Our Legal Documents & Policies

This Privacy Notice explains how we obtain, use and disclose your personal information and aims to inform you of your rights and how to exercise them.

This Privacy Notice sets out:

• Who we are

• What personal information we collect and where we collect it from

• The purposes for which we use your personal information

• To whom we disclose your personal information

• How we safeguard your personal information

• Your rights to access, correct and delete your personal information

• How to contact us

• The Information Regulator’s contact details

Who are we

In this Privacy Notice, “Futuregrowth” or “we” refers to Futuregrowth Asset Management Proprietary Limited.

The Information We collect

We collect and process your personal information mainly to provide the investment management services as contemplated in our agreements with you (and any services ancillary thereto, including part of our onboarding processes), to grant you access to our services and financial products, to help us improve our offerings to you and for certain other purposes explained below. In order for us to do this, it is incumbent upon you to provide us with the personal information we request, failing which we cannot enter into a relationship with you, assist you, or fully comply with our contractual obligations to you.

When you provide us with information about third parties (for example your clients, service providers or parties related to you), we will process their personal information in order to give effect to our agreement and in order to pursue your and our legitimate interests. We will furthermore process personal information for the purposes set out in this Privacy Notice. You warrant that, when you give us personal information about third parties, this information is accurate and correct and you have received their permission for the purposes set out in this Privacy Notice of any other related purposes.

The type of information we collect will depend on the purpose for which it is collected and used, set out herein. We will only collect information that we need for that purpose.

We collect information directly from you where you provide us with your personal information, for example when you apply for a product or services from us or when you submit enquiries to us or contact us.

We also collect information about you and/or your related parties from other parties, such as third parties, for example anti-money laundering.

We have a duty to take all reasonably practicable steps to ensure that your personal information is complete, accurate, not misleading and that it is updated on a regular basis. To enable this, we will always try to obtain personal information from your directly and we will appreciate it if you would similarly ensure that your personal information processed by us, is up to date and accurate. You can do this by engaging with any of the Futuregrowth contacts on our website. Where we are unable to obtain personal information from you directly, we will make use of verifiable independent third party data sources.

Website usage information is collected by using cookies. For more information on how we deal with cookies you can view our Privacy Policy on the Futuregrowth website.

Purpose For Which We Use Your Information

We will only use your information for the following purposes:

To conclude a legal agreement with you and to perform the obligations required in terms of such agreement which includes, investment management services such as managing your portfolio, reporting to you and to keep you apprised on developments pertaining to your portfolio(s)

To pursue our legitimate interests, which include:

• Compiling relevant reports;

• Complying with requests from any internal or external auditor, or any regulatory or supervisory body;

• Compliance with any regulatory requirements and/or industry codes applicable to the financial services industry;

• Corresponding with you;

• Confirming and verifying our identity, address and banking details and maintaining the accuracy thereof;

• Conducting the requisite client identification and verification process as required in terms of the Financial Intelligence Centre Act;

• To conduct sanction screening against all mandatory and non-mandatory sanctions lists;

• Detecting and preventing fraud, crime and money-laundering (or other malpractice);

• Offering financial products and services to you;

• Maintaining our business relationship with you;

• Conducting market and/or client satisfaction research for statistical analysis;

• Protecting your and/or our interests in legal proceedings;

• Processing your marketing preferences (and where you have unsubscribed from certain direct marketing communications, keeping a record of your information and request to ensure that we do not send such direct marketing to you again); and

• Resolving any complaint

Disclose of Infarmation

We may disclose your information to our service providers where it is necessary to give effect to our obligations in terms of our legal agreements with you.

Information Security

We are legally obliged to provide adequate protection for your personal information we hold and to stop the unauthorized access and use thereof. We will, on an ongoing basis, continue to review our security controls and related processes to ensure that your personal information is secure.

Our security procedures and policies cover:

• Physical security;

• Computer and network security;

• Access to persona information;

• Secure communications;

• Retention and disposal of personal information;

• Acceptable usage of personal information;

• Governance and regulatory aspects;

• Monitoring access and usage of personal information; and

• Investigating and reacting to security incidents.

When we contract with third parties, we will take steps to ensure that there are appropriate security, privacy and confidentiality obligations on third parties to ensure that personal information that we remain responsible for, is kept secure.

Changes to This Privacy Notice

Please note that we may amend this Privacy Notice from time to time. Please check this website periodically to inform yourself of any changes.

How to Contact Us

If you have any questions about this Privacy Notice or believe that we have not adhered to it, or need further information about our privacy practices, please contact our Compliance Officer directly at Rkieser@futuregrowth.co.za.

Information Regulator

You have the right to lodge a complaint directly with the Information Regulator, at the following contact details:

Website: https://www.justice.gov.za/inforeg/index.html

General enquiries: inforeg@justice.gov.za

Complaints: complaints.IR@justice.gov.za

Terms and Conditions

General disclaimer

This website is owned and managed by Futuregrowth Asset Management (Proprietary) Limited (Registration No. 1996/18222/07) (“Futuregrowth”).

This website is only intended to provide general information regarding Futuregrowth and its products and services. The information provided is objective information and is not intended to constitute a recommendation, guidance or proposal in regard to the suitability of any product in respect of your financial needs. Neither the website, nor any information contained on the website constitutes or forms part of a representation, a contract or a term of any contract. The information on this website may be updated or altered by Futuregrowth at any point in time.

While Futuregrowth has taken reasonable care to ensure that the content of this website is accurate, it does not provide any warranty, express or implied, regarding the accuracy or completeness of the information contained on the website.

Liability and indemnity

1. The content of this website is provided without any express or implied warranty of any kind.

2. Futuregrowth does not warrant that the content of this website is appropriate or suitable for any particular purpose or that it is complete or accurate.

3. Futuregrowth does not warrant that the functions of this website will be uninterrupted or error free, or that the website or the server that makes the website available is free from viruses or other harmful components.

4. Futuregrowth and its directors and employees shall not be responsible for and disclaim all liability for any loss, damage (whether direct, indirect or consequential, including but not limited to loss of profits and loss of business) and/or expenses of any nature at all, which may be suffered because of or which may be attributable, directly or indirectly, to the use of, or reliance upon any information, links or service provided through this website.

Intellectual property

The information and branding (including logos, graphics and any multimedia), whether licensed or unlicensed, belongs to Futuregrowth and may not be changed, reproduced or transmitted without the written consent of Futuregrowth, except where you use, print or reproduce the information for your own non-commercial personal use.

Privacy

Futuregrowth Asset Management (Pty) Ltd (Futuregrowth) may electronically collect, store and use certain personal information about you, which may include use of third party data related service providers, such as cloud storage service providers. Cloud storage is a service through which data is maintained, managed, backed up remotely and made available to those authorised to access such data, over a network. Futuregrowth and its directors, officers and employees respect your privacy and the confidentiality of your personal information.

We will only collect, disclose, collate, process and store your personal information that you supply to us via this website:

1. To identify you; and/or

2. For the specific and explicitly defined purpose for which we request the information from you, as stated on the relevant web pages; and/or

3. To the extent necessary to enable us to meet our obligations to you (insofar as it relates to the purpose for which we have collected your personal information); and/or

4. To comply with any legal obligation imposed on us.

We will not disclose your personal information to third parties, other than third party data related service providers, and/or process it further, unless you have expressly consented to such disclosure and/or further processing.

We may further process your personal information if it is in accordance or compatible with the purpose for which the personal information was originally collected. Further processing of your personal information shall be in accordance or compatible with the purpose for which it was collected if:

1. the information is available in or derived from a public record;

2. it is necessary to avoid prejudice to the maintenance of the law, including the prevention, detection, investigation, prosecution and punishment of offences;

3. it is necessary to comply with an obligation imposed by law;

4. for the conduct of proceedings in any court or tribunal that have commenced or are reasonably contemplated;

5. it is in the interest of national security;

6. further processing is necessary to prevent or mitigate a serious or imminent threat to public health or public safety; and/or

7. it is in the public interest to do so (to the extent granted by the Information Regulator under the Protection of Personal Information Act 4 of 2013.

To the extent that you provide us with your personal information, we will-

1. treat your personal information as strictly confidential;

2. take appropriate technical and organisational measures to ensure that your personal information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access;

3. provide you with access to your personal information to view and/or update personal details or to correct any errors;

4. promptly notify you if we become aware of any unauthorised use, disclosure or processing of your personal information;

5. provide you with reasonable evidence of our compliance with our obligations under this privacy policy on reasonable notice and request; and

6. upon your request, promptly return or destroy any and all of your personal information in our possession or control.

FAIS Disclaimer

Futuregrowth Asset Management (Pty) Ltd (“Futuregrowth”) is a licensed discretionary financial services provider, FSP 520, approved by the Registrar of the Financial Sector Conduct Authority to provide intermediary services and advice in terms of the Financial Advisory and Intermediary Services Act 37 of 2002.

The fund values may be market linked or policy based. Market fluctuations and changes in exchange rates may have an impact on fund values, prices and income and these are therefore not guaranteed. Past performance is not necessarily a guide to future performance. Futuregrowth has comprehensive crime and professional indemnity in place. Performance figures are sourced from Futuregrowth and IRESS.

Personal trading by staff is restricted to ensure that there is no conflict of interest. All employees of Futuregrowth are remunerated with salaries and standard short and long-term incentives. No commission or incentives are paid by Futuregrowth to any persons. All inter-group transactions are done on an arm’s length basis.

Conflict of Interest Management Policy

The Financial Advisory and Intermediary Services Act 37 of 2002 requires every financial services provider to adopt, implement and maintain a conflicts of interest management policy. For more detailed information, please download a copy of our policy.

Complaints Procedure

We will reply to any complaints that we receive. Kindly email your complaint directly to info@futuregrowth.co.za or contact our Head of Compliance, Ryan Kieser, on 021 659 5447. Please note that should you be dissatisfied with our response, you may contact the Ombud for financial services at:

FAIS Ombud

Name: Ms N Bam

Postal Address: PO Box 74571, Lynwood Ridge, 0400

Telephone: +27 12 470 9080

Facsimile: +27 12 348 3447

Email: info@faisombud.co.za

For more detailed information, please download a copy of our complaints resolution policy.

Privacy and Cookie Policy

If you agree to allow Futuregrowth to store cookies on your device, it is used to enhance site performance and assist us in our marketing efforts. A cookie is a piece of information that is stored on your computer’s hard drive by your web browser for record-keeping purposes. When you visit our site, we automatically collect certain information about your device, including information about your web browser and geolocation.

Additionally, as you browse the site, we collect information about the individual web pages on our website or our products that you view, what websites or search terms referred you to the site, and information about how you interact with the site. This is termed, ‘device information’.

If you subscribe to receive our communication emails, we allocate cookies to your subscription. These cookies will hold information collected during your subscription and will allow us to recognise you as a subscriber. If your browser is set to reject cookies, we will not be able to track you, and will not be able to capture the data to better understand your interests while online and to improve your visits to the website.

Most browsers are set by default to accept cookies automatically, these settings can be changed to prevent automatic acceptance and will prompt you each time a cookie is sent to you or to accept or decline being tracked a cookie. Turning off cookies will not prohibit you from using the Website, it may however limit your use of the Website.

How do we use your personal information?

• If you subscribe to our mailing list, we communicate with you via email.

• We use the device information that we collect to help us to improve and optimise our site (for example, by generating analytics about how our clients/users browse and interact with the site, and to assess the success of our marketing and advertising campaigns).

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy

For more information about Google Analytics’ currently available opt-outs, visit the following website: tools.google.com/dlpage/gaoptout/

Switch off Google Analytics by clicking the button below:

Email Confidentiality and Disclaimer Notice

Futuregrowth Asset Management (Proprietary) Limited is a licensed financial services provider under the Financial Advisory and Intermediary Services Act No. 37 of 2002. Futuregrowth does not accept responsibility for any information contained in or attached to this e-mail unless issued under the signature of an FSCA-approved representative or key individual (as defined in the Act) and strictly related to the business of Futuregrowth. This e-mail contains proprietary and confidential information some or all of which may be legally privileged. It is for the intended recipient only. If an addressing or transmission error has misdirected this e-mail, please notify the author by replying to this e-mail and then deleting same. If you are not the intended recipient you must not use, disclose, distribute, copy, print or rely on this e-mail. Futuregrowth is not liable for any variation effected to this e-mail or any attachment thereto unless that variation has been approved in writing by an FSCA approved representative or key individual. Futuregrowth is not liable for the security of information sent by e-mail and accepts no liability of whatsoever nature for any loss, damage or expense resulting, directly or indirectly, from the access of this e-mail or any attachments hereto.

Promotion of Access to Information

Should you require specific information pertinent to the Company in terms of the Promotion of Access to Information Act 2 of 2000 you will have to prove that the information requested is required in order to exercise or protect your fundamental human rights as set out in the Constitution of 1996. The costs of such request and of the supply of such information shall be borne by the requester. Any request for information must -

(a) identify the record(s) requested;

(b) identify the requester;

(c) specify a postal address or fax number of the requester within the Republic of South Africa;

(d) identify the right the requester is seeking to exercise or protect and provide an explanation of why the information requested is required for exercise or protection of such right;

(e) state the manner in which the requester wishes to be informed of the decision on the request, if other than or in addition to a written reply;

(f) indicate which form of access is required;

(g) submit proof of the capacity in which the requester is making the request to the reasonable satisfaction of the head of FUTUREGROWTH ASSET MANAGEMENT if the request is being made on behalf of a person.

The requester shall be obliged to pay the prescribed request fee before FUTUREGROWTH ASSET MANAGEMENT processes a request.

It should be noted that Section 36 of the Constitution limits personal rights to the extent that it is reasonable and justifiable taking into consideration:

(a) the nature of the right;

(b) the importance of the purpose of the limitation;

(c) the nature and extent of the limitation;

(d) the relation between the limitation and its purpose; and

(e) less restrictive means to achieve the purpose

and the balancing of competing interests of third parties and the company as a juristic entity.

Old Mutual Unit Trust Managers Disclaimer

The below disclaimer refers to the Old Mutual Institutional Short Term Interest Fund specifically.

We aim to treat our clients fairly by giving you the information you need in as simple a way as possible to enable you to make informed decisions about your investments.

We believe in the value of sound advice and so recommend that you consult a financial adviser before buying or selling unit trusts. You may however, buy and sell without the help of a financial adviser. If you do use a financial adviser, we remind you that they are entitled to certain negotiable adviser fees or commissions.

The fees and costs that we charge for managing your investment are accessible on the relevant fund’s minimum disclosure document (MDD) or table of fees and charges both available on our public website or from our service centre.

You should ideally see unit trusts as a medium to long term investment. The fluctuations of particular investment strategies affect how a fund performs. Your fund value may go up or down. Therefore, we cannot guarantee the investment capital or return of your investment. How a fund has performed in the past does not necessarily indicate how it will perform in the future.

Our cut-off time for client instructions (e.g. buying and selling) is at 13:00 each working day. We value the fund at 15:00 to determine the daily ruling price. Daily prices are available on the public website and in the media.

Funds may borrow to pay client disinvestments and may engage in scrip lending.

The daily ruling price is based on the current market value of the fund’s assets plus income minus expenses (NAV of the portfolio) divided by the number of units in issue. Old Mutual Unit Trusts has the right to close a portfolio to new investors in order to manage it more efficiently in accordance with its mandate.

Old Mutual Unit Trust Managers (RF) (Pty) Ltd is a registered manager in terms of the Collective Investment Scheme Control Act 45 of 2002. Old Mutual is a member of the Association for Savings and Investment South Africa (ASISA).

Old Mutual Unit Trust Managers (RF) (Pty) Ltd has the right to close the portfolio to new investors in order to manage it more efficiently in accordance with its mandate.

Income Funds:

Income funds derive their income primarily from interest-bearing instruments as defined. The published yield is a current yield and is calculated daily. The value of underlying assets of Income funds are marked to market on a daily basis.

The portfolio performance is calculated on a NAV-NAV basis and does not take any initial fees into account. Income is reinvested on the ex-dividend date. Actual investment performance will differ based on the initial fees applicable, the actual investment date and the date of reinvestment of income.