Your privacy matters to us. This policy explains how we collect, use, and protect your personal information.
1.1. Protecting your privacy and keeping your personal information confidential is very important to us. This Privacy Policy ("Policy") sets out how we collect and manage your personal and sensitive information.
1.2. In this Policy, we use the terms "we" "us" "our" or "Cumbrae Investments" to refer to Cumbrae Investments (Pty) Ltd and its related companies.
1.3. Personal information is any information or opinion about you that is capable (or reasonably capable) of identifying you, whether the information or opinion is true or not, and regardless of whether the information is recorded in a material form.
1.4. Sensitive information includes things like your racial or ethnic origin, political opinions or membership of political associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or criminal record. Your health, genetic and biometric information and biometric templates are also sensitive information. Sensitive information is also personal information for the purposes of the Privacy Act.
1.5. We collect personal and/or sensitive information to provide you with the products and services that you ask for, as well as information about products and services offered by us or third parties.
1.6. We may use your personal and/or sensitive information to administer our products and services, for prudential and risk management purposes and, unless you tell us otherwise, to provide you with related marketing information. We also use the information we hold to help detect and prevent illegal activity. We cooperate with police and other enforcement bodies as required by law.
1.7. We disclose relevant personal information to external organizations that help us provide services. These organizations are bound by confidentiality arrangements. They may include overseas organizations.
2.1. We only collect personal information when it's reasonably necessary for us to do business with you.
2.2. We use your personal information to:
3.1. The personal information we collect about you generally includes the following:
3.2. We're required by law to identify you if you're opening a new account or adding a new signatory to an existing account. The AML/CTF Act requires us to sight and record details of certain documents (i.e. photographic and non-photographic documents).
3.3. Where necessary, we also collect information on the following individuals:
3.4. We may take steps to verify the information we collect. For example, a birth certificate provided as identification may be verified with records held by the Registry of Births, Deaths and Marriages to protect against impersonation, or we may verify with an employer that employment and remuneration information provided in a credit application is accurate.
4.1. We may either collect personal information about you directly from you or from sources other than you when permitted under the AML/CTF Act. "Sources other than you" may include your agents, family members, friends, related entities, affiliates or divisions.
4.2. We may also collect information from you electronically, for instance, when you visit our website.
5.1. If you provide us with incomplete or inaccurate information, we may not be able to provide you with the products or services that you ask for.
6.1. In most cases, we'll obtain your consent to use and disclose your personal information for our intended purposes either before or at the time that we collect it.
6.2. If you don't give us your consent or withdraw your consent, we may not be able to provide you with the products or services you ask for.
7.1. You can withdraw your consent at any time. To withdraw your consent, please email [email protected] in the first instance.
8.1. We'll only collect sensitive information about you if we have your consent, or if we're required or authorized by law.
9.1. We ensure that the personal information we collect and handle is accurate, up to date, complete and relevant.
9.2. Please contact us if any of the details you have provided to us change or if you believe that the information we have about you is not accurate or up to date.
9.3. We may also take steps to update the personal information we hold, for example, an address, by collecting personal information from publicly available sources such as telephone directories or electoral rolls.
10.1. We're committed to protecting the personal information we hold about you from misuse, unauthorized access and disclosure.
10.2. We've implemented a range of practices and policies to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.
10.3. Our security measures include:
10.4. Where we identify that we no longer need certain personal information, we ensure that it's effectively and securely destroyed. For example, we may shred paper records or use other means such as degaussing (de-magnetism of a device) and deletion in the case of electronic equipment and records.
11.1. We may share your information with our related entities and third parties that we outsource functions to or partner with, in certain limited situations where it's necessary for us to provide our products and services or perform associated business activities.
11.2. These entities and third parties include:
12.1. We'll also disclose your personal information if we're required by law or permitted to do so under the Privacy Act.
13.1. Unless you've asked us not to, we may use your personal information to let you know about new or improved products and services and special offers that may be of interest to you.
13.2. If you don't want us to use your personal information for marketing purposes, please:
19.1. If you have any questions or would like further information about our privacy and information handling practices, please contact us using one of the following channels:
Last updated: October 27, 2025