Privacy and Cookie Policy

Effective Date: 01 July 2025
Last Updated: 01 July 2025

1. Introduction

Scotasay Financial Western Cape (Pty) Ltd (“Scotasay”, “we”, “us”, or “our”) is committed to protecting your privacy and ensuring the lawful processing of your personal information. This Privacy and Cookie Policy outlines how we collect, use, disclose, store, and protect your information when you use our website or our financial services.

Scotasay is a company registered in South Africa (Reg. No. 2024/431460/07) and is authorised and regulated by the Financial Sector Conduct Authority (FSCA) under FSP No. 54718.

This policy complies with:

The Protection of Personal Information Act (POPIA)
The General Data Protection Regulation (GDPR), where applicable
Applicable South African financial regulatory requirements

2. Information We Collect

We may collect and process the following types of personal data:

A. Information You Provide Directly

Full name, contact details (phone, email, address)
Identification documents (e.g., passport, ID, proof of residence)
Employment and financial information
Trading experience and investment objectives
Account login details

B. Information Collected Automatically

IP address, browser type, device information
Cookies and usage data (see Section 7)
Geolocation data

C. Information from Third Parties

Credit checks or KYC verification services
Regulatory or compliance databases

3. How We Use Your Information

We use your personal data for the following purposes:

To onboard you as a client and conduct KYC/AML checks
To provide financial services and manage your trading account
To comply with legal and regulatory obligations
To respond to your enquiries or support requests
To personalise your user experience and improve our services
For marketing and communication purposes (with your consent)
For internal audits, risk management, and security

4. Lawful Basis for Processing

We process your personal information under one or more of the following lawful bases:

Your consent
The necessity to perform a contract
Compliance with legal or regulatory obligations
Our legitimate interests (e.g., fraud prevention, service improvement)

5. Sharing and Disclosure

We may share your information with:

Regulatory authorities such as the FSCA or SARS
Third-party service providers (e.g., IT, payment processing, KYC providers)
Legal or compliance professionals where required
Other entities only with your explicit consent or under legal obligation

We do not sell your data to third parties.

6. Data Storage and Security

Your data is stored securely using encrypted systems and access controls. We take reasonable technical and organisational measures to protect your information against loss, misuse, and unauthorised access.

Retention periods are based on legal, regulatory, and business requirements. Typically, data is retained for five (5) years after account closure in line with FSCA rules.

7. Cookies Policy

What Are Cookies?

Cookies are small data files stored on your device when you visit our website. They help us understand how users interact with our site and enhance functionality.

Types of Cookies We Use

Essential Cookies: Required for the website to function.
Analytical Cookies: Help us understand user behaviour (e.g., Google Analytics).
Functional Cookies: Remember preferences and settings.
Marketing Cookies: May be used to deliver relevant advertisements (used only with consent).

Managing Cookies

You can control or delete cookies through your browser settings. If you disable cookies, some parts of our website may not function properly.

8. International Transfers

If your data is transferred outside South Africa, we ensure appropriate safeguards are in place (such as contracts or adequacy decisions) to protect your information in compliance with POPIA and GDPR where applicable.

9. Your Rights

Under POPIA and (if applicable) GDPR, you have the right to:

Access your personal data
Request correction or deletion
Object to or restrict processing
Withdraw consent at any time
Lodge a complaint with the Information Regulator or data protection authority

South African Information Regulator: https://www.justice.gov.za/inforeg/

10. Contact Us

If you have any questions about this Privacy and Cookie Policy, or wish to exercise your rights, please contact us:

Scotasay Financial Western Cape (Pty) Ltd
896 Codonia Avenue, Waverley, Gauteng, South Africa
Email: info@scotasay.com

11. Changes to This Policy