknowledge that Capital Legacy shall have the right to process Personal Information provided to Capital Legacy by you or some other party, to enable Capital Legacy to fulfil its legal and contractual obligations.
Personal Information may also be used based on the legitimate interests pursued by Capital Legacy or its affiliates, 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 Capital Legacy to utilise your Personal Information in the manner described in this Privacy Notice, Capital Legacy will not be in a position to offer you use of its services.
Capital Legacy may share your information other than as described in this notice if we notify you and you consent to the sharing. In circumstances where you give us your consent for a specific purpose, you are entitled to withdraw that consent at any time. Be aware that in the event that you withdraw your consent, this will not affect any processing of your Personal Information that took place prior to such withdrawal and it will not affect the processing of your Personal Information where there are other lawful grounds for processing your Personal Information.
You are responsible for informing Capital Legacy if your information changes.
Transfers To Third Parties
Capital Legacy may share the information we collect with:
Capital Legacy subsidiaries and affiliates
We share information with our holding companies, shareholders, subsidiaries and affiliates to help provide our services, for governance and regulatory requirements or conduct data processing on our behalf.
Capital Legacy service providers and business partners
Capital Legacy 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 Capital Legacy to enhance the safety and security of its business activities;
- consultants, lawyers, accountants and other professional service providers;
- successors of the business, where Capital Legacy or the services are sold to, acquired by, or merged with another organisation, in whole or in part. Where Personal Information is shared in these circumstances it will continue to be Processed in accordance with this Privacy Notice; and
- insurance and financing partners.
Other entities for legal reasons or in the event of a dispute
Capital Legacy may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.
7. Cross-Border Data Transfers
Your data may be subject to cross-border data transfers. When making cross-border transfers of Personal Information, Capital Legacy will ensure that the third-party processor (operator) is subject to a law, binding corporate rules or binding agreement which provides an adequate level of protection for the lawful processing of your Personal Information and includes provisions, relating to the further transfer of Personal Information from the recipient to third parties who are in a foreign country. Where applicable, Capital Legacy will contractually commit to employ suitable technical and organisational measures to protect your Personal Information as required by the applicable law (hereinafter referred to as “Supplier Data Processing Agreements”), as well as other suitable safeguards recognised by Data Protection Laws.
Capital Legacy requires Plan Holders’ information in order to provide our products and services. We retain such information for as long as you maintain your Capital Legacy plan or have your Will and any codicils lodged with us.
Once information is no longer necessary to provide Capital Legacy services, enable customer support, enhance the user experience or for other operational purposes, Capital Legacy takes steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.
Capital Legacy may also retain certain information, if necessary, for its legitimate business interests, such as fraud prevention and enhancing Plan Holders’ safety and security.
Security of your personal information
Capital Legacy is committed to protecting your Personal Information from misuse, loss, unauthorised 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.
Whilst Capital Legacy makes every effort to secure its websites, you should note that the internet is not completely secure; thus when you submit or post Personal Information online, you should be aware that Capital Legacy cannot guarantee the security of any Personal Information that you submit or post online.
By using the Capital Legacy website, you accept that your Personal Information may be disclosed to Capital Legacy employees, suppliers and marketing agents where this information is necessary for them to offer, evaluate and enhance products and services offered on the Capital Legacy website.
As our client, we are allowed to send you marketing material about our own similar products and services. As a visitor to our website ,we are also permitted to approach you for your consent to receive our marketing materials.
In all instances, 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 or SMS text message from us; or
- sending an email to [email protected] including your details and a description of the marketing material you no longer wish to receive from us.
We will comply with your request as soon as is reasonably practicable.
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 without your consent to unaffiliated third parties for direct marketing purposes or sell, rent, distribute, or otherwise make Personal Information commercially available to any third party.
We operate and communicate through our designated channels, pages and accounts on some social media sites 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 South Africa that may have different privacy regulations. We regularly update and monitor our social media accounts and welcome feedback and ideas sent to us through these channels. We try to join conversations whenever possible but cannot guarantee that we will read or reply to all messages sent to official Capital Legacy 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 Capital Legacy.
Changes to our Privacy Notice
We may change this Privacy Notice at any time. The most updated version will be always be available on www.capitallegacy.co.za.
Upon your request, we will provide you with access to any Personal Information on you that we may hold. You may also request us to correct your Personal Information, at any time. You can contact us on [email protected] to request access to your Personal Information or the correction of your Personal Information. You can also seek to be removed from any of Capital Legacy’ subscriptions lists at any time by contacting us on [email protected].
Please note that the above rights are not absolute, and Capital Legacy may be entitled to refuse requests where exceptions apply.
If you have any compliant about the way in which Capital Legacy handles your Personal Information, you may lodge a complaint with Capital Legacy by emailing [email protected]. Our Information Officer will then look into your complaint and work with you to resolve the matter.
If you still feel that your Personal Information has not been handled appropriately according to
the law, you can contact South African Information Regulator
( [email protected] ) and file a complaint with them.