Privacy Policy

Scope of this policy

This is one corporate Privacy Policy. It applies to:

• this website;
• services provided by MyGlobalCFO (Pty) Ltd in South Africa; and
• services provided by MyGlobalCFO Pty Ltd in Australia.

The entity that provides the relevant service is responsible for personal information collected in connection with that service and jurisdiction.

This policy describes the types of personal information that may be collected. It does not set out every detail that may be requested during a particular service engagement.

We may also provide additional privacy collection notices when we collect personal information in connection with particular services.

For country-specific information, see the South African POPIA disclosures and Australian privacy disclosures below.

South African POPIA disclosures

Website and Email Privacy Statement of MyGlobalCFO (Pty) Ltd

We collect, process and store information of data subjects as a usual course of our business. We need to continue doing so whilst being compliant with POPI (the Protection of Personal Information Act). We are fully compliant with POPI and this statement serves as our disclosure to Data Subjects and other interested parties, in broad terms, of how we achieve that. Data Subjects are defined as a natural or legal person whose information is collected, processed or stored.

Why?

• As a company that provides data subjects with a service or with data interaction for a lawful reason, we need to gather certain information to be able to do so and in a certain manner.
• The information we collect will depend on the reasons for which it is collected and used. This might differ in our various interactions. We will only collect information that we need for that particular purpose as agreed upon and no more than necessary. We’ll also tell Data Subjects what information they need to provide to us and what information is optional.

How?

• We have a fully developed POPI compliance framework in place which comprises impact assessments and a POPI Policy, among others.
• We will usually obtain information from a Data Subject directly via various different means but may from time to time also obtain publicly available information.
• Data Subject information may be processed by third parties like regulators, our software providers or other suppliers to ensure Data Subjects get great service and may be transferred cross border, for instance where we use cloud services to store data or if one of our own service providers are situated overseas.

What?

From time to time, we may collect some of the information below of natural or legal persons, which is defined as personal information in terms of POPI. However, our specific interaction with the Data Subject will detail what information we need exactly:

• information relating to the education or the medical, financial, criminal or employment history of the person;
• any identifying number, symbol, email address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
• the biometric information of the person;
• the personal opinions, views or preferences of the person;
• correspondence sent by the person 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 the person; and
• the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person;
• information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person.
• personal information concerning a child.

Data Subject Rights

• Data subjects have a right not to share the information as set out above but in that instance, we cannot offer Data Subjects our services. They may contact us to enquire what information of theirs we hold. They also have the right to correct their information or to request us to delete the information, unless the law states that we must hold the information. They have a right to revoke this consent.  If a Data Subject would like to contact us in relation to Data Subject information, please see our contact details on our website.

Enquiries or Complaints

• Anyone can approach us on our contact details on our website where you found this notice to speak to our Information Officer or to submit any data queries or complaints.
• You have the right to lodge a complaint to the Information Regulator at:  POPIAComplaints@inforegulator.org.za or search their office on the internet at inforegulator.org.za .

Consent

• By visiting our website and communicating electronically with us, the Data subject consents to the processing, including transfer of his Personal information as set out in this Notice.

Promotion of Access to Information Manual

• Download our Promotion of Access to Information Manual here.

Australian privacy disclosures

This section applies to personal information handled by MyGlobalCFO Pty Ltd in connection with Australian services. It explains the information we collect and hold, how we use and disclose it, and your access, correction and privacy complaint options.

Providing information

Where lawful and practicable, you may deal with us anonymously or using a pseudonym. Identification may be required by law or necessary to provide a particular service. We explain the information required at the point of collection; if necessary information is not provided, we may be unable to respond to an enquiry or provide that service.

Service-specific collection notices explain the relevant collection circumstances. This public policy does not replace those notices or the client process.

Personal information we collect

The personal information we collect depends on how you deal with us. We aim to collect only information that is reasonably required for the relevant enquiry or service.

Typical categories include:

• identity and contact information;
• enquiry and service-related information;
• financial and financial-advice information, where relevant;
• transaction, compliance and verification information, where required;
• communications with us; and
• website and technical information.

Where we provide financial advice or related services, we may collect financial and financial-advice information reasonably required to understand your circumstances, objectives and preferences and to provide those services.

Identity verification during onboarding

As part of identity verification for Australian services, we may collect a selfie and a photograph of your identification document for comparison. MyGlobalCFO Pty Ltd retains copies in the onboarding provider’s system. These are collected during service onboarding, not through the public website forms.

How we collect personal information

We usually collect personal information directly from you, including through website forms, email, telephone, meetings and other correspondence.

We may also collect personal information:

• during onboarding or while providing a service;
• from an authorised representative;
• from third parties you have authorised, such as a professional adviser or financial institution, where relevant to the service; and
• from public or regulatory sources where appropriate.

We hold personal information electronically in systems used by us and by service providers that support our operations.

How we use personal information

We use personal information for the purpose for which it was collected, including to:

• respond to enquiries;
• provide and administer services;
• assess client needs where relevant;
• satisfy legal, regulatory, compliance, AML/KYC and record-keeping obligations;
• communicate with clients;
• process transactions where relevant;
• manage complaints;
• prevent fraud and protect our systems;
• operate, secure and improve the website; and
• carry out internal administration.

Personal information handled by MyGlobalCFO Pty Ltd may be processed where permitted or required by applicable law. We do not treat a visit to this website as consent to all processing described in this Australian section.

Sharing personal information

We may share personal information with other parties where that is needed for the purposes described in this policy, including:

• MyGlobalCFO personnel and contractors;
• the relevant MyGlobalCFO entity;
• financial institutions and product or service providers, where necessary;
• professional advisers;
• technology, hosting, communications and security providers;
• identity or compliance providers, where required;
• regulators, government bodies and law enforcement, where legally required; and
• other parties where you have authorised the disclosure, or where disclosure is required or permitted by law.

Overseas disclosure

Where applicable, personal information relating to Australian services may be disclosed to or accessed by recipients in South Africa. This does not mean every client’s information is transferred overseas.

Where Australian privacy requirements concerning overseas disclosure apply, we take reasonable steps appropriate to the circumstances to protect personal information.

Security

We take reasonable technical and organisational measures designed to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

No electronic system can be guaranteed completely secure, and internet transmission may be interrupted or subject to error.

Retention

We retain personal information for as long as reasonably necessary for the relevant purpose, and as required by applicable legal, regulatory and professional obligations.

Certain records relating to Australian personal financial advice may be required to be retained for at least seven years after the advice is provided. That does not mean every piece of personal information is automatically retained for seven years.

Where personal information is no longer required, and no retention obligation applies, we take reasonable steps to destroy or de-identify it.

Access and correction

If MyGlobalCFO Pty Ltd holds your personal information, you may request access to it, and request correction where it is inaccurate, out of date, incomplete, irrelevant or misleading, subject to applicable legal exceptions.

Send requests through info@myglobalcfo.com or the Contact page. We may need to verify your identity before responding. If we cannot grant a request, we will explain the reason where required by law.

Privacy complaints

If you have a privacy concern, contact MyGlobalCFO Pty Ltd through info@myglobalcfo.com or the Contact page so we can investigate and respond within a reasonable time.

If the matter remains unresolved, you may lodge a privacy complaint with the Office of the Australian Information Commissioner (OAIC), subject to its complaint process.

Website forms and technical information

Website forms

Our public website forms collect only the information needed to respond to an enquiry.

The contact form typically asks for your name, email address, selected service and message.

The Foreign Exchange enquiry form typically asks for your full name, email address, destination country, confirmation that the destination bank account is in your own name, and an estimated annual Rand amount.

Those forms do not collect South African identity numbers, passport details, tax numbers or FICA documents. Where that information is required, it is collected later through the appropriate onboarding process.

Website and technical information

When you visit this website, limited technical information may be recorded in order to operate and secure the site. That may include an IP address, browser and device information and pages requested.

Cookies, security technologies and analytics

WordPress and related essential technologies may use cookies or similar tools where needed to operate, secure or administer the website — for example when a person is logged in.

Public forms use Cloudflare Turnstile to help prevent spam and abuse. Security and anti-spam technologies may therefore operate as required.

This website does not currently use Google Analytics 4, Google Tag Manager, advertising pixels or behavioural advertising trackers.

Third-party websites

This website may include links to third-party websites and to separate product portals. Those sites have their own privacy practices, and MyGlobalCFO is not responsible for them.