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1. Introduction

Gemoedsrus.co.za ("Gemoedsrus", "we", "us", or "our") is a trading name of RoxWealth (Pty) Ltd, a licensed Financial Services Provider (FSP No. [Number]) authorised by the Financial Sector Conduct Authority (FSCA) of South Africa. We are committed to protecting the privacy and personal information of our clients, website visitors, and users in accordance with the Protection of Personal Information Act, 2013 (POPIA) and all applicable South African legislation.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you interact with our website, our AI assistant "Frik", or our services.

2. Responsible Party

For purposes of POPIA, the responsible party is:

3. Personal Information We Collect

We may collect the following categories of personal information depending on how you interact with us:

3.1 Information You Provide Directly

• Identity information: Full name, ID number, date of birth, gender
• Contact information: Email address, phone number, physical address
• Financial information: Current insurance provider, policy details, income range (for needs analysis)
• Employment information: Occupation, employer name (where relevant to insurance assessment)
• Communication records: Messages sent via our contact forms, chat conversations with Frik, email correspondence, and phone call recordings (where applicable)

3.2 Information Collected Automatically

• Device and browser information: IP address, browser type, operating system, screen resolution
• Usage data: Pages visited, time on site, click interactions, referral source
• Cookies and similar technologies: As described in Section 9 below

3.3 Information from Third Parties

• Insurance providers: Policy details or quotes received from PPS, Liberty Life, Sanlam, Hollard, or other partnered insurers
• Public sources: Information available in public registries or databases where relevant

4. Purpose of Processing

We process your personal information for the following purposes:

• Providing financial intermediary services, including facilitating insurance quotes, policy reviews, renewals, and new applications
• Conducting a financial needs analysis as required by the Financial Advisory and Intermediary Services Act (FAIS)
• Communicating with you regarding your enquiries, appointments, and policy matters
• Improving and personalising our AI assistant (Frik) to better serve your needs
• Complying with legal and regulatory obligations, including FAIS, FICA (Financial Intelligence Centre Act), and POPIA
• Preventing fraud and ensuring the security of our systems
• Marketing our services (only with your consent)
• Internal record keeping and business administration

5. Legal Basis for Processing

We process your personal information on one or more of the following legal grounds under POPIA:

• Consent: Where you have given us explicit consent (e.g., submitting a contact form, opting in to marketing)
• Contract: Where processing is necessary to fulfil our obligations under an agreement with you
• Legal obligation: Where we are required by law to process information (e.g., FICA, FAIS record-keeping)
• Legitimate interest: Where processing is in our legitimate business interest and does not prejudice your rights

6. Sharing of Personal Information

We may share your personal information with the following categories of recipients:

• Insurance providers: PPS, Liberty Life, Sanlam, Hollard, and other authorised insurers for the purpose of obtaining quotes or processing applications
• Technology service providers: Our development and hosting partners who assist in maintaining our website and systems, subject to appropriate data processing agreements
• Regulatory authorities: The FSCA, Information Regulator, or other authorities where required by law
• Professional advisors: Auditors, legal advisors, or compliance officers where necessary

We do not sell your personal information to third parties. We will not share your information with any party not listed above without your prior consent, unless required by law.

7. Cross-Border Transfer

Our website is developed and maintained by a technology team based in India. This may involve the transfer of certain technical data (such as website analytics) to systems outside of South Africa. Where personal information is transferred across borders, we ensure that adequate safeguards are in place as required by Section 72 of POPIA, including contractual data protection obligations with our service providers.

8. Retention of Personal Information

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Specific retention periods include:

• Client records (FAIS): Minimum 5 years from date of last transaction or advice
• FICA records: Minimum 5 years from the end of the business relationship
• Marketing consent records: Until consent is withdrawn
• Website analytics: 26 months (standard analytics retention)

After the applicable retention period, personal information will be securely destroyed or de-identified.

9. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to improve functionality and user experience. Types of cookies used include:

• Essential cookies: Required for basic website functionality (e.g., theme preference, session management)
• Analytics cookies: Used to understand how visitors interact with our website (e.g., Google Analytics)
• Functional cookies: Remember your preferences (e.g., dark/light mode)

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

10. AI Assistant (Frik) and Your Data

Frik is an AI-powered assistant designed to help you explore insurance options and facilitate communication with our team. When interacting with Frik (via chat or phone):

• Conversations may be recorded or logged for quality assurance and service improvement
• Information you provide to Frik is treated with the same confidentiality as information provided directly to a human advisor
• Frik does not provide regulated financial advice — it facilitates the process and connects you with our licensed advisors
• AI-generated responses should be verified for accuracy, particularly regarding policy terms and pricing

11. Your Rights Under POPIA

As a data subject, you have the following rights under the Protection of Personal Information Act:

• Right of access: You may request confirmation of whether we hold your personal information and request a copy
• Right to correction: You may request that inaccurate or incomplete personal information be corrected
• Right to deletion: You may request that your personal information be deleted where it is no longer necessary
• Right to object: You may object to the processing of your personal information for direct marketing purposes
• Right to restrict processing: You may request that processing be restricted in certain circumstances
• Right to lodge a complaint: You may lodge a complaint with the Information Regulator of South Africa

To exercise any of these rights, please contact our Information Officer at privacy@gemoedsrus.co.za.

12. Security Measures

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include SSL/TLS encryption for data in transit, access controls, regular security assessments, and secure data storage practices.

While we take all reasonable steps to protect your information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

13. Direct Marketing

We will only send you direct marketing communications (such as newsletters, promotional offers, or insurance product information) with your prior consent. You may withdraw your consent at any time by contacting us at privacy@gemoedsrus.co.za or by using the "unsubscribe" link in any marketing communication.

14. Children's Information

Our services are not directed at children under the age of 18. We do not knowingly collect personal information from children. If you believe a child's information has been provided to us, please contact us immediately so that we can take appropriate action.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. The "Last Updated" date at the top of this page will be revised accordingly. We encourage you to review this policy periodically.

16. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us:

You may also lodge a complaint with the Information Regulator of South Africa: