Privacy Policy
Last updated: June 2026 | Value Portfolio Managers (Pty) Ltd — FSP 6351. Introduction and Objective
At Value Portfolio Managers (Pty) Ltd (“VPM”), we are committed to the principles of respecting your privacy and keeping your personal information safe. We will use, collect and safeguard your personal information as set out below and in accordance with applicable laws.
- We will only collect personal information that is of legitimate interest, and which is useful and necessary for improving our products, services and your experience.
- We will never sell your personal information.
- We will never make decisions based solely on automated processing or profiling of personal information.
- We will always take the security of your personal information seriously.
This Policy applies to all areas within VPM where personal information is received and/or processed in connection with any services provided.
2. Definitions
| Term | Meaning |
|---|---|
| Applicable laws | All legislation that VPM must adhere to, including but not limited to the Protection of Personal Information Act No. 4 of 2013 (POPIA), the Financial Intelligence Centre Act No. 38 of 2001, the Collective Investment Schemes Control Act No. 45 of 2002, the Companies Act No. 71 of 2008, and the Promotion of Access to Information Act No. 2 of 2000 (PAIA). |
| Personal information | Information relating to an identifiable, living, natural person and, where applicable, an identifiable existing juristic person, including but not limited to: race, gender, sex, age, health, disability or religion; education, financial, criminal or employment history; any identifying number, e-mail address, physical address, telephone number or online identifier; biometric information; personal opinions, views or preferences; private correspondence; and your name where its disclosure reveals further information about you. |
| Processing | Any activity concerning personal information including collection, receipt, storage, retrieval, use, dissemination, merging, restriction, erasure or destruction. |
| Special personal information | Personal information concerning religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric information, or criminal behaviour. |
| We / us / VPM | Value Portfolio Managers (Pty) Ltd, a registered Financial Services Provider (FSP 635). |
| You / your | Any prospective, new, or existing client, supplier, employee, service provider, partner, and other stakeholders of VPM. |
3. Types of Personal Information We Collect
VPM will collect and use only as much personal data as is necessary to provide you with the products and services you have requested. You may provide us with your personal information when you engage with us via our website, in respect of our services, or when you communicate with us by phone, email or otherwise. Depending on the services, products or information requested, we may collect:
- Name, address, contact details, date of birth, place of birth, identity number, passport number, email address, bank details, gender, children’s information, employment details, tax number, marital status and financial information.
- Records of correspondence or enquiries (including contact form submissions from this website).
- Details of transactions and contracts.
- Details available on third-party sanctions lists.
- Special personal information, which may include images and voiceprints.
- Technical / usage data: IP address, browser type, pages visited and time of visit, collected automatically via cookies (see section 7).
We do not collect sensitive financial account details, identity numbers, or health data through this website’s contact form.
4. How We Collect Personal Information
We collect information in a variety of ways, mainly directly from you:
- Directly from you when you complete and submit our contact form, enter into agreements with us, or contact us by phone or email.
- From your appointed agent, any regulator, or other third party that may hold such information.
- From sanctions screening lists hosted by third parties.
- From other companies in our network or from publicly available sources.
- Automatically via cookies and analytics when you browse our website.
5. Why We Collect Your Personal Information and the Legal Basis
We may collect, transfer, share and otherwise process your personal information for purposes including:
- Fulfilling and providing the services, products or offerings you have requested, and notifying you of important changes to these.
- Managing your account or our relationship and complying with your instructions or requests.
- Providing your personal information to our partners responsible for the management of the various portfolios.
- Detecting and preventing fraud, money laundering and terrorist financing risk.
- Assessing and dealing with complaints.
- Operational, marketing, auditing, legal and record-keeping requirements.
- Verifying your identity and the identities of beneficial owners of entities.
- Carrying out marketing activities (where you have consented).
VPM processes personal information only on one of the following legal bases:
- Your consent.
- For the conclusion and performance of a contract.
- To comply with a legal obligation.
- To protect a legitimate interest of a data subject.
- For the proper performance of a public law duty.
- For the pursuance of a legitimate interest of VPM or a third party.
6. How We Keep Your Information Secure
All information you provide is stored securely using a layered security approach. Electronic information — including databases and files — is held in a secure location on-site, and we take appropriate security and technical measures to protect such information from unauthorised access. All electronic transmission of information is encrypted to prevent interception.
Our layered security approach includes:
- Encryption: AES-256 for data at rest; TLS 1.2+ for data in transit.
- Access Controls: Role-based access, least-privilege principle, and multi-factor authentication.
- Network Security: Firewalls, intrusion detection/prevention systems, and regular vulnerability scans.
- Physical Security: Restricted access to server rooms, CCTV monitoring, and secure disposal of paper records.
- Monitoring & Logging: Continuous monitoring, audit logs, and anomaly detection.
- Data Minimisation: Collect only necessary data; anonymise or pseudonymise where possible.
- Incident Response: Documented breach response plan with regulator and client notification protocols.
7. Disclosure of Your Personal Information
We will only disclose your personal information when necessary, in accordance with applicable laws and regulations. We may disclose your information to:
- Any person with legal or regulatory power that requires such disclosure on legal grounds.
- Service providers engaged by us to help us run our business and effectively perform our services.
- Agents, partners or other entities for purposes described in this privacy notice.
- Other persons as agreed with a client or as required or expressly permitted by applicable law.
Some of these third parties may be situated outside South Africa. When such transfers occur, we will take appropriate steps to ensure there is an adequate level of protection for personal information (including a legal agreement and appropriate security measures) in accordance with applicable legal requirements. Third parties are permitted to use personal data only for the purposes we have identified and are not permitted to further share the data without our express permission.
8. Retention of Your Personal Information
We hold your personal data on our systems for as long as is necessary to provide the services and as required by law. This is ordinarily 5 (five) years after the business relationship has been terminated, in order to allow us to refer to your information in correspondence with you or relating to legal or regulatory proceedings. Under FAIS, transaction records are kept for a minimum of five years.
9. Your Rights (POPIA)
You have the following rights in relation to how we process your personal information:
- Right of access — you have the right to know if we are using your information and, if so, the right to access it and receive information about how we are using it.
- Right of correction — you have the right to require us to rectify any errors in and/or update information we hold about you.
- Right to deletion — you have the right to require us to delete your information in certain circumstances if our continued use is not justified.
- Right to restrict processing — in some circumstances you may be entitled to limit the purposes for which we can use your information.
- Right to object to the processing of your information for direct marketing purposes.
- Right to lodge a complaint with the Information Regulator of South Africa: www.justice.gov.za/inforeg/ | POPIAComplaints@inforegulator.org.za
Requests will be processed within 30 days in line with POPIA. To exercise any of these rights, please contact our Information Officer (see section 12).
7a. Cookie Policy
Our website uses cookies — small text files stored on your device — to make our site work properly and to understand how visitors use it.
| Cookie | Type | Purpose | Duration |
|---|---|---|---|
| PHPSESSID | Strictly necessary | Maintains your session for the contact form (CSRF protection). Not used for tracking. | Session |
| _ga | Analytics | Google Analytics — distinguishes users for website usage statistics. | 2 years |
| _gid | Analytics | Google Analytics — distinguishes users (short-term). | 24 hours |
| _gat | Analytics | Google Analytics — throttles request rate. | 1 minute |
7b. How to Manage Cookies
You can control or delete cookies at any time through your browser settings:
Please note that disabling cookies may affect the functionality of our contact form. To opt out of Google Analytics tracking specifically, use the Google Analytics Opt-out Browser Add-on.
8a. Do Not Track (DNT)
Some browsers allow you to set a “Do Not Track” (DNT) signal. Our website currently does not alter its data collection behaviour in response to DNT signals because there is no universally accepted standard for how websites should respond to them. We encourage you to use the cookie opt-out options described in section 7b above.
9a. Children’s Online Privacy
Our website and investment management services are directed exclusively at adults (18 years and older). We do not knowingly collect personal information from persons under 18. If you believe we have inadvertently collected data from a minor, please contact us immediately and we will delete it without delay.
10. Changes to this Privacy Notice
We will update this Privacy Notice when necessary to reflect changes in the law, our data practices, or the services we offer. When we make an update we will amend the date of this notice — you are advised to check this page periodically. We may also notify you in other ways from time to time about the processing of your personal information. Where changes are material, we will make reasonable efforts to notify you.
11. Complaints
If you wish to make a complaint about how we have handled your personal information, you can contact our Information Officer (see section 12 below). If you are not satisfied with our response, or believe we are not processing your personal information in accordance with applicable law, you can lodge a complaint with the Information Regulator of South Africa:
- Email: POPIAComplaints@inforegulator.org.za
- Website: www.justice.gov.za/inforeg/
12. Contact Our Information Officer
Questions, comments and the exercise of your data rights regarding this Privacy Notice and your personal information are welcomed and should be addressed to our Information Officer:
- Value Portfolio Managers (Pty) Ltd
- 15 Boeing Road West, Bedfordview, Johannesburg, 2007
- Tel: +27 11 622 7692 / +27 11 626 9900
- Email: valuepm@worldonline.co.za / musa@valueportfolio.co.za
- Web: www.valueportfolio.co.za/#contact
Value Portfolio Managers (Pty) Ltd is an Authorised Financial Services Provider. FSP number 635.