Privacy Policy

What Personal Information does the Company require?

1.1. Dalebrook Capital (Pty) Ltd (“the Company”)’s Personal Information Protection Policy governs the Processing of your Personal Information. You may view the Personal Information Protection Policy by contacting the Information Officer on or on 021 205 3636.

1.2. “Personal Information” is defined in the Protection of Personal Information Act (Act no. 4 of 2013) (“POPIA”) as follows:

“Information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to –

(a) information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, wellbeing, disability, religion, conscience, belief, culture, language and birth of the person;
(b) information relating to the education or the medical, financial, criminal, or the employment history of the person;
(c) any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
(d) the biometric information of the person;
(e) the personal opinions, views or preferences of the person;
(f) correspondence sent by the person, that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
(g) the views or opinions of another individual about the person; and
(h) the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.”

1.3. “Processing” is defined in POPIA as follows:

“any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including—
(a) the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
(b) dissemination by means of transmission, distribution or making available in any form; or
(c) merging, linking, as well as restriction, degradation, erasure or destruction of i information;”

1.4. The Company is a Responsible Party in respect of the Personal Information you (Data Subject) provide to the Company. The Company processes the following types of Personal Information from you:

1.4.1.Identification document;
1.4.2.Proof of residential/business operating address;
1.4.3.South African Income Tax registration number;
1.4.4.South African VAT registration number (if applicable per individual/legal entity);
1.4.5.Contact numbers;
1.4.6.E-mail addresses;
1.4.7.Banking details;
1.4.8. Employer/Occupation details
1.4.9. Approximate Income
1.4.10. Source of Funds
1.4.11. Assets and Liabilities

2. Why does the Company require your Personal Information?

2.1. This Personal Information is required in terms of the Financial Intelligence Centre Act, 38 of 2001 and the Company’s Risk Management and Compliance Programme. The Personal Information forms part of the Company’s requirements when obtaining a discretionary mandate from you or opening an account to facilitate the relevant business activities.

2.2. The Company needs your Personal Information to provide you with the following services:

2.2.1.To establish a legal relationship with you;
2.2.2.To populate the client account information required on the various on-boarding platforms to open your account; and
2.2.3.To generate statements and capture contact information related to this discretionary mandate or account;

3. How is your Personal Information Processed?

3.1. Your Personal Information is Processed at Unit 4 Ground Floor, Canal Edge 1-B, Tyger Waterfront, Carl Cronje Drive, Bellville, 7530. Storage of your Personal Information takes place in Unit 4 Ground Floor, Canal Edge 1-B, Tyger Waterfront, Carl Cronje Drive, Bellville, 7530.

3.2. No third-party providers have direct access to your Personal Information unless specifically required by law and to satisfy client due diligence principles.

3.3. Your Personal Information is shared with product suppliers, for account opening purposes.

4. How long does the Company keep your Personal Information?

4.1. Under South African law, the Company is required to keep your Personal Information for a five (5) year period following the date of termination of the business relationship according to the Company’s Personal Information Retention Policy. After this period, your Personal Information will be irreversibly destroyed. For more information on the Company’s Personal Information retention schedule, please refer to our Personal Information Retention Policy which can be accessed at

5. What are your rights?

5.1. Should you believe that any of your Personal Information held by the Company is incorrect or incomplete, you have the right to request to view this information, rectify it or have it deleted. Please contact the Company’s Information Officer on, should this be required.

5.2. In addition, if you wish to complain about how the Company has handled your Personal Information, please contact the Information Officer on . The Company’s Compliance Department will investigate your complaint and contact you within two (2) business days of the complaint being lodged and work with you to resolve the matter.

5.3. If your query relating to your Personal Information is not, in your opinion, adequately dealt with, you can contact the Information Regulator on 012 406 4818 or to file an official complaint.


Please see the following technical information about what data is collected and how it is processed:

1. Introduction

1.1. In adopting this Privacy Policy, we wish to balance our legitimate business interests when collecting and using your information and your reasonable expectation of privacy. In this respect, we will take all reasonable steps to prevent unauthorised access to your personal information.

1.2. Please note, we cannot guarantee that your personal information shall at all times be 100% secure since no security system on the internet can offer a 100% secure guarantee. We do however take all reasonable steps to our website against hackers by using secure hosting environments and installing the necessary plugins to harden the website security protocols.

1.3. By continuing to use our website, or any of our services you agree and are deemed to accept the terms and conditions of this Privacy Policy.

1.4. You also agree and accept that we may collect, process and/or store your personal information (as defined in the ECT Act) provided by you if you enter your details in the online contact form.

2. Collection of Usage Data

2.1. Usage Data is collected automatically when using our website through tracking cookies like Google Analytics and Facebook Pixel, however, this information collected passively using various technologies is strictly for statistical purposes and to determine the visitor traffic patterns through our website and cannot be used by us to specifically identify you or extract personal information.

2.2. Google Analytics data may include information such as your browser type, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

2.3. When you access our website through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever you visit our website or when you access our website by or through a mobile device.

3. What Personal Information is Collected

3.1. Only the details you provide by entering your information into the online contact form. This information normally includes your name, email address, contact number and occasionally your website address.

3.2. By entering your personal information into the online contact forms, you consent to provide us with your details we will use to send you the appropriate information required for you to use our products or services.

4. How Your Personal Information is Used

4.1. The primary goal in collecting your personal information is to provide you with a better customer experience, which may include, interactive communications, online shopping and other services.

4.2. Your personal information may be used to:

4.2.1. To contact you by email, telephone calls, or other equivalent forms of electronic communication, regarding quotations, updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

4.2.2. To provide you with general information about our company like important events such as website downtime, business closure dates during holidays or important news and updates.

4.2.3. To attend and manage your requests to us.

5. With whom is your information shared?

5.1. Your personal information will never be shared with any third-party organisations to be used for direct marketing purposes.

5.2. Your personal information may also be shared under the following circumstances:

5.3. If we need to create accounts for products or services and they need to be registered in your name.

5.4. Where the law requires that we disclose your personal information in special cases, where we have reason to believe that such disclosure is necessary to identify, contact or bring legal action against a party.

5.5. Online Payments to make a purchase from our website, the information obtained during the checkout process including tracking information, cookies, credit card number and contact information is provided to the payment gateway and where required, the delivery company.

5.6. Occasionally we many need to use third-party providers like MailChimp for the purposes of sending you marketing-related announcements related to the products or services available by us on our website or general information like season’s greetings or new-year special offers. You may at any time opt out of receiving such marketing-relating announcements.

6. What are Cookies And How are They Used?

6.1. Cookies are pieces of information that a website transfers to a user’s hard drive for record-keeping purposes. Cookies make surfing the web easier for you by saving your preferences and tracking your online habits, traffic patterns, and making sure you do not see the same advertisement too often. These files do not contain personal data, but they do contain a personal identifier allowing some websites to associate your personal data with a certain device. The use of cookies is an industry standard.

6.2. We do not extract personal information form cookies nor are we affiliated with any marketing company that uses services to match identifiers with personal information.

6.3. We may place a “cookie” on your browser to store and sometimes track information about you and the use of our website.

6.4. While most browsers are initially set up to accept cookies, you can reset your browser to refuse all cookies or indicate when a cookie is being sent. Please, note that some parts of our website will not function properly if you refuse cookies. You may occasionally get cookies from third party advertisers. We do not control these third-party cookies. The use of advertising cookies sent by third-party advertisers is an industry standard.

7. The Types of Cookies We Use

7.1. We use different types of cookies on our website. These cookies may be deleted from your device at different times, such as at the end of your browsing session (when you leave the website) or after a pre-set amount of time, or they may persist on your device until you delete them.

7.2. We use the following types of cookies on our website:

7.3. Essential cookies – these are cookies that allow our website to perform its essential functions. Without these cookies, some parts of our websites would stop working.

7.4. Site analytics cookies – these are cookies that monitor how our website is performing, and how you interact with it. We use them to know how best to improve our website or services.

7.5. Functional cookies – these are cookies that remember who you are as a user of our website. We use them to remember any preferences you may have selected on our website, like saving your username and password or settings.

8. Security of Personal Information

8.1. Overall website security and the protection of all personal information associated with you is of the utmost concern to us. While we exercise great care in providing secure transmission of your personal information, no data transmission over the Internet can be guaranteed to be 100% secure. We therefore cannot guarantee the security of any information you transmit to, or from our website. We do however take all reasonable and appropriate measures to keep your personal information secure. We also back-up all of your personal information on a regular basis.

9. E-Mail

9.1. We use email as the primary method of communication, and we will respond your online contact request or direct contact request via email on the address you provided.

10. Children’s Privacy

10.1. Our website does not address anyone under the age of 18 (“Children”). We do not knowingly collect Personal Information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us and we will remove it. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers.

11. Retention of Data

11.1. We will retain your Personal Information which is collected only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

11.2. We will also retain Non-Personal Information for internal analysis purposes.

12. Access to and Correction of Personal Information

12.1. We do not maintain a customer database. All personal information is either saved in email communications or saved on Third Party Applications like Sage Account where your information is used to send quotations or invoices.

12.2. If you are a client and you can provide the necessary identification, you may request a record of all personal information we have and request removal where your information is no longer needed in the operation of our business for example record keeping for legal purposes.

13. Privacy Laws

13.1. The use of our website and any electronic transaction concluded with us are governed by the laws of the Republic of South Africa. If any user accesses our website from locations outside of the Republic of South Africa, that user is responsible for compliance with all local laws.

14. Changes to the Privacy Policy

14.1. Our website and/or any other information displayed on our website may change from time to time. As a result, at times it may be necessary for us to make changes to our website and this Privacy Policy. We reserve the right to update or modify our website and this Privacy Policy at any time and without prior notice to you. We will request your consent should any update or modification of our website or Privacy Policy adversely affect your rights set out herein.

14.2. Please review this Privacy Policy periodically and especially before you provide any Personal Information to us.
14.3. Your continued use of our website, after any changes or revisions thereto or to this Privacy Policy, shall indicate your agreement with the terms of such revised Privacy Policy.