Privacy notice

• Stonehage Fleming Financial Services (Pty) Ltd, an authorised Financial Services Provider that provides advisory and intermediary family office services.
• Stonehage Fleming Investment Management (South Africa) (Pty) Ltd, an authorised Financial Services Provider that renders advisory and discretionary investment management services.
• Stonehage Fleming Investment Management Ltd, an authorised foreign Financial Services Provider based in the United Kingdom that renders discretionary and advisory investment management services.
• Stonehage Fleming Advisory Ltd, an authorised foreign Financial Services Provider based in the United Kingdom that provides advice on long-term tax planning and structuring solutions.
• Stonehage Fleming Dealing and Treasury Services (Jersey) Ltd, an authorised foreign Financial Services Provider based in Jersey that handles banking and investment administration, including cash management, deal execution and custody.
• Stonehage Fleming Consulting (Pty) Ltd, an entity providing tax and legal structuring services.
• Terra Nova Trustees (Pty) Ltd, which provides independent trustee services.
• Stonehage Fleming South Africa (Pty) Ltd, which provides finance, accounting and human resource support services to the rest of the Stonehage Fleming Group.
• Stonehage Fleming Corporate Services (Pty) Ltd, an authorised Financial Services Provider which provides Corporate Fiduciary, Corporate Governance & Secretarial, Corporate Financial Management and Structured Finance & Agency services from South Africa to related corporate clients.
• Stonehage Fleming Asset Management (Pty) Ltd, an authorised Financial Services Provider that renders advisory and discretionary investment management services.
• Stonehage Fleming Fiduciary Ltd, an authorised Financial Services Provider that provides fiduciary services.
• Stonehage Fleming Advisory (Pty) Ltd, an entity providing private client tax and legal structuring services.
• Stonehage Fleming Executors Ltd, an entity providing estate administration services.
• Stonehage Fleming Trustees (Pty) Ltd, which provides independent trustee services.
• Theseus Trustees (South Africa) (Pty) Ltd, which provides independent trustee services.

You have the following rights:

• To be notified that your personal data is being collected;
• To obtain access to, and copies of, the personal data that we hold about you;
• To require that we cease processing your personal data if the processing is causing you damage
• or distress;
• To require us not to send you marketing communications;
• To require us to erase your personal data;
• To require us to restrict our data processing activities;
• To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Information Officer using the following:

By post: 54 Glenhove Road, Melrose, Johannesburg, 2196, South Africa, or

First Floor, North Block, Waterway House, 3 Dock Road, V&A Waterfront, Cape Town, 8001, South Africa

By email: sainformationofficer@stonehagefleming.com

By telephone: +27 21 301 0800

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Regulator in South Africa or relevant supervisory authority, in your jurisdiction.

We may collect your personal data in a number of ways, for example:

• From the information you provide to us;
• When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
• From other companies in our Group;
• From publicly available sources or from third parties to whom you also provide services (for example, where those third parties pass on your details when they recommend you to us).

We may collect the following categories of personal data about you:

• Your name and your employer or employee names, company registration details, and contact information such as address, email address and telephone number;
• Identification / registration details;
• Details regarding and relating to the services you supply.

We may process personal data because it is necessary for the performance of a contract to which you are a party or to enter into a contract with you. In this respect, we use your personal data for the following:

• providing you with information about us (as relevant for your supply of services to us);
• carrying out diligence and reference checks on you or your employees before you begin to supply services to us;
• performing the contract between us.

In this respect, we may share your personal data with the following:

• Other suppliers with which we may need to interact;
• Other companies or entities within our Group;
• Our data storage providers.

We may also process your personal data because it is necessary for our legitimate interests. In this respect, we may use your personal data for the following:

• For the administration and management of our business;
• Seeking advice on our rights and obligations, such as where we require our own legal advice.

In this respect we may share your personal data with the following:

• Our advisers where it is necessary for us to obtain their advice or assistance;
• With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.

We may also process your data to comply with a legal obligation. In this respect, we may use your personal data to meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws. In this respect, we may share your personal data with the following:

• Our advisers where it is necessary for us to obtain their advice or assistance;
• Our auditors where it is necessary as part of their auditing functions;
• With relevant government agencies where we are required to do so.

We may process your data for the following reasons, provided that you have given your explicit consent at the time you provide your data to us. Where you supply your services at our premises and we need to make reasonable adjustments to our working environment to cater for your medical conditions. We may obtain or record your consent in writing, but please note that where you volunteer more sensitive personal data to us for a particular purpose, your provision of that data may itself indicate your consent for us to process it for that purpose.

Please note that if you do not agree to this or you withdraw your consent then we may not be able to make special arrangements to accommodate your condition(s).

We may need to transfer your personal data for the reasons set out elsewhere in this Privacy Notice to other Group companies located in Switzerland, the United Kingdom, Israel, Guernsey, Canada, Jersey, Liechtenstein, Luxembourg, the Isle of Man and Malta. These countries provide an adequate level of protection for your personal data.

Where we need to share your personal data with a Group company in Mauritius, Monaco or the United States, which are countries which do not provide an adequate level of protection for your personal data, we will do so using either a data sharing agreement, another available safeguard or with your explicit consent.

We will retain your personal information for as long as necessary and permitted for legal, regulatory, and legitimate business purposes. After this period, your personal data will be deleted and / or destroyed.

Version date: 11 April 2024