S-BRO FUND MANAGERS (PTY) LTD is committed to protecting Your privacy. This Privacy Policy, together with our Website Terms and Conditions, explains:

• The kinds of personal information S-BRO FUND MANAGERS (PTY) LTD collects and holds.

• How S-BRO FUND MANAGERS (PTY) LTD collects and holds personal information.

• The purpose for which S-BRO FUND MANAGERS (PTY) LTD collects, holds, uses, and discloses personal information.

• Your right to seek access to and correction of Your personal information.

• How You may complain about privacy matters.

• S-BRO FUND MANAGERS (PTY) LTD's sharing of Your personal information with third parties.

If You have any questions concerning Your personal information, please contact S-BRO FUND MANAGERS (PTY) LTD at www.sbro.co.za.

1. PERSONAL INFORMATION Personal Information refers to all information about You as an identifiable individual, including Your name, address, email address, telephone number, and identity number.

2. COLLECTION AND PROCESSING OF PERSONAL INFORMATION

2.1 S-BRO FUND MANAGERS (PTY) LTD only collects and processes Personal Information that is reasonably necessary for its business, functions, and activities, which include but are not limited to the following instances:

• Making an online purchase.

• Opening an account.

• Taking part in S-BRO FUND MANAGERS (PTY) LTD's promotions, competitions, and surveys.

2.2 S-BRO FUND MANAGERS (PTY) LTD may also collect Personal Information about You by accessing data from other sources and then analysing that data together with the information S-BRO FUND MANAGERS (PTY) LTD already holds about You in order to learn more about Your likely preferences and interests.

2.3 In order to register for certain services or enter competitions or promotions offered through S-BRO FUND MANAGERS (PTY) LTD's Website from time to time, S-BRO FUND MANAGERS (PTY) LTD may collect relevant Personal Information which may be used to provide the services to You.

2.4 S-BRO FUND MANAGERS (PTY) LTD may use Personal Information for its own internal purposes including:

• Establishing and verifying Your identity.

• Maintaining and updating S-BRO FUND MANAGERS (PTY) LTD's customer database.

• Marketing, product research, and development purposes.

3. STORAGE OF PERSONAL INFORMATION

3.1 S-BRO FUND MANAGERS (PTY) LTD uses all reasonable endeavours to put in place and maintain electronic procedures and systems to ensure accuracy and to eliminate risks of unauthorised access to, and loss, misuse, or wrongful alteration of Personal Information with reference to accepted technological standards.

3.2 The S-BRO FUND MANAGERS (PTY) LTD Website uses Peach Payments Gateway to implement encryption to encrypt transmission of sensitive information between Your browser and S-BRO FUND MANAGERS (PTY) LTD's web server.

3.3 S-BRO FUND MANAGERS (PTY) LTD's security encrypts Your Personal Information so that it cannot be read as the information travels over the Internet.

4. PERSONAL INFORMATION SHARED 4.1 S-BRO FUND MANAGERS (PTY) LTD will not sell, rent, or otherwise disclose Your Personal Information to any third party without Your consent, provided that by using S-BRO FUND MANAGERS (PTY) LTD's Website You provide Your express and informed consent for S-BRO FUND MANAGERS (PTY) LTD to disclose Your Personal Information to third parties as follows:

• To third-party companies employed by S-BRO FUND MANAGERS (PTY) LTD to provide services for S-BRO FUND MANAGERS (PTY) LTD, including for example, website hosting and development – these companies require access to Your Personal Information to perform their functions and not for any other purposes.

• To transfer S-BRO FUND MANAGERS (PTY) LTD's customer database, including Personal Information contained therein, to any third party who acquires all or substantially all of the assets or shares in S-BRO FUND MANAGERS (PTY) LTD or its Website service, whether by sale, merger, acquisition, or otherwise.

• To governmental agencies, exchanges, and other regulatory or self-regulatory organisations if S-BRO FUND MANAGERS (PTY) LTD is required to do so by law or if S-BRO FUND MANAGERS (PTY) LTD believes that such action is necessary to comply with the law or with any legal process, protect and defend S-BRO FUND MANAGERS (PTY) LTD's rights and property or that of its customers and companies in the group, prevent fraud or abuse, misuse or unauthorised use of S-BRO FUND MANAGERS (PTY) LTD's Website and/or protect the personal safety or property of S-BRO FUND MANAGERS (PTY) LTD's customers or the public.

4.2 S-BRO FUND MANAGERS (PTY) LTD reserves the right to share non-personal, non-individual information in aggregate form with third parties for business purposes, for example with advertisers on S-BRO FUND MANAGERS (PTY) LTD's Website or business associates and partners. This does not involve disclosing any Personal Information which can identify any individual consumer in any way.

5. ACCURACY OF INFORMATION

5.1 It is important that the information You provide to S-BRO FUND MANAGERS (PTY) LTD is accurate and up to date. If your personally identifiable information changes, you may correct or update it online.

5.2 S-BRO FUND MANAGERS (PTY) LTD cannot be held liable for any information that is inaccurate and/or obsolete.

5.3 If You would like to receive a copy of the information about You held by S-BRO FUND MANAGERS (PTY) LTD, please contact S-BRO FUND MANAGERS (PTY) LTD.

6. OPTING OUT

6.1 If You are an existing customer, S-BRO FUND MANAGERS (PTY) LTD provides You the opportunity to ‘opt-out’ of having Your personally identifiable information used for certain purposes when this information is provided to S-BRO FUND MANAGERS (PTY) LTD.

6.2 If You no longer wish to receive promotional communications, you may opt-out of receiving it by updating Your registered profile preferences.

7. CHANGES TO THIS PRIVACY POLICY

7.1 S-BRO FUND MANAGERS (PTY) LTD reserves the right to modify this policy at any time, with any changes being posted to this page.

7.2 If S-BRO FUND MANAGERS (PTY) LTD makes any material changes to this policy, you will be notified through a notice on S-BRO FUND MANAGERS (PTY) LTD's home page.

7.3 Any amended privacy and security policy will supersede and replace any previous policies, effective from the date on which it is posted on S-BRO FUND MANAGERS (PTY) LTD's Website.

8. HOW S-BRO FUND MANAGERS (PTY) LTD USES COOKIES

8.1 A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.

8.2 S-BRO FUND MANAGERS (PTY) LTD uses traffic log cookies to identify which pages are being used. This helps S-BRO FUND MANAGERS (PTY) LTD analyze data about web page traffic and improve its website to better suit customer needs. This information is used for statistical analysis purposes only, after which the data is removed from the system.

8.3 Overall, cookies help S-BRO FUND MANAGERS (PTY) LTD provide you with a better Website, by enabling S-BRO FUND MANAGERS (PTY) LTD to monitor which pages you find useful and which you do not. A cookie in no way gives S-BRO FUND MANAGERS (PTY) LTD access to your computer or any information about you, other than the data you choose to share. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. However, this may prevent you from fully experiencing the Website.

8.4 List of cookies S-BRO FUND MANAGERS (PTY) LTD collects

The table below lists the cookies S-BRO FUND MANAGERS (PTY) LTD collects and what information they store.

How we use cookies A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis purposes, and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

List of cookies we collect The table below lists the cookies we collect and what information they store.