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About Us

The Empowerment Capital Group — which includes Empowerment Capital Investment Partners (Pty) Ltd, Andzani Ventures (Pty) Ltd, Imvelo Ventures (Pty) Ltd, and EPIC Venture Capital (Pty) Ltd — does process protected personal information.

Information We Collect

Any information requested from you is used to provide information for the purpose of those who enquire about our products and services, and to handle related business matters as well as compliance with applicable laws. This information is also used to get in touch with customers when necessary. From time to time, the information gathered through this site will be used to notify you about products and services that we think will be of interest to you.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track the activity on our website and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our website.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.

Sharing of Personal Information

We may have to pass on personal information that you have shared with us to other third parties. However, we do not sell, rent, trade or lend such personal information to third parties. This site contains a number of links to other sites. We are not responsible for the security or privacy practices of these sites, the products or services offered by these sites, or the content appearing at these sites. We do not endorse any of the products or services marketed at any other sites.

Security

Our site is protected with a variety of security measures. We also employ a variety of other mechanisms to ensure that data you provide is not lost, misused, or altered inappropriately. These controls include data confidentiality policies and regular database backups.

Our Privacy Documents

You can read our full privacy documentation below:

1. Overview of the Empowerment Capital Group

Empowerment Capital Investment Partners (Pty) Ltd ("Empowerment Capital" or the "Group") has a portfolio of integrated financial services businesses and operates in South Africa. Through its portfolio of separately branded financial services businesses, the Group offers a universal set of investment and finance products and services.

The Group includes inter alia Andzani Ventures (Pty) Ltd and Imvelo Ventures (Pty) Ltd.

2. Definitions, Background and Purpose

In this document, references to "Empowerment Capital" or the "Group" are to Empowerment Capital Investment Partners (Pty) Ltd and its subsidiary companies, including divisions, segments and business units. The Group includes inter alia Andzani Ventures (Pty) Ltd and Imvelo Ventures (Pty) Ltd.

Protecting customers' personal information is important to Empowerment Capital. The Group has developed this customer privacy notice ("Notice") to enable its customers to understand how the Group collects, uses and safeguards their personal information. A "customer" is any person, whether natural or juristic, that interacts with the Group.

In this notice "Process" means how the Group collects, uses, stores, makes available, destroys, updates, discloses, or otherwise deals with customers' personal information. The Group will only process customers' personal information if this is required to deliver or offer a solution to a customer.

The Group may change this notice from time to time if required by law or its business practices. The latest version is available at: www.empowerment.capital/POPIA

3. Responsible Parties

Customers can contact the responsible parties in the Empowerment Capital Group through the applicable business. All enquiries and privacy-related requests should be directed to:

4. What is Personal Information?

Personal information refers to any information that identifies a natural or juristic person or specifically relates to a customer, including but not limited to: name and surname; marital status; national origin; date of birth; language; education; financial history; employment history; gender; identity or passport number; income tax number; company registration number; email address; physical address; telephone number; online identifiers; social media profiles; and race.

Special personal information includes: religious and philosophical beliefs; race; ethnic origin; trade union membership; political beliefs; biometric information; and criminal behaviour relating to alleged offences.

5. When Will the Group Process Personal Information?

The Group may process personal information for lawful purposes if: it is necessary to conclude or perform under a contract; the law requires or permits it; it is required to protect legitimate interests; the customer has consented; or a legally authorised person has consented on the customer's behalf.

6. When Will the Group Process Special Personal Information?

The Group may process special personal information where: it is needed to create, use or protect a right or obligation in law; it is for statistical or research purposes; the information was made public by the customer; processing is required by law; or the customer has consented.

7. When and from Where Does the Group Obtain Personal Information?

The Group collects information directly from the person concerned; through customers' use of Group solutions and service channels; through customers' engagement and interactions with the Group; from public sources; from technology and digital platforms; and from third parties the Group interacts with for the purposes of conducting its business, including credit bureaux, regulatory authorities, service providers, and joint venture partners.

8. Reasons the Group Needs to Process Personal Information

Contract: To conclude or perform under a contract, assess applications, conduct affordability assessments, open and maintain accounts, communicate with customers, respond to enquiries and complaints, and meet record-keeping obligations.

Law: To comply with legislative, regulatory, risk and compliance requirements; fulfil reporting requirements; process payment instructions; and detect, prevent and report fraud, money laundering, and other crimes.

Legitimate interest: To develop, implement and improve Group business processes; manage business continuity; protect and enforce the Group's rights; develop and test solutions; market appropriate solutions; respond to customer communications and complaints; and conduct statistical and research activities.

9–10. Further Processing and Centralised Processing

The Group will only further use personal information where the law allows it and the purposes are compatible with the original purpose. Personal information may be processed through centralised Group functions and systems, including a centralised Group data warehouse, to improve information management, integrity, information security, and to reduce management costs.

11. Marketing

The Group will use customers' personal information to market investments and other related financial solutions. If a person is not a Group customer, the Group will only market to them by electronic communications with their consent. Customers can request the Group to stop sending marketing communications at any time.

12. Credit Bureau Information

The Group may obtain customers' personal information from credit bureaux to verify identity; obtain employment details; obtain credit reports; determine credit risk; for debt recovery; to conduct research and statistical analysis; and to determine which solutions to offer to a customer.

13. Cross-Border Transfers

The Group will only transfer personal information to third parties in another country where: the information will be adequately protected; the transfer is necessary for a contract; the customer has consented; or the transfer is otherwise in the customer's interest.

14. Customers' Rights

Right to access: Customers may request confirmation that the Group holds their personal information and request a copy or description of that record.

Right to correction, deletion or destruction: Customers may request the Group to correct, delete or destroy personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, or misleading.

Right to object: Customers may object on reasonable grounds to the processing of their personal information. The Group will provide feedback regarding objections.

Right to withdraw consent: Where consent was provided, customers may withdraw it at any time by contacting the Group Information Officer.

Right to complain: Customers may file a complaint with the Group or the Information Regulator (South Africa). Contact: [email protected] | General: [email protected] | Tel: +27 (0)10 023 5200

15–16. Security and Retention

The Group will take appropriate and reasonable technical and organisational steps to protect customers' personal information, including keeping systems secure, storing records securely, controlling access to premises and systems, and safely destroying or deleting records.

The Group will keep personal information for as long as required by law, contract, consent, or lawful business purposes. TAKE NOTE: The Group may retain personal information even after a customer relationship ends if the law permits or requires it.

17. Cookies

Cookies are small pieces of data sent from a website to the user's device. By using Group websites or applications, customers agree that cookies may be forwarded to their device. The Group uses cookies to recognise returning users and to prevent fraud. Please refer to the Empowerment Capital Group cookie notice, available on all Group websites.

18. Personal Information of Persons Related to a Juristic Person

If a customer is a juristic person, the Group may collect and use personal information relating to that entity's directors, officers, employees, shareholders, members, authorised signatories, representatives, guarantors, sureties and other related persons. Customers who provide such information warrant that the related persons are aware and have consented to the sharing of their personal information.

1. Introduction

The Protection of Personal Information Act, 2013 ("POPI") gives effect to the constitutional right of privacy, regulates the manner in which personal information may be processed and provides rights and remedies to protect personal information.

This policy outlines how Empowerment Capital Investment Partners (Pty) Ltd ("the company") collects, uses, stores, processes, and shares personal information of its data subjects. The policy applies to all personal information collected or produced by the company; all employees involved in the processing of personal information; and all service providers, contractors and other third parties who have access to personal information in the company's control.

The purpose of this policy is to establish management direction and high-level objectives for regulating the manner in which personal information is processed, ensure compliance with POPI, provide unified retention and destruction procedures, and assist employees in understanding their obligations.

2. Key Definitions

Company: Empowerment Capital Investment Partners (Pty) Ltd.

Data subject: The person to whom personal information relates.

Information Officer: An employee appointed as the company's information officer.

Operator: A person who processes personal information for the company in terms of a contract or mandate, without coming under the direct authority of the company.

Personal information: Information relating to an identifiable, living, natural person (and where applicable, an identifiable juristic person), including information relating to race, gender, marital status, health, education, financial history, employment history, biometric information, personal opinions, correspondence, and name.

Processing: Any operation concerning personal information, including collection, recording, organisation, storage, updating, retrieval, consultation, use, dissemination, merging, linking, restriction, erasure or destruction.

Special personal information: Personal information relating to religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric information, or criminal behaviour.

3. Processing Conditions

The company must comply with the following eight conditions for the lawful processing of personal information as prescribed by POPI:

4. Responsibility and Accountability

The Chief Executive Officer of the company is the appointed Information Officer. The Information Officer is responsible for encouraging and supporting the company's overall compliance with POPI, drafting policies and procedures, designating individuals to monitor compliance, and undertaking training awareness sessions.

Any employee or data subject suspecting that personal information is being used for purposes other than those explicitly collected for may register a complaint with the Information Officer. If the complainant is dissatisfied with the Information Officer's findings, an appeal may be submitted to the appeal forum, whose determination will be final.

5. Purpose of Collection of Personal Information

Personal information must be collected for a specific, explicitly defined and lawful purpose related to the function or activity of the company. The data subject must be made aware of the purpose of the collection.

6. Security

The company must keep all personal information secure against the risk of loss, unauthorised access, interference, modification, destruction or disclosure, and conduct regular risk assessments. Service Level Agreements with third parties will include a data protection clause. All employment contracts must include a confidentiality and/or data protection clause.

The company will not disclose any personal information to third parties unless compelled by law or regulatory requirements, it is in the public interest, or the company needs to do so to protect its rights.

Personal information must be destroyed, deleted or de-identified as soon as reasonably practical after it is no longer needed. Destruction or deletion must be done in a manner that prevents its reconstruction in an intelligible form.

7. Consent

When collecting personal information, the company shall obtain voluntary, informed and specific consent from the data subject. Consent must be obtained before collecting personal information, and the data subject must understand how their information will be used. A data subject may withdraw consent at any time, upon which the company may no longer process their personal information.

8. Purpose Specification

Personal information may only be processed for specific, explicitly defined and legitimate reasons, of which the data subject is made aware. Personal information will only be collected to the extent required for the specific purpose. If it becomes necessary to change the purpose for which personal information is processed, the data subject will be informed before any processing occurs.

Records of personal information may only be kept for as long as necessary for achieving the purpose for which the information was collected, unless retention is required by law, contract, or consent. Personal information must thereafter be destroyed, deleted or de-identified in a manner that prevents reconstruction.

9. Limiting Collection and Further Processing

The company is an authorised financial services provider in terms of FAIS and an accountable institution in terms of FICA. Personal information must be collected directly from a data subject, except where the information is in a public record, the data subject has consented to collection from another source, or collection from another source would not prejudice a legitimate interest of the data subject.

Further processing must be compatible with the purpose for which it was collected, unless the data subject gives consent. The company may use personal information to make automated decisions as allowed by law, and data subjects have the right to query any such decisions.

10. Accuracy

The company must take reasonably practical steps to ensure that personal information is complete, accurate, not misleading and updated where necessary. Inaccurate or out-of-date information will be destroyed. The Information Officer must develop processes for checking accuracy, dealing with complaints about timeliness, and enabling data subjects to periodically verify and update their information.

11. Openness

Prior to or at the time of collecting personal information, the company must take reasonably practicable steps to ensure that data subjects are aware of: the information being collected and its source; the name and address of the company; the purpose for which information is being collected; whether supply is voluntary or mandatory; consequences of failure to provide the information; the right of access and rectification; any intended cross-border transfers; the right to object to processing; and the right to lodge a complaint with the Information Regulator.

12. Data Subject Access

Data subjects have the right to have the company confirm whether it holds personal information about them and to request access to such information. The Information Officer shall ensure that the company responds to requests within a reasonable time and at minimum or no cost to the data subject.

Data subjects may request the company to: provide access to personal information held; prevent processing for direct marketing purposes; amend inaccurate or incomplete information; destroy or delete information the company is no longer authorised to retain; and object to decisions made solely by automated processes.

13. Sharing of Personal Information

Employees dealing with third-party enquiries must check the identity and legal entitlement of the enquiring party, suggest that requests be made in writing, and refer to the Information Officer in difficult situations. Current employees are required to sign consent clauses for the use and storage of employee information in terms of POPI.

14. Fair and Lawful Processing

For personal information to be processed lawfully, the company must either obtain the data subject's consent, or the processing must be necessary for the legitimate interest of the company or the party to whom the information is disclosed. When special personal information is processed, explicit consent is required. Personal information about employees may be processed for legal, personnel, administrative and management purposes as required by law.

15. Electronic and Direct Marketing

Unless a data subject has given consent or is an existing client, the processing of personal information for direct marketing by means of unsolicited electronic communications is prohibited. The company may only approach a data subject once to opt in to receive marketing information. All direct marketing communications must contain an unsubscribe option and the identity of the sender.

No direct marketing communication may be sent on Sundays or public holidays; on Saturdays before 09h00 or after 13h00; or on other days between 20h00 and 08h00.

16. Transfer of Personal Information

The company will not transfer personal information to a third party in another country unless: the recipient is subject to laws that uphold principles substantially similar to POPI; the data subject consents; the transfer is necessary for performance of a contract; the transfer is for the benefit of the data subject; or it is not reasonably practicable to obtain consent and the data subject would likely have given it.

17. Breach of Policies

A breach of this policy or any related policy — including the POPI Compliance Framework, Information Security Management Policy, Data Breach Notification Policy, Records Management Policy and the POPI Manual — will result in disciplinary proceedings which may lead to dismissal.

This manual is published in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"). PAIA gives effect to the constitutional right of access to information held by private bodies where that information is required for the exercise or protection of any right. This manual describes the records held by Empowerment Capital Investment Partners (Pty) Ltd, the procedure to request access, and the grounds on which access may be refused.

1. Details of the Private Body

2. Information Officer

The Information Officer is the person responsible for ensuring compliance with PAIA and for handling requests for access to information on behalf of Empowerment Capital. All PAIA requests must be addressed to the Information Officer.

3. Guide on How to Use the Act

The South African Human Rights Commission ("SAHRC") has compiled a guide on how to use PAIA, as required by Section 10 of the Act. This guide contains information to assist persons wishing to exercise their rights under PAIA.

4. Records Available Without Formal Request

The following records and information are made available by Empowerment Capital without the need to submit a formal PAIA request:

5. Description of Records Held

Empowerment Capital holds the following categories of records, subject to applicable grounds for refusal:

6. Request Procedure

Any person wishing to request access to a record held by Empowerment Capital must follow the procedure set out below.

7. Grounds for Refusal of Access

In terms of PAIA, Empowerment Capital may refuse access to records on the following grounds:

8. Remedies Available to Requesters

If a request for access is refused or if the Information Officer fails to respond within the prescribed period, the following remedies are available to the requester:

Internal appeal: The requester may lodge an internal appeal with the Information Officer within 60 days of the refusal decision.

Application to court: The requester may apply to the High Court for relief in terms of Section 78 of PAIA if they are aggrieved by a decision of the Information Officer.

Information Regulator: A complaint may be lodged with the Information Regulator regarding the processing of personal information or a refusal of access. Contact: [email protected] | Tel: +27 (0)10 023 5200.

9. Applicable Legislation

Empowerment Capital holds records required or regulated under the following legislation, among others:

1. Status of Financial Services Provider

Empowerment Capital Investment Partners (Pty) Ltd is an authorised Financial Services Provider, Company Registration number 2015/117874/07, FAIS Licence number 46333.

Anton Baumann and Mark Fitzjohn are key individuals of Empowerment Capital Investment Partners (Pty) Ltd, and as such participate in the decision making and management of the organisation.

4. FSP Office Contact Particulars

7. Qualifications and Memberships

8. Independence and Professional Indemnity Insurance

Empowerment Capital Investment Partners (Pty) Ltd does not have any agreements with product providers, or any financial interest in any product suppliers, except for related party companies that offer financial products to companies. Any such relationships are disclosed to clients where applicable. Empowerment Capital Investment Partners (Pty) Ltd does not have other representatives which render financial services on its behalf and accepts responsibility for the actions of the abovementioned key individuals acting within the mandates listed below.

Empowerment Capital Investment Partners (Pty) Ltd has professional indemnity insurance in place and has implemented a conflict of interest management policy as required by FAIS and the General Code of Conduct. A copy of the said policies is available to clients at our offices. Empowerment Capital Investment Partners generates remuneration from management fees earned from clients and may co-invest in shares and other security instruments using internally generated sources of investment funds, with all necessary disclosures made as required by relevant legislation.

9. Authorisation

Empowerment Capital Investment Partners (Pty) Ltd is authorised to render intermediary services on the following products:

10. Complaints Procedures

If you have a complaint, please contact Empowerment Capital Investment Partners (Pty) Ltd. The complaints officer (Mark Fitzjohn) will assist you to address the concerns you have. Please note that in terms of the FAIS Act, all complaints must be addressed to us in writing and may be handed in at our office. Should we not be able to address the concerns to your satisfaction, you may wish to lodge a complaint with the FAIS Ombudsman. If you wish to learn more about our complaints policy and procedure, please click here or contact us via telephone or email.