Privacy policy

3.  What Personal Information does Summit require?

Summit’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:

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Information Officer : Louise Chennells
Telephone number : +27 79 366 0389
Postal & Physical address : 1st Floor, The Ridge at Discovery, 1 Discovery Place, Johannesburg, South Africa
E-mail address:  louise@summitafrica.co.za

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

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

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• 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;

• information relating to the education or the medical, financial, criminal, or the employment history of the person;

• any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;

• the biometric information of the person;

• the personal opinions, views or preferences of the person;

• 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;

• the views or opinions of another individual about the person; and

• 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.”

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“Processing” is defined in POPIA as follows:

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“any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including-

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• the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;

• dissemination by means of transmission, distribution or making available in any form; or

• merging, linking, as well as restriction, degradation, erasure or destruction of information;”

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

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• Identification document;

• Curriculum vitae data, including professional and employment history and education;

• Proof of residential/business operating address, postal address, billing address;

• E-mail addresses;

• Contact numbers;

• Income Tax registration or other tax identification number;

• VAT registration number (if applicable per individual/legal entity);

• Banking details where you are required to make a payment to Summit or we are required to remit a payment to you or as part of a bank reference or statement provided to us during a due diligence exercise;

• Political exposed person status;

• Source of wealth and source of funds;

• For Juristic Persons we may also collect documents to establish your identity and existence, including the business activities, financial position, transactions, tax related information, regulated status, listed status, directors, management, control, shareholdings and beneficial ownership;

• Marketing preferences in receiving marketing from us and our third parties and your communication preferences.

You are responsible for providing us accurate and up-to-date information. Please keep us informed if your personal information changes during your relationship with us.

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When you provide us with information about other individuals or Juristic Persons in connection with your dealings with us, you must ensure that they agree to Summit using their information as set out in our letter of engagement or agreement and you will need to tell them how to access Summit’s Privacy Policy.

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Summit may also collate and hold data found from the results of Google or other internet searches and other sources in the public domain as well as third party service providers in the course of our employee and client due diligence and review process, and in providing the services that we are engaged to provide.

4.  Why does Summit require your Personal Information?

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

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Summit needs your Personal Information to provide you with the following services:

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• To establish a legal relationship with you;

• To populate the client account information required on the various on-boarding platforms; and

• For internal administrative and accounting, auditing, data analysis and research purposes in the normal course of managing Summit’s business and to improve Summit’s services and client communications.