Privacy Notice

Who are we

ComplexityFit is committed to protecting the information we hold about you. In this notice, we refer to ourselves collectively as ‘ComplexityFit,’ ‘we,’ ‘us,’ and ‘our.’

This notice provides you with information about how, when, and why we use your personal information and how we keep it secure. It also sets out your rights under the law, our responsibilities to you, and how you can contact us.

This notice concerns any information that we collect in the following ways:

Information we receive through our website Additional details of the information we receive through the ComplexityFit website are set out below, and Information we receive as a result of the products and services that we offer, including through our related support, mobile or cloud-based services.

Should you have any questions about who we are or what we do with your personal information, please contact us here.

General Information

Information about other people

If you provide us with personal information about other people – such as a joint applicant or your dependents - you must show this privacy notice to them, and you must ensure that you have their consent to provide their personal information to us.

Personal Information we hold about you

As with other businesses, we collect personal information about you.

Most of this information is necessary for us to comply with our legal obligations, to enter into a contract with you, or for legitimate business purposes.

When you apply to become a client, and during the course of our dealings with you, we will collect some personal information about you. This includes what you tell us about yourself and what we learn by having you as a customer. Whether this collection is mandatory or voluntary will depend on the reason why we are collecting your personal information. For example, if you want to become a client or investor of ours, we require certain mandatory information from you to be able to add you to the relevant register of the product you subscribe to. If you refuse or fail to supply this information, we will not be able to enter into a business relationship with you. However, if you voluntarily contact us about our products and/or services and you are not a client or investor, you are in control of what information you volunteer and which is subsequently collected by us.

We have set out below a description of the types of personal information about you that we will collect and process in different situations when you interact with us.

1. Personal information that we generally process regardless of how you contact us, or for whatever reason, includes:
• your title, full name, your contact details, including, for instance, your email address, home, and mobile telephone numbers; and/or
• your home address, correspondence address (where different from your home address), and address history.
2. If you submit an application to become a client or investor or are already one, in addition to the above personal information, we may collect the following from you:
• your date of birth and/or age;
• financial information, including your bank account information;
• proof of identification in the form of copies of your passport, driving license, or other identifying documents like utility bills.
• personal information and contact information which you provide in correspondence with us, whether by email, written letter, telephone call, or through our online inquiry system (this will be information volunteered by you, it could include the reasons why you have decided to invest, or where your investment money has come from, by way of example); and/or
• information relating to your use of our service, any other ComplexityFit products and services you currently have, you have applied for, or you have previously held.

3. When you interact with the ComplexityFit website, in addition to the above personal information, we may collect the following from you:
• where you submit an application for employment, such information may include education and qualification details, training and professional memberships and accreditations, date of birth; and/or
4. In addition to the above, we collect the following information from you when required:
• to comply with our legal and regulatory requirements, your tax residency and/or nationality;
• for anti-money laundering purposes, personal information which we obtain from identity verification agencies (see the section on ‘Identity Verification Agencies’ below);
• for regulatory compliance purposes relevant to specific products and/or services, information about your employment status (including whether you are employed, retired, or receive benefits) and regarding the source of your wealth; and/or
• to secure your online valuation facility, the answers to security verification questions, and/or your username.

Where we get your personal information from

We may have information about you that you did not provide to us yourself.

In relation to the categories of personal information described above, we collect personal information in the following ways:

Information that you provide to us.

We typically collect the personal information directly from you as part of our client on-boarding process when you complete an application form and provide proof of your identity. Additionally, we collect personal information from you when you correspond with us (whether by telephone, e-mail, or through the ComplexityFit website) or complete a request for a product or service. The nature of our relationship with you will determine the kind of personal information we might ask for.

Information that we collect or generate about you.

We will continue to collect additional personal information that we learn about you during the course of providing our products and services, such as:

• the way you use our online services; and/or
• information you provide in correspondence to us (whether by telephone, e-mail or through the ComplexityFit website), including contact history.

How we use your personal information and why
We need to use some personal information to provide you with our service and to fulfill our contract with you.

We mainly use the personal information we hold about you where it is necessary for us to perform our contract with you and/or to enable us to comply with legal obligations. Your personal information will also be used when it is in our legitimate interest. A legitimate interest is when we (and sometimes third parties) have a business or commercial reason to use your information. But even then, our legitimate interest must not unfairly go against what is right and best for you.

Each of these categories is a ‘legal basis that allows us to process your information under data protection law. We have provided further information below about what this actually means in terms of how we process or the purposes for processing your personal information relevant to each legal basis.

We need to use some personal information to provide you with our service and to fulfill our contract with you.

    • to communicate with you about your products or services (i.e., periodic updates);
      • to enable payments to be made;
      • to notify you about changes to your products and/or services (such as a change of name or amendments to the product or service);
      • to recover any money amount owed to us;
      • to investigate and deal with complaints or disputes;
      • to contact you when we have updated this Privacy Notice and consider that it is necessary to advise you about any changes to the way we are processing your personal information;
      • to transfer your personal information to any third party who replaces ComplexityFit as a provider of services to you; and/or
      • to share your personal information with third parties (such as our service provider who assists us with the administration of processing transactions on our behalf) if required for the management of your product or service.

Use of your information is necessary for us to comply with our legal obligations

We need to use some personal information to comply with legal obligations.

• to verify your identity and to carry out regulatory checks (such as anti-money laundering and identity verification checks);
• to enable a register of customers to be maintained;
• to contact you with notices about your product or service;
• to comply with audit requests from our auditor;
• to ensure you are eligible for a product;
• to comply with requests made by you when exercising your legal rights (such as those contained within this Privacy Notice);
• when to achieve the above purposes, we share your personal information with the following categories of individuals or organizations:
• law enforcement agencies and governmental and regulatory bodies such as tax authorities, financial regulators/ombudsmen, and non-financial regulators (depending on the circumstances of the sharing); and/or
• courts and to other organizations where it is necessary for the administration of justice, to protect vital interests, and to protect the security or integrity of our business operations.

Use of your information which is necessary to pursue our ‘legitimate interests

We are allowed to use your personal information to pursue our own interests as long as your fundamental interests do not override these.

This will include processing which, on balance, we consider is in our legitimate interests and which does not cause you undue prejudice. Our legitimate interests, which are applicable to our processing of your personal information, include:

• identification verification and any anti-fraud, anti-money laundering, and such other checks to confirm your identity and to ensure that the product or service which we handle for you is done in compliance with our legal obligations;
• administering and managing your account(s) and services relating to that, updating your records, tracing your whereabouts to contact you about your account;
• to adhere to guidance and best practices under the regimes of governmental and regulatory bodies;
• for management and audit of our business operations, including accounting;
• reviewing and improving the information provided on the ComplexityFit website to ensure is it user friendly and to prevent any potential disruptions or cyber-attacks;
• conducting analysis required to detect malicious data and understand how this may affect your IT system;
• for statistical monitoring and analysis of current attacks on devices and systems and for the ongoing adaptation of the solutions provided to secure devices and systems against current attacks;
• to determine the target market for our existing and future products (e.g., determining whether a product is meeting the needs of customers);
• to contact you when we have updated this Privacy Notice and consider that it is necessary to advise you about any changes to the way we are processing your personal information;

when to achieve the above purposes, we share your personal information with the following categories of individuals or organizations:

• members of our Group;
• our legal and other professional advisors and auditors;
• governmental and regulatory bodies;
• other organizations and businesses who provide services to us under contract, such as agents that recover money owed to us, back up and server hosting providers, IT software and maintenance providers, document storage providers, and suppliers of other back office functions;
• identity verification agencies (see below for more information); and/or
• market research organizations who help us to develop and improve our products and services

Use of your personal information with your consent

Where we are relying on your consent to process your personal information, you are entitled to withdraw your consent at any time.

However, as noted above, we are usually processing your personal information based on another reason, in which case withdrawing your consent will not change how we process your personal information.

If you wish to withdraw your consent, you may do so by contacting us.

Unlike the uses described above, sometimes we rely on your consent to use your personal information. We will rely on your consent:

• where you have submitted an application for employment on the ComplexityFit website to process your application;
• where you have opted-in to receiving marketing communications (and have not subsequently opted out or requested to be removed from any marketing list); and/or
• when you volunteer information to us in correspondence, which information we need in order to respond to your enquiry, and only where lawful to do so.
• You have the right to withdraw your consent at any time by contacting us.

Please note, that if you do withdraw your consent, this will mean that we will stop similar future processing. However, the withdrawal of your consent will not invalidate any processing which we previously undertook before you withdrew your consent.

Please note that where we rely on another lawful reason to process your personal information which does not require your consent, withdrawing your consent will not affect that processing. This is the case where the processing is necessary for our performing our contract with you or where we must process your personal information to comply with the law, as described above. We will continue to process your personal information for those lawful purposes, notwithstanding the fact that you have withdrawn your consent for one of the above-listed purposes that requires your consent.

Whether you have to provide personal information

If you want to use our services, there is some information that you will be required to provide to us either because of legal requirements or because we need that information to provide our services to you.

We are required to collect some personal information by law and regulation. For example, we are required to verify your identity before we can accept any applications.

In other cases, we need the information in order to provide our service to you.

We will tell you when the personal information requested is mandatory or if it is voluntary. If you do not provide that personal information that is mandatory, we will be unable to properly provide you with the services and/or perform all obligations under our agreement with you.
Where you choose not to provide us voluntary personal information, this may reduce the quality of service we are able to provide (for example, if you only provide us your contact number and do not provide us with your e-mail address, we will only be able to contact you telephonically).

Will we share your personal information with others

Your personal information will be shared with other businesses, regulators and authorities.

Yes, there are times when we are either mandated by law to disclose your personal information to third parties.

We will never sell, rent or trade your personal information.

We will share your information with others who have a duty to keep it secure and confidential and where we have a lawful reason for doing so, as explained above. The categories of organizations that we will share your information with are:

• other than ComplexityFit;
• professional advisors, such as lawyers;
• anyone we transfer our rights and duties to – e.g., if we restructure or sell our business.

We cannot control all use of your information by third parties (especially where they are not our service providers and under contract with us, for example, personal information shared with regulators). As such, where your personal information has been shared with another data controller entity, you will have rights over how that third party handles your personal information, and you can and should contact those parties directly if you want to exercise your rights in relation to those third party’s uses of your personal information.

Where we transfer your data

We will also share your personal information, where necessary, with regulatory authorities in South Africa. It is possible that those authorities will, in turn, also share your information with other regulators. However, when they do so, they do so in their own legal capacities. So if you would like more information about how they handle your personal information, you will need to contact them directly.

How long we will keep your information

Your information may be held for a considerable period after our relationship ends (or indefinitely if anonymized).

We will keep your personal information as long as you are a client of ComplexityFit.

After you cease to be a client of ours or investor with us, we may keep your data for up to an additional five years for one of the below reasons:

• To respond to any questions or complaints;
• To show that we treated you fairly;
• To maintain records in accordance with the rules that apply to us, including legislation surrounding the history and storage of financial records.

We may keep your data for longer than five years if we cannot delete it for legal or regulatory reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use the data for those purposes and, to the extent possible, anonymized.

Your rights (‘data subject’ rights)

You have a number of rights over your personal information, including a right to object to the processing of your information.

You will not be able to use these rights in all circumstances.

You are also entitled to make a complaint to the ombudsman.

Under data protection law, you have a number of rights (set out below). Please note that these rights are not without limitation and in some instances, may not be available.

Where applicable, you have the right to:

• be informed about our processing of your personal information;
• have inaccurate/incomplete personal information corrected/completed;
• object to the processing of your personal information;
• restrict the processing of your personal information;
• have your personal information erased;
• request access to your personal information and obtain information about how we process it;
• move, copy or transfer your personal information digitally;
• object to automated decision-making, such as profiling.

To exercise your rights as set out above, please contact us here. There is no fee for making these requests.

You also have the right to lodge a complaint with your local data protection regulator if you think we have infringed upon any of your rights.

Pursuant to applicable law, you will not be discriminated against for exercising certain of your rights as set out above.

Automatic Information and Cookies

If you use the ComplexityFit website, we may collect technical information through the use of cookies. For example, what pages of the ComplexityFit website were visited by each user, any documents downloaded, and security incidents.

We may also automatically collect, or use third-party service providers to collect, certain information in relation to your use of any online service or the website (Automatic Information). This information may be aggregated to provide data related to how our website performs and does not identify you or your individual browsing behavior.

If you submit a form, you may opt-in to saving your name, email address, and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you use the ComplexityFit website and follow a link from it to another website, different privacy policies may apply. Prior to submitting any personal information to a website, you should read the privacy notice applicable to that website.

Future changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will notify you when we make any substantial updates.

We will also notify you in other ways from time to time about the processing of your personal information. For example, if you take out a new product with us.

The latest version of this privacy notice can always be found at


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