Privacy Policy | Imvelo Wealth Solutions

1. Who We Are

Imvelo Wealth Solutions (Pty) Ltd ("Imvelo Wealth", "we", "us", or "our") is a South African Financial Services Provider licensed and regulated by the Financial Sector Conduct Authority (FSCA) under the Financial Advisory and Intermediary Services Act, 37 of 2002 (FAIS Act). Imvelo Wealth Solutions is based in Johannesburg, South Africa.

We process personal information as a responsible party in terms of the Protection of Personal Information Act, 4 of 2013 (POPIA). This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, how long we retain it, and what rights you have in respect of your personal information.

For any privacy-related queries or to exercise your rights, contact our Information Officer:
Email: admin@imvelowealth.co.za
Postal address: Information Officer, Imvelo Wealth Solutions, Johannesburg, South Africa

2. What Personal Information We Collect

We collect only the minimum personal information necessary for the purposes described in this policy. This includes:

Identity information: First name, last name, South African ID number or passport number (collected only for regulatory onboarding where required by FICA).
Contact information: Email address, telephone number, and physical address.
Financial information: Income range, asset values, liability details, investment objectives, and risk tolerance — collected during the financial needs analysis process required under FAIS.
Consultation preferences: Preferred appointment dates, times, and financial goals submitted through our booking form.
Communication records: Correspondence by email, WhatsApp, or telephone that you initiate with us.
Technical information: IP address, browser type, and anonymised page visit data collected automatically through our website analytics (no personal identifiers are stored in analytics).

We do not collect special personal information (as defined in section 26 of POPIA — including race, health, or biometric data) unless required by law or with your explicit consent.

3. Why We Collect It (Purpose)

We process your personal information for the following purposes:

To deliver financial advisory services: Completing the financial needs analysis, preparing financial plans, and providing ongoing advice in terms of our mandate.
To fulfil regulatory obligations: Compliance with FAIS, FICA (Financial Intelligence Centre Act), and SARS reporting requirements may require us to verify your identity and retain records.
To manage your consultation booking: Scheduling, confirming, and following up on consultation appointments you request through our website.
To communicate with you: Responding to enquiries, sending appointment confirmations, and providing regulatory updates or educational content you have opted into.
To improve our services: Analysing aggregated, anonymised usage patterns on our website to improve functionality and content.

We rely on the following lawful grounds under POPIA section 11 for processing: (a) your consent; (b) the performance of a contract with you or steps prior to entering into a contract; (c) compliance with a legal obligation; and (d) our legitimate interests, where those interests are not overridden by your right to privacy.

4. How Long We Retain Your Information

Consultation request data (name, contact details, appointment details): 12 months from the date of submission, or for the duration of our advisory relationship if one commences.
Client records and financial advice records: 5 years from the date of the last advice interaction, as required by FAIS Board Notice 80 of 2003 (Record Keeping).
FICA identity verification records: 5 years from the date on which the business relationship ends, as required by the Financial Intelligence Centre Act.
Website analytics data: Anonymised — retained for 26 months per industry standard.

After the applicable retention period, personal information is securely deleted or anonymised.

5. Sharing Your Information

We do not sell your personal information. We share your information only in the following limited circumstances:

Service providers (operators): We use third-party services including Resend (email delivery) and Vercel (website hosting). These parties process personal information on our behalf under written operator agreements that bind them to POPIA-equivalent data protection obligations.
Product providers and platforms: Where you instruct us to execute a financial product on your behalf, we share the minimum required personal information with the relevant licenced product provider (e.g., asset management platforms, insurers).
Regulatory and legal obligations: We may disclose personal information to the FSCA, SARS, the Financial Intelligence Centre, or courts where required by law.

Cross-border transfers of personal information (e.g., to cloud infrastructure hosted outside South Africa) are subject to the protections required under POPIA section 72, including ensuring the recipient country or contract provides equivalent protection.

6. How We Protect Your Information

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, and destruction. These measures include:

TLS encryption for all data transmitted through our website.
Access controls limiting personal information to staff who require it for their role.
Operator agreements with all third-party service providers.
Regular security reviews of our digital infrastructure.

In the event of a data breach that is likely to affect your rights adversely, we will notify the Information Regulator and you as required by POPIA section 22.

7. Your Rights Under POPIA

As a data subject under POPIA, you have the following rights:

Right to access: You may request confirmation of whether we hold your personal information and obtain a copy of it.
Right to correction: You may request that we correct inaccurate or incomplete personal information.
Right to deletion: You may request deletion of your personal information, subject to our legal retention obligations.
Right to object: You may object to the processing of your personal information on grounds relating to your particular situation, where processing is based on legitimate interests.
Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
Right to complain: You may lodge a complaint with the Information Regulator of South Africa at inforeg@justice.gov.za if you believe we have processed your personal information unlawfully.

To exercise any of these rights, submit a written request to admin@imvelowealth.co.za. We will respond within 30 days.

8. Cookies and Website Analytics

Our website uses no third-party advertising or tracking cookies. We use privacy-respecting, anonymised analytics to understand aggregate usage patterns. No personally identifiable information is stored in our analytics system. You may disable cookies in your browser settings without any loss of core website functionality.

9. Marketing Communications

We may send you educational content, regulatory updates, or information about our services where you have opted in or where we have a pre-existing relationship and you have not opted out. Every marketing communication includes an unsubscribe mechanism. We do not send unsolicited commercial communications.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by posting the updated policy on this page with a revised "Last updated" date. We encourage you to review this page periodically.

11. Contact Us

For privacy-related queries, to exercise your rights, or to reach our Information Officer:

Email: admin@imvelowealth.co.za
General enquiries: info@imvelowealth.co.za / admin@imvelowealth.co.za
Location: Johannesburg, South Africa