1.Policy

1. Obtain and process your information fairly.
2. Keep your information only for one or more specified, explicit, and lawful purposes.
3. Use and disclose your information only in ways compatible with these purposes.
4. Keep your information safe and secure.
5. Keep your information accurate, complete, and up to date.
6. Ensure that your information is adequate, relevant, and not excessive.
7. Retain your information for no longer than is necessary for the purpose or purposes.
8. Provide a copy of your personal data kept to you on request.

2.Types of personal information we work with

Financial Junction Investments generally works with the following types of personal information:

• information relating to the race, gender, sex, pregnancy, marital status, national, ethnic, or social origin, colour, age, physical or mental health, well-being, disability, language, and birth;
• information relating to the education, medical, financial, criminal or employment history;
• identifying number, name, symbol, e-mail address, physical address, telephone number, location information; and or

• correspondence sent/received that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence.

3. What we do with this information

We may use this information in the process of:

• administer our relationship with you (including communications and reporting);
• provide a product / service to you;
• market our products and services to you;
• confirm, verify, and update contact details;
• detect and prevention fraud, crime, money laundering or other malpractice;
• comply with audit and record keeping requirements;
• carry out the services requested and to maintain and constantly improve the relationship;
• communicate with you about Wayne Rogers Financial Brokers cc and regulatory matters that may affect you;
• comply with legal and regulatory requirements or when it is otherwise allowed by law; and or
• facilitate transaction(s) requested.
• assess and process claims;
• obtain claims history; and or
• conduct market or customer satisfaction research.

We collect and store any relevant communication sent and received e.g., emails, meeting notes etc.

4.Information sources

We may also supplement the information you have provided with information we receive from other providers like Astute, Google, sanction list information requests, independent FICA verification agencies and Insurers to offer a more efficient, consistent, and personalised experience.

5. Sharing personal information

5.1 General sharing of personal Information

We will disclose your personal information to relevant service providers, affiliates or third parties including Investment Managers, Custodians, Linked Investment Services Platforms, Insurers, and our bookkeepers for everyday business purpose e.g., our own commission management, to facilitate transactions and maintain your accounts or in response to court orders or legal investigations. 

Financial Junction Investments has however concluded agreements with all our service providers that process information on our behalf placing and obligation on these providers to keep this information confidential and to take the necessary measures to protect it.

Additionally, Financial Junction Investments also has a process in place to determine if the parties with whom we duly share your Personal Information subscribes to the same data protection principles as what we do.

Due to the nature of our infrastructure information may also be shared with:

• The Microsoft Corporation;

5.2 Sending personal information to foreign countries

We may need to transfer Personal Information to another country for processing or storage. We will endeavour to ensure that anyone to whom we pass personal information are subject to the same Data protection regulations as what we are or agrees to treat Personal Information with a similar level of protection as afforded by ourselves.

6. Your rights under data protection law

You have the right to be informed about the personal information we have, and what we do with it.

You have the right to:

• ask us what we know about you;
• ask what information was sent to our suppliers, service providers or any other third party;
• ask us to update, correct or delete any out-of-date or incorrect personal information we hold about you if it is no longer necessary to provide services to you (we can unfortunately not take responsibility for incorrect or outdated information if we were provided with incorrect information or you failed to inform us of changes);
• receive the information we have about you and to transfer it to another service provider in machine readable form;
• unsubscribe from any direct marketing communications we may send you;
• object to the processing of your personal information.

You can request access to the information we hold about you or correct your personal information by contacting our deputy information officer.

It may take us up to 21 business days to respond to your request, because there are procedures that we need to follow. In certain cases, we may require proof of your identity and sometimes changes to your information may be subject to additional requirements such as valid proof of residence.

7.Data Breaches

We will take every precaution and implement appropriate technical measures to prevent data breaches and have taken reasonable steps to minimise the impact of a breach.

We regularly monitor our systems for possible vulnerabilities and security breaches, but no system is perfect and we cannot guarantee that we will never experience a breach of any of our physical, technical, or managerial safeguards. If something should happen, we have taken steps to minimise the threat to your privacy. We will let you know of any breaches which affect your personal information and inform you how you can help minimise the impact.

8.Information Officer and Deputy Information Officer

The Protection of Personal Information Act appoints the highest level of authority in an organisation as the Information Officer. The Information Officer has been tasked with ensuring compliance with data protection and privacy legislation and regulations.

The Information Officer has appointed a Deputy Information Officer to perform the required tasks. 

The details of our Information Officer and Deputy Information Officer are as follows:

9. Updates to this Privacy Policy

We reserve the right to make changes to this Privacy Policy and any changes to this policy will be published accordingly.

10. Version control and approval