FSP name: Asset Protection International (SA) Pty Ltd (FSP768) (hereinafter referred to as the FSP

• Introduction

1. 1. 1. The FSP is an authorised financial service provider (FSP768) which is obliged to comply with The Protection of Personal information Act (‘POPI’).
      2. POPI requires the FSP to inform their clients as to how their Personal information is used, disclosed and
         destroyed.
      3. The FSP is committed to protecting the privacy of their clients and ensuring their personal information
         is used appropriately, transparently, securely and in accordance with applicable laws.
      4. This Policy sets out how the FSP deals with the personal information of their clients and the purpose
         for which the information is used for.

• THE PERSONAL INFORMATION COLLECTED

1. 1. 1. Section 9 of POPI states that “Personal information may only be processed if given the purpose for
         which it is processed it is adequate, relevant and not excessive.”
      2. The FSP collects and processes the personal information of clients as it pertains their financial planning
         needs as described further in point 3 below. The type of information will depend on the need for which it is
         collected, and it will be processed for that purpose only. Whenever possible, we will inform the client what
         information they are required to provide us with and what information is optional.

Examples of the personal information we collect include but is not limited to:

1. 1. 1. 1. Client’s identity number, name, surname, address, postal code, marital status and dependents, bank
            account details, tax number, etc.
         2. Description of client’s personal and business assets, financial circumstances, wills, life policies and
            medical aid policies; and
         3. Any other information required by us, our suppliers and insurers in order to provide clients with an
            accurate analysis of their financial needs.
      2. The FSP collects and processes the personal information of clients and potential clients to ensure our
         products and services remain applicable.
      3. We have agreements in place with our product suppliers, insurers and third party service providers to
         ensure that there is a mutual understanding with regard to the protection of client personal information.

Our suppliers are subject to the same POPI regulations as we are.

1. 1. 1. With the consent of clients, we may also supplement the information provided with information we
         receive from other providers in order to offer a more consistent and personalized experience in our
         interactions with them.
      2. For purposes of this policy, “clients” includes potential and existing clients.

• HOW PERSONAL INFORMATION IS USED

1. 1. 1. The personal information of clients will only be used for the purpose for which it was collected and
         agreed. This may include:

Providing financial planning advice and related services to clients including the provision of related
products and services and the associated transactions;
For confirming, verifying and updating details of clients in the records of the FSP as well as to confirm and
update details of clients in the records of product providers and third party service providers. Product
providers and third party service providers may where necessary share the personal information with other
third parties as required to deliver their services;
For providing ongoing financial advice, investment reviews, market commentaries and client servicing
communications;
For the detection and prevention of fraud, crime, money laundering or other malpractices;
For conducting market or customer satisfaction research;
For audit and record keeping purposes, or in connection with regulatory and legal proceedings;
For providing our services to clients and to carry out the services as requested, and to maintain and
improve client relationships;
For providing general communications in respect of the FSP including regulatory matters that may affect
clients and in connection with, or to comply with legal and regulatory requirements.

1. 1. 1. According to section 10 of POPI personal information may only be processed if certain conditions are
         met, including:
         1. Client consents to the processing – consent is typically obtained from clients during the introductory,
            appointment and needs analysis stage of our relationship;
         2. The processing is necessary – in order to conduct an analysis of client’s financial needs and in order to
            provide financial planning advice and related investment products and services, certain personal
            information is required;
         3. Processing complies with an obligation imposed by law on the FSP. The applicable regulation requires
            the Financial Service Provider to conduct a needs analysis in order to obtain relevant information from
            clients about their financial needs and circumstances in order to provide them with appropriate advice.
         4. Processing protects a legitimate interest of the client – it is in the client’s best interest to have a full
            and proper analysis performed in order to provide them with appropriate advice, and this necessitates
            obtaining comprehensive personal information.
         5. Processing is necessary for pursuing the legitimate interests of the FSP or of a third party to whom
            information is supplied. In order to provide clients with products and services, both the FSP and our
            product suppliers require certain personal information to ensure the financial product is appropriate for
            the client and to comply with regulatory requirements.

• DISCLOSURE OF PERSONAL INFORMATION

1. 1. 1. We may disclose the personal information of clients to product providers whose services or products
         clients elect to use. The product providers in turn are subject to confidentiality and privacy regulation.
      2. We may disclose personal information of clients to third party service providers that provide
         administrative and/or technology support services or any other relevant support services to the FSP. This
         might include the distribution of client communications, the analysis of client data for the purposes of
         financial planning, the provision of client statements and portfolio reviews, or other any support services
         that the FSP requires for its efficient functioning or to support the provision of its services to clients.
      3. We may also disclose client information where we have a duty or a right to disclose in terms of
         applicable legislation or where it may be necessary to protect our rights.

• SAFEGUARDING CLIENT INFORMATION

1. 1. 1. It is a requirement of POPI that we adequately protect the personal information and to avoid
         unauthorised access and use thereof. We will continuously review our security controls and processes to
         ensure that personal information is secure.
      2. The following procedures are in place in order to protect the personal information of clients. This list is
         not exhaustive:
         1. The FSP’s INFORMATION OFFICER is Peter Morgans whose details are available below and who is
            responsible for the compliance with the conditions of the lawful processing of personal information and
            other provisions of POPI.
         2. This policy has been put in place and training on this policy and the POPI Act takes place annually;
         3. Relevant disclosure documents containing clauses pertaining to POPI have been drafted;
         4. Our archived client information is stored at either an offsite third party provider or safely in our own
            offices;
         5. All electronic files are backed up by an authorised IT provider who is also responsible for system
            security which protects third party access and physical threats.
         6. A security incident management register is kept to log any security incidents and to report on and
            manage such incidents;
         7. Consent to process client information is typically obtained from clients (or from a person who has
            been authorised to act on behalf of a client or a person authorised by the client to provide the client’s
            Personal Information) during the introductory, appointment and needs analysis stage of the relationship.
         8. We personally deliver to and instruct a professional shredding company to ensure proper destruction
            of personal information that is in printed format, or alternatively we shred such documents ourselves in our
            offices.

• ACCESS AND CORRECTION OF PERSONAL INFORMATION

1. 1. 1. Clients have the right to access the personal information we hold on them. Clients also have the right
         to ask us to update, correct or delete their personal information on reasonable grounds. Subject to our
         obligations to comply with statutory requirements to maintain records for prescribed periods, once a client
         objects to the processing of their personal information, the FSP may no longer process it.
      2. The details of our Information Officer are as follows:
         Information officer details: PETER MORGANS
         Email: client.service.dbn@apiwealth.co.za
         Telephone number: +27-31-2669959

• AMENDMENTS TO THIS POLICY

Amendments to this Policy will take place on an ad hoc basis. It will be reviewed at least once a year.
Where material changes take place clients will be notified directly.