Your privacy is important to QTC. This Privacy Policy has been compiled in terms of POPI and will assist you to understand how we collect, communicate and use any personal information that you submit to us. QTC’s services, the measures it takes to protect your privacy and any communication around its policy are subject to this Privacy Policy. As QTC’s business evolves, this Privacy Policy will be updated. The most up to date published version of this Privacy Policy will be on QTC’s website.
1. Personal Information
1.1 Your personal information may be collected by QTC (from QTC’s website or from public records) or provided by you. Personal information includes any information provided by you that identifies you as a natural or juristic person and which relates to you as an identifiable individual such as your name, physical and postal addresses, e-mail address, telephone number, certain correspondence, the internet address of the domain from which you are visiting QTC’s (or its Affiliates’) website, and/or your race, age, education, etc as applicable.
1.2 Should you decide to engage with QTC (or its Affiliates) or use QTC’s website, you expressly consent to QTC collecting, collating, processing and using your personal information.
1.3 Unless QTC obtains your voluntary and informed consent, or unless it is required or permitted by law, QTC will not distribute or disclose your personal information that you have supplied. QTC will only collect your personal information lawfully and fairly and, where appropriate, with the knowledge or consent of the individual concerned.
1.4 You have the right to request that QTC stops processing your personal information. You may withdraw your consent at any time and QTC will no longer use or process your personal information, however this may affect the outcomes of your engagement with QTC. QTC will advise you if any outcome will be affected at the time you withdraw your consent.
1.5 Should you have any questions about this policy, or should you wish to exercise your legal rights in terms of POPI, access, correct, withdraw your consent and/or request that QTC stops processing any of your personal information held, you may send an email to popi@quivertreecapital.co.za.
1.6 Should you have any concerns, QTC would appreciate the opportunity to resolve them, however should you wish to contact the Information Regulator or lodge a complaint, you may do so at the details below:
The Information Regulator (South Africa)
Complaints email: complaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za
Physical address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Postal address: P.O Box 31533, Braamfontein, Johannesburg, 2017
2. QTC
2.1 QTC is a private company incorporated in South Africa with the following contact details:
Name: Quiver Tree Capital (Pty) Ltd
Address: The Woodlands, Building 27, Ground Floor, Woodlands Drive, Woodmead, South Africa
Email: popi@quivertreecapital.co.za
Phone: +27 11 073 1730
Information Officer: Lawrence Roff
2.2 When you engage with QTC to provide you with a service, QTC is the responsible party (as defined in POPI) and is responsible for both your personal information and for processing your personal information.
2.3 There may be occasions where QTC is the responsible party and a third party Affiliate is the operator (as defined in POPI). In this instance, QTC will only ever share your personal information with a third party Affiliate (for the third party Affiliate to process) with your consent.
3. QTC’s Purpose for Processing Your Personal Information
3.1 QTC provides solutions and historical information in respect of all 5 elements of the B-BBEE scorecard for regulatory purposes and for the provision to verification agents and other professionals. In order to provide these solutions and historical data, it is necessary for QTC to contact, market, promote and engage with potential clients and potential Empowerment Partners on an ongoing basis (QTC’s purpose/s).
3.2 In order achieve the purposes, to partner with QTC, and for QTC to implement the solution(s) chosen by you, QTC will collect, use and process certain necessary personal information provided by you. Before or at the time of collecting your personal information, QTC will identify the specific purpose(s) for which the personal information is being collected.
3.3 QTC will only retain your personal information for as long as necessary to fulfil the purpose(s) that have been identified to you. Once the identified purpose has been fulfilled, QTC will retain your personal information for historical purposes. Your personal information will be retained for 5 years after the last purpose for which you engaged QTC has been achieved before it is archived for historical purposes.
4. Your Personal Information
4.1 QTC processes your personal information with your consent and for the purpose for which you have engaged QTC. Each new engagement with QTC will be a new purpose, and your personal information will be processed for the new purpose with your consent. Where you are a party to a transaction, you consent to your personal information being shared with and processed by other parties to the transaction (and their professional advisors) that are based outside of the Republic of South Africa in countries with data privacy protection laws that offer the same level of data protection as POPI or more.
4.2 QTC has considered your privacy interests and only requests, collects and uses the information necessary to achieve the purpose for which you’ve engage QTC. When you engage QTC, QTC will send you a request for information that is pertinent to the service requested by you. QTC may request updated personal information from you from time to time or as necessary to provide the service. Failure to provide the personal information requested by QTC may result in delays in your chosen service being implemented. For further information on what is applicable to your chosen service, please refer to the Letter of Engagement you have signed with QTC.
4.3 The personal information QTC collects and processes provided by you includes, but is not limited to, names, company registration numbers, identity or passport numbers, Masters reference numbers, telephone numbers, email, postal and physical addresses, FICA documents, proprietary company information, records and documentation, share registers and shareholder details, company financial information, beneficiary details, curricula vitae, personal profiles, affidavits, B-BBEE certificates, Enterprise Development and Socio-Economic Development Certificates, bank account details, and SARS official documentation. From time to time QTC may need to collect other information from you that isn’t listed here.
4.4 QTC doesn’t collect or process any personal information of anyone under the age of 18 years old without the consent of their legal guardian. Users of the QTC website warrant that they are not younger than 18 years old and if so, that the minor’s guardian has given consent for the minor to use the QTC website and for the QTC website to collect the minor’s information. This information will not be processed without the guardian’s consent.
4.5 Generally, QTC only processes the personal information that you provide in order to achieve the purpose. Where QTC sources personal information about you (for example on CIPC) QTC does its best to ensure that the information is complete, accurate and up to date. Please ensure that any information that you provide to QTC for an engagement or otherwise is accurate, true and correct. Should any of the personal information that you’ve supplied to QTC change, please ensure that you send the updated details to QTC as soon as reasonably possible.
4.6 Where applicable, QTC may request up to date FICA documents where they are older than 3 months.
5. Information Security
5.1 QTC values your privacy and takes reasonable technical and organisational measures (including generally accepted security practices) to secure the integrity and confidentiality of your personal information. Although QTC believes that your information is safe, should there be any unauthorised access or processing of your personal information, QTC will notify the Information Regulator and you in writing as soon as reasonably practical.
5.2 QTC uses third party cloud servers to store and manage our data and information, like Dropbox and Microsoft Office365. This means that your personal information may be transferred to a third country or international organisation. Should you wish to know more about what data security our service providers have in place, please contact us on popi@quivertreecapital.co.za.
6. Your Rights
6.1 You have the right (on providing a certified copy of your ID to QTC) to request that QTC:
6.1.1 confirms whether or not it holds your personal information;
6.1.2 gives you a description of your personal information held within a reasonable time and manner, QTC may charge you the prescribed fee, where applicable;
6.1.3 corrects any of your personal information;
6.1.4 delete any personal information that is inaccurate, irrelevant out of date, incomplete, or misleading, as well as delete any personal information that QTC is no longer authorised to retain.
6.2 Further, you may object to your personal information being processed. To contact QTC to exercise your rights, please send an email to popi@quivertreecapital.co.za. Please note that access to your personal information is subject to certain provisions of PAIA. QTC’s PAIA manual can be found here.
6.3 On receiving your request QTC will respond within 20 business days, although often as soon as reasonably practicable. Upon your request QTC will correct, and on a demonstrable best endeavours basis destroy or delete the relevant information and inform you that the request has been processed.
7. Glossary of Terms
7.1 Affiliate means any company in the Magenta Group of companies or any of QTC’s suppliers or professional advisors;
7.2 Magenta Group means the group of companies being Magenta Sky Holdings (Pty) Ltd and its subsidiaries currently consisting of Magenta Industrial Technologies (Pty) Ltd, Magenta Quantum Solutions (Pty) Ltd, Magenta Spark (Pty) Ltd and Magenta Origins (Pty) Ltd;
7.3 QTC means Quiver Tree Capital (Pty) Ltd;
7.4 POPI means the Protection of Personal Information Act, No 4 of 2013 (as amended);
7.5 PAIA means the Promotion of Access to Information Act, No 2 of 2000.
