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CLOUD SECURITY POLICY

  1. Overview

  2. S-BRO FUND MANAGERS (PTY) LTD, registration number (FSCA category 2: Nr: 41855) (Reg no: 1999/018626/07), (hereafter referred to as “S-BRO FUND MANAGERS (PTY) LTD”) is hosted and delivered by (https://www.xneelo.co.za) (hereafter referred to as “Cloud Provider”). While the Cloud Provider is responsible for the security of its actual data centres and hosting platforms, S-BRO FUND MANAGERS (PTY) LTD is responsible for managing, maintaining, and securing the website/s content, and registered user information (Client Information, Personal Information and Personally Identifiable Information).

  3. A core focus of our Cloud Security Strategy aligns with our organisational Information Security Management System (ISMS) and focuses on the following key control areas. • Confidentiality – Data is only accessed by those with the right to view the data. • Integrity – Data can be relied upon to be accurate and processed correctly. • Availability – Data can be accessed when needed.

  4. Facilities and Architecture

  5. The S-BRO FUND MANAGERS (PTY) LTD Corporate Website and S-BRO FUND MANAGERS (PTY) LTD Online Store are designed for redundancy and the expectation that failures will happen. Our websites and applications are stored in secure environments, completely managed by a first-class cloud vendor DiaMatrix Pty Ltd.

  6. The Cloud Provider is responsible for the data centres that host the S-BRO FUND MANAGERS (PTY) LTD Corporate Website and S-BRO FUND MANAGERS (PTY) LTD Online Store. For more information about security at those data centres, please go to the appropriate links below:

  7. S-BRO FUND MANAGERS (PTY) LTD Corporate Website and S-BRO FUND MANAGERS (PTY) LTD Online Store are currently hosted in South Africa (https://www.xneelo.co.za/contact).

  8. Certification

  9. The Cloud Provider is responsible for managing the security of the cloud. They have been certified by third-party organisations and are compliant with the applicable laws and regulations. The list of such certifications and compliance statements can be found in the links below: https://www.xneelo.co.za/accreditations

  10. S-BRO FUND MANAGERS (PTY) LTD Corporate Website and S-BRO FUND MANAGERS (PTY) LTD Online Store are subject to strict information security assessments, conducted by independent third parties, to ensure compliance with security standards such as the Open Web Application Security Project (OWASP) Application Security Verification Standard (ASVS) before public release.

  11. Data Storage

  12. Access to data at rest is cryptographically secured using industry-standard encryption. Additionally, all communications with the S-BRO FUND MANAGERS (PTY) LTD Corporate Website and S-BRO FUND MANAGERS (PTY) LTD Online Store are protected with HTTPS using TLS.

  13. Data Backups

  14. Customer data is backed up daily and stored in an encrypted state.

  15. Data Retention

  16. Customer information and data (S-BRO FUND MANAGERS (PTY) LTD Online Store) is retained indefinitely while you are our customer. In the event that you opt to deregister as a user/customer from the S-BRO FUND MANAGERS (PTY) LTD Online Store, one month later your data is moved into a secure storage archive and removed from the production database. As a part of our effort of not storing unnecessary data too long, the data is then removed from the archive when one year has passed from you deregistering as a user/customer from the S-BRO FUND MANAGERS (PTY) LTD Online Store.

  17. People and Access

  18. Within S-BRO FUND MANAGERS (PTY) LTD, only a few trusted members of our web development team have access to the production environment for the purposes of maintaining our cloud services and assisting our customers. Additionally, we monitor all access to the S-BRO FUND MANAGERS (PTY) LTD Corporate Website and S-BRO FUND MANAGERS (PTY) LTD Online Store.

  19. Customers are responsible for maintaining the security of their own login information.

  20. Information Security Incident Management

  21. Every care is taken by S-BRO FUND MANAGERS (PTY) LTD to protect personal data from incidents (either accidentally or deliberately) to avoid a data protection breach that could compromise security.

  22. 8.1 Definition An incident in the context of this Cloud Security Statement is an event or action which may compromise the confidentiality, integrity or availability of systems or data, either accidentally or deliberately, and has caused or has the potential to cause damage to the company’s information, assets and/or reputation.

  23. An incident includes but is not restricted to, the following: • Loss or theft of confidential or sensitive data or equipment on which such data is stored. • Attempts (failed or successful) to gain unauthorised access to information or system(s) • Unauthorised disclosure of sensitive/confidential data • Human error

  24. 8.2 Overview of Information Security Response Plan The S-BRO FUND MANAGERS (PTY) LTD information security incident response plan consists of the following: • Confirm the Incident. • Contain the Incident. • Assess Risks and Impact. • Report the Incident. • Resolve the Incident and provide a post-mortem report.

  25. Privacy

  26. In line with the Protection of Personal Information Act 4 of 2013, S-BRO FUND MANAGERS (PTY) LTD understands the importance and is committed to ensure the privacy of your personally identifiable information. For more information, please see our Privacy Policy.

  27. Reporting Issues

  28. At S-BRO FUND MANAGERS (PTY) LTD we take any reports of vulnerabilities seriously. If you encounter a security issue with any of our online services, please report it to reception@s-bro.co.za. We have an internal SLA for responding to such issues and are committed to addressing security issues promptly.

  29. Please note that it is against our Information Security Policy to run automated security scanning tools against our system without prior approval.

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  32. HEAD OFFICE: Paul Laesecke Laan 14, Panorama, Bethlehem, 9701, South Africa,

  33. Tel: (058) 303 0450

  34. Email: reception@s-bro.co.za

  35. HEAD OFFICE BUSINESS HOURS Monday – Friday: 08:00 – 17:00

  36. Saturday: Closed

  37. Sunday: Closed

  38. © 2023 S-BRO FUND MANAGERS (PTY) LTD. All rights reserved. Website by Warp Development. Terms & Conditions Privacy Policy Cloud Security Policy PAIA & POPI Manual

S-BRO FUND MANAGERS (PTY) LTD (FSCA category 2: Nr: 41855) (Reg no: 1999/018626/07)

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