Privacy Policy


This policy applies to everyone with access to Personal Information available to them due to their relationship with Harbour Advisory (Pty) Ltd. It addresses the rights of Data Subjects, being the various categories of people whose personal information we have access to. Personal Information broadly means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly to a specific natural or juristic person / Data Subject. This policy must be read together with Harbour Advisory (Pty) Ltd Records Management, Cyber Security and Business Continuity Policies

2. Purpose

This Policy aims to ensure Harbour Advisory (Pty) Ltd compliance with various laws and regulations addressing Personal Information and sets out how Harbour Advisory (Pty) Ltd handles their Data Subjects’ Personal Information and additionally lists the purpose(s) said information is used for.

3. Policy

Harbour Advisory (Pty) Ltd is committed to protecting the privacy of Data Subjects and to ensuring that their Personal Information is used appropriately, transparently, securely and in accordance with applicable laws. We subscribe to the Protection of Personal Information Act Principles and will:
1. Obtain and process information fairly.
2. Keep information only for one or more specified, explicit, and lawful purposes.
3. Use and disclose information only in ways compatible with these purposes.
4. Keep information safe and secure.
5. Keep information accurate, complete, and up to date.
6. Ensure that information is adequate, relevant, and not excessive.
7. Retain information for no longer than is necessary for the purpose or purposes.
8. Provide a copy of personal data kept to the Data Subject on request.

4. Procedures

4.1 Personal Information Collected

Harbour Advisory (Pty) Ltd will generally collect some of the following personal information from our Data Subjects:
• 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.
• Biometric information (employees).
• 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.
• The views or opinions of another individual about our Data Subject.2
We have agreements in place with all our product suppliers, and third-party service providers to ensure that there is a mutual understanding with regards to the protection of Personal Information. We may also supplement the information provided with information we receive from other providers to offer a more
consistent and personalised experience in clients’ interaction with us.

4.2 How Personal Information is used

Personal Information will only be used for the purpose for which it was collected and agreed. This may include:
• Providing a product / service to a Data Subject;
• As part of employee on-boarding or any other internal human resources function;
• Conducting credit reference searches or verification;
• Confirming, verifying, and updating contact details;
• For the detection and prevention of fraud, crime, money laundering or other malpractice;
• For audit and record keeping purposes;
• In connection with legal proceedings;
• Providing our services to a Data Subject to carry out the services requested and to maintain and constantly improve the relationship;
• Providing communications in respect of Harbour Advisory (Pty) Ltd and regulatory matters that may affect Data Subjects;
• In connection with and to comply with legal and regulatory requirements or when it is otherwise allowed by law;
• To carry out the transaction(s) requested;
• For underwriting purposes;
• Assessing and processing claims;
• For purposes of claims history; and or
• Conducting market or customer satisfaction research.

In terms of the provisions of the Protection of Personal Information Act, Personal Information may only be processed if certain conditions are met, which are listed below, along with supporting information for Harbour Advisory (Pty) Ltd
processing of Personal Information:
• When Data Subject consents to the processing – consent only required where the information will be used for something other than the intended use for which the information is supplied.
• The processing is necessary.
• Processing complies with an obligation imposed by law on Harbour Advisory (Pty) Ltd
• Processing protects the legitimate interest of the Data Subject.
• Processing is necessary for pursuing the legitimate interest of Harbour Advisory (Pty) Ltd or of a third party to whom information is supplied.

4.3 Disclosure of Personal Information

We will only disclose a Data Subject’s Personal Information for a reason it was not intentionally supplied for where we have a duty or a right to disclose in terms of the law or where it is necessary to protect our rights. We have agreements in place to ensure compliance with confidentiality and privacy conditions.

We may also share client Personal Information with, and obtain information about, clients from third parties for the reasons already discussed above.

4.4 Safeguarding Personal Information

We will adequately protect the Personal Information we hold and avoid unauthorised access and use of Personal Information. We will continuously review our security controls and processes to ensure that personal Information is secure.

When we contract with third parties, we impose appropriate security, privacy, and confidentiality obligations on them to ensure that Personal Information is kept secure. We may need to transfer (electronic) Personal Information to another country for processing or storage. We will ensure that anyone to whom we pass personal information agrees to treat Personal Information with a similar level of protection as afforded by ourselves.

4.5 Access and correction of Personal Information

Data Subjects have the right to access the Personal Information we hold about them. Data Subjects also have the right to request us to update, correct or delete their Personal Information on reasonable grounds. Once a Data Subject objects to
the processing of their Personal Information, Harbour Advisory (Pty) Ltd may no longer process said Personal Information.

We will take all reasonable steps to confirm our Data Subject’s identity before providing details of their Personal Information or making changes to their Personal Information. Harbour Advisory (Pty) Ltd Information Officer will be responsible for
managing this process.

4.6 Sharing personal information

We will disclose your personal information to service providers, affiliates or third parties including Investment Managers, Custodians, Linked Investment Services Platforms, Insurers for everyday business purpose e.g. to facilitate transactions
and maintain your accounts or in response to court orders or legal investigations.
We have a mutual understanding with all our product suppliers and third-party service providers mutual understanding with regards to the protection of Personal Information. Due to the nature of our infrastructure information may also be shared with:
• Microsoft Corporation

4.7 Monitoring of communications

We record and monitor telephone conversations and electronic communications with you for the purposes of
(i)ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances,
(ii) ensuring compliance with our regulatory obligations; and / or (iii) detecting and preventing the commission of financial crime.

4.8 Data breaches

Even though Harbour Advisory (Pty) Ltd will take every precaution to prevent a data breach, a breach may still occur. A personal data breach is a breach of security leading to a:
• Confidentiality breach – an accidental or unauthorised disclosure of, or access to, personal data.
• Availability breach – an accidental or unauthorised loss of access to, or destruction of, personal data and/or
• Integrity breach – an accidental or unauthorised alteration of personal data.

4.8.1 Notification to the Information Regulator (“IR”)

The Information Regulator must be notified of the breach if it is likely to result in a risk to the rights and freedoms of data subjects i.e., if, for example, it could result in:
• loss of control over their data
• limitation of their rights
• discrimination
• identity theft
• fraud
• damage to reputation
• financial loss
• unauthorised reversal of pseudonymisation
• loss of confidentiality
• any other significant economic or social disadvantage.4

Where a breach is reportable, the Company must notify the Information Regulator without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach. If our report is submitted late, it must also set out the reasons for our delay.

The notification must at least include:
• a description of the nature of the breach including, where possible, the categories and approximate number of affected
data subjects and the categories and approximate number of affected records;
• the name and contact details of the Information Officer;
• a description of the likely consequences of the breach; and
• a description of the measures taken, or to be taken, by the Company to address the breach and mitigate its possible adverse effects.

4.8.2. Communication to affected Data Subjects

Where the personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, Harbour Advisory (Pty) Ltd also needs to communicate the breach to the affected data subjects without undue delay, i.e., as soon as possible. Reporting to Data Subjects may however be delayed if reporting may lead to an increased risk to the Data Subject.

In clear and plain language, Harbour Advisory (Pty) Ltd must provide affected Data Subjects with:
• a description of the nature of the breach;
• the name and contact details of Harbour Advisory (Pty) Ltd’s Information Officer and CEO;
• a description of the likely consequences of the breach;
• a description of the measures taken, or to be taken, by Harbour Advisory (Pty) Ltd to address the breach and mitigate its possible adverse effects;
• practical advice on how to limit the damage, e.g., resetting their passwords; and
• Data subjects will be contacted individually, by e-mail, unless that would involve Harbour Advisory (Pty) Ltd in disproportionate effort such as where contact details have been lost as a result of the breach or were not known in the first place, in which case we will use a public communication, such as a notification on our website.

However, Harbour Advisory (Pty) Ltd is not required to report the breach to Data Subjects if:
• appropriate technical and organisational protection measures have been implemented, and those measures have been applied to the personal data affected by the breach, in particular those that render the personal data unintelligible
to any person who is not authorised to access them, such as state-of-the-art encryption, or
• subsequent measures were taken to ensure that the high risk to the rights and freedoms of Data Subjects is no longer likely to materialise.
Communication to Data Subjects with regards to Data Breaches may under no circumstances be communicated or published without prior approval of Harbour Advisory (Pty) Ltd Information Officer.

4.8.3 Data breach register

Harbour Advisory (Pty) Ltd will maintain a register of all personal data breaches, regardless of whether they are notifiable to the Information Regulator. Please see a template register in Annexure A.

4.8.4 Data breach reporting procedure

If anyone knows or suspects that a personal data breach has occurred, they must immediately both advise their line manager and contact the Company’s CEO. Evidence in relation to the breach must be retained. Harbour Advisory (Pty) Ltd will investigate and assess the actual or suspected personal data breach in accordance with the response plan set out below and will determine who should be notified and how.

4.6.5 Response plan

According to Harbour Advisory (Pty) Ltd response plan the Information Officer will:
• Make an urgent preliminary assessment of what data has been lost, why and how.
• Take immediate steps to contain the breach and recover any lost data.
• Undertake a full and detailed assessment of the breach.
• Record the breach in the Company’s data breach register.
• Notify the Information Regulator where the breach is likely to result in a risk to the rights and freedoms of data subjects.
• Notify affected Data Subjects where the breach is likely to result in a high risk to their rights and freedoms.
• Respond to the breach by putting in place any further measures to address it and mitigate its possible adverse effects, and to prevent future breaches. Please see Annexure B for more information.

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

Information Officer
Name and Surname: Eugene Maree
Information Officer Registration Number:
Our Deputy Information Officer is Razina Gareeb, they are both contactable at our Head Office:
Telephone Number: 010 593 3109
Physical Address: 2
nd Floor, Lacey Oak House, Ballyoaks Office Park, 35 Ballyclare Drive, Bryanston
Email Address:

5. Consequences of Non-Adherence

Compliance monitoring will be performed regularly, and feedback will be provided to the Deputy Information Officer of Harbour Advisory (Pty) Ltd.

Action will be taken against those that do not adhere to requirements and principles stated in this policy.

6. Training and awareness

Relevant staff will receive training on what is required from them.

7. Review

This policy shall be reviewed as and when Harbour Advisory (Pty) Ltd compliance management strategy and framework change or the business strategy changes, but at least annually.


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These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged-in to that website. Below you can find a list of the services we use:


The Facebook page plugin is used to display our Facebook timeline on our site. Facebook has its own cookie and privacy policies over which we have no control. There is no installation of cookies from Facebook and your IP is not sent to a Facebook server until you consent to it. See their privacy policy here: Facebook Privacy Policy .


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We use YouTube videos embedded on our site. YouTube has its own cookie and privacy policies over which we have no control. There is no installation of cookies from YouTube and your IP is not sent to a YouTube server until you consent to it. See their privacy policy here: YouTube Privacy Policy.


This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymized tracking data to third party applications like Google Analytics. Cookies generally exist to make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser.

  • cfduid: Is used for our CDN CloudFlare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. See more information on privacy here: CloudFlare Privacy Policy.
  • PHPSESSID: To identify your unique session on the website.
  • wp-auth: Used by WordPress to authenticate logged-in visitors, password authentication and user verification.
  • wordpress_logged_in_{hash}: Used by WordPress to authenticate logged-in visitors, password authentication and user verification.
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  • wp-settings-[UID]: WordPress sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface.
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If you are not a registered client for our site, there is no personal information we can retain or view regarding yourself.

If you are a client with a registered account, your personal information can be accessed by:

  • Our system administrators.
  • Our supporters when they (in order to provide support) need to get the information about the client accounts and access.

We don’t share your data with third-parties in a way as to reveal any of your personal information like email, name, etc. The only exceptions to that rule are for partners we have to share limited data with in order to provide the services you expect from us. Please see below:


For the purpose of validating and getting your purchase information regarding licenses for our theme, we send your provided tokens and purchase keys to Envato Pty Ltd and use the response from their API to register your validated support data. See the Envato privacy policy here: Envato Privacy Policy.


Ticksy provides the support ticketing platform we use to handle support requests. The data they receive is limited to the data you explicitly provide and consent to being set when you create a support ticket. Ticksy adheres to the EU/US “Privacy Shield” and you can see their privacy policy here: Ticksy Privacy Policy.


When you submit a support ticket or a comment, its metadata is retained until (if) you tell us to remove it. We use this data so that we can recognize you and approve your comments automatically instead of holding them for moderation.

If you register on our website, we also store the personal information you provide in your user profile. You can see, edit, or delete your personal information at any time (except changing your username). Website administrators can also see and edit that information.


We use the SSL/HTTPS protocol throughout our site. This encrypts our user communications with the servers so that personal identifiable information is not captured/hijacked by third parties without authorization.

In case of a data breach, system administrators will immediately take all needed steps to ensure system integrity, will contact affected users and will attempt to reset passwords if needed.


If you have a registered account on this website or have left comments, you can request an exported file of the personal data we retain, including any additional data you have provided to us.

You can also request that we erase any of the personal data we have stored. This does not include any data we are obliged to keep for administrative, legal, or security purposes. In short, we cannot erase data that is vital to you being an active customer (i.e. basic account information like an email address).

If you wish that all of your data is erased, we will no longer be able to offer any support or other product-related services to you.


Your privacy is critically important to us. Going forward with the GDPR we aim to support the GDPR standard. ThemeREX permits residents of the European Union to use its Service. Therefore, it is the intent of ThemeREX to comply with the European General Data Protection Regulation. For more details please see here: EU GDPR Information Portal.


ThemeREX may post links to third party websites on this website. These third party websites are not screened for privacy or security compliance by ThemeREX, and you release us from any liability for the conduct of these third party websites.

All social media sharing links, either displayed as text links or social media icons do not connect you to any of the associated third parties, unless you explicitly click on them.

Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, does not create rights enforceable by third parties or require disclosure of any personal information relating to members of the Service or Site. ThemeREX bears no responsibility for the information collected or used by any advertiser or third party website. Please review the privacy policy and terms of service for each site you visit through third party links.


At times it may become necessary or desirable to ThemeREX, for legal purposes, to release your information in response to a request from a government agency or a private litigant. You agree that we may disclose your information to a third party where we believe, in good faith, that it is desirable to do so for the purposes of a civil action, criminal investigation, or other legal matter. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you, and release your information to, third parties where we believe that it is prudent to do so for legal reasons, such as our belief that you have engaged in fraudulent activities. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants.

Any passing on of personal data for legal purposes will only be done in compliance with laws of the country you reside in.


We may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will update this page accordingly and require you to accept the amendments in order to be permitted to continue using our services.