Privacy Policy for Analytics Consulting

Introduction
This document sets forth the Portfolio Analytics Consulting Privacy Policy (the "Privacy Policy") for this website, www.analyticsconsultingco.za (the "Site"). If you have objections to the Privacy Policy, you should not access or use this Site. This Privacy Policy does not govern privacy practices associated with offline activities or any other websites. Portfolio Analytics Consulting (Pty) Ltd is a provider of discretionary investment management services to individuals, institutions and retirement funds. Portfolio Analytics Consulting utilises the web for both marketing and service delivery. Portfolio Analytics Consulting supports ethical use of personal information and subscribes to the privacy policy herein.

Changes in Privacy Policy
All "personal information" ("personal information" is defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains) that we collect and maintain will be subject to the version of the Privacy Policy in effect at the time of such collection. Portfolio Analytics Consulting reserves the right to change the Privacy Policy from time to time at its sole discretion, and will provide notice of material changes on the home page of the Site. If as the result of such changes, you want to alter the ways in which Portfolio Analytics Consulting is allowed to use your personal information, you can do so by following the procedure described below in the section titled "Updating your personal information and privacy preferences." You will be deemed to have been made aware of, and will be subject to, the changes to the Privacy Policy by your continued use of the Site after such notice has been posted for thirty (30) days. However, if Portfolio Analytics Consulting sells assets to another entity, or is acquired by, or merged with, another entity, Portfolio Analytics Consulting may provide to such entity customer information that is related to that part of our business that was sold to or merged with the other entity without your consent.

Collection of personal information
As a visitor to this Site, you can engage in many activities without providing any personal information. In connection with other activities, Portfolio Analytics Consulting may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, Portfolio Analytics Consulting may ask that you provide us personal information, such as your first and last name, mailing address (including postal code), e-mail address, employer, job title and department, telephone and facsimile numbers, and other personal information. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.

How your personal information is used
Portfolio Analytics Consulting collects your information in order to record and support your participation in the activities you select. If, for example, you subscribe to a service, the information is used to register your subscription preferences and rights, if any, to support or other benefits that may be made available to registered subscribers. Your personal information is also used to keep you informed about other products and services of Portfolio Analytics Consulting and selected third parties if you have so opted to receive such communications. Portfolio Analytics Consulting may collect information about the use of the Site, such as the types of services used and how many users we receive daily. This information is collected in aggregate form, without identifying any user individually. Portfolio Analytics Consulting may use this aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes.

Your choices with respect to personal information
Portfolio Analytics Consulting recognises and appreciates the importance of responsible use of information collected on this Site. Except in the particular circumstances described in this Privacy Policy, Portfolio Analytics Consulting will not provide your name to other companies or organizations without your consent. There are other instances in which Portfolio Analytics Consulting may divulge your personal information. Portfolio Analytics Consulting  may provide your personal information if necessary, in Portfolio Analytics Consulting ' good faith judgment, to comply with laws or regulations of a governmental or regulatory body or in response to a valid subpoena, warrant, or order or to protect the rights of Portfolio Analytics Consulting  or others.

Privacy-related inquiries and complaints
Portfolio Analytics Consulting takes its users' privacy concerns seriously. If you believe that Portfolio Analytics Consulting has not complied with this Online Privacy Policy with respect to your personal information or you have other related inquiries or concerns, you may write to the Chief Operating Officer of Portfolio Analytics Consulting at the following address: PO Box 13, Cape Town, 8000. In your letter, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that the Portfolio Analytics Consulting Privacy Policy has not been complied with. We will investigate your inquiry or complaint promptly. Please note that Portfolio Analytics Consulting is not responsible for the content or privacy practices of non-Portfolio Analytics Consulting websites to which this Site may link. You should review the privacy policy of such sites before using the sites.

Terms and conditions

1. Ownership & Copyright
Copyright in all website content ("content") made available through this website is protected by intellectual property law. Unauthorised copying, reproduction, retransmission, distribution, dissemination, sale, publication, broadcast or other use, or exploitation of this material will constitute an infringement of such protection.The copyright in all material of Portfolio Analytics Consulting (Pty) Ltd published on this website shall continue to vest in Portfolio Analytics Consulting. Your access to this website, and the information contained on it, does not in any way convey or transfer any right in or to the intellectual property rights of Portfolio Analytics Consulting. If you so wish, Portfolio Analytics Consulting  hereby authorises you to view, copy, download to a local drive, print and distribute the content of this website, or any part thereof, if:
• The content is used for personal information purposes only;
• The content is used for non-commercial purposes. You are expressly prohibited from incorporating any material of Portfolio Analytics Consulting ' proprietary material from this website in any other work, publication or website;Any reproduction of Portfolio Analytics Consulting ' content from this website or portion thereof must include this notice in its entirety; and
• The trademarks, logos and service marks may not be used without the written permission of the owner thereof.

2. Content
This website is only intended to provide general information regarding Portfolio Analytics Consulting and its products and services and it is not intended to provide exhaustive information of any subject dealt with.The information in this website including, without limitation, all research, opinions or other content is therefore not intended nor does it constitute financial, accounting, tax, legal, investment, consulting or other professional advice or services. Before making any decision or taking any action, which might affect your personal finances or business, you should consult your own professional advisors.This website could include technical, typographical or other inaccuracies and you are urged to contact Portfolio Analytics Consulting to confirm all information contained on these pages prior to placing reliance thereon. Portfolio Analytics Consulting expressly reserves the right, in its sole and absolute discretion, to alter or amend any criteria or information set out in this website without notice.

3. No Offer
No information or content contained on these pages should be construed as an offer by Portfolio Analytics Consulting. All services offered by Portfolio Analytics Consulting are subject to signature of the appropriate application forms and other documentation relating thereto and are governed by the standard terms and conditions of Portfolio Analytics Consulting in respect thereof and Portfolio Analytics Consulting shall not be bound in any manner until a formal written agreement has been entered into. Portfolio Analytics Consulting reserves the right to reject at its discretion any application submitted for services contained on this website.

4. Transmission of Information
Information transmitted via the Internet, including e-mail, is susceptible to monitoring and interception. You are discouraged from transmitting to Portfolio Analytics Consulting any information, which may be confidential, proprietary or sensitive. You shall bear all risk of transmitting such information in this manner and under no circumstances will Portfolio Analytics Consulting  be liable for any loss, harm or damage suffered by you as a result thereof. Portfolio Analytics Consulting reserves the right to request independent verification of any information transmitted via email.

5. Links to Third Party Sites
Portfolio Analytics Consulting may provide hypertext links to websites on the Internet which are operated by third parties. Visitors are advised to use caution and discretion when searching or accessing such links. Under no circumstances does Portfolio Analytics Consulting take responsibility for the content and/or services or products offered on third party websites that may be linked to this website and Portfolio Analytics Consulting gives no warranty, guarantee and makes no representation in respect of such linked websites.

6. Disclaimer
Portfolio Analytics Consulting strives to ensure that the content on this website is up to date and accurate. Whilst all care is taken by Portfolio Analytics Consulting in the preparation of the content of this website, the content is provided "as is" and no warranty, express or implied, is given or made by Portfolio Analytics Consulting. If Portfolio Analytics Consulting becomes aware that the information on the website is inaccurate or out of date it will use its reasonable endeavours to remove it or take other appropriate action. Portfolio Analytics Consulting reserves the right to alter or amend any information on this website without notice.The information, research, opinions and recommendations contained in this website are for general information purposes only, and must be interpreted solely as statements of opinion and not statements of fact. The information on this site is not intended to and does not constitute solicitation, recommendation or advice, and Portfolio Analytics Consulting does not purport to act in any way as a financial advisor. Portfolio Analytics Consulting accepts no liability for or in any respect of any direct, indirect or consequential liability, loss or damage of any kind or nature, howsoever arising, from the reliance on, or use of, information provided on this website.The website may contain links to other websites, for information purposes, which are not under the control of and are not maintained by Portfolio Analytics Consulting. Portfolio Analytics Consulting shall not be responsible for any loss or damage suffered by you as a result of using the links provided on the website.The copyright and all other rights in the information on this website is owned by or licensed to Portfolio Analytics Consulting. Access to and use of the website is subject to these terms and all applicable laws. You are invited to browse the website for your personal information, education and communication about Portfolio Analytics Consulting. You are prohibited from copying, reproducing, modifying, distributing, republishing, displaying, posting or transmitting any part of the website without the permission of Portfolio Analytics Consulting. You may view or print individual pages only for your own personal, non-commercial use provided you keep intact all copyright and other proprietary notices.

7. Risk & No Liability
Your use of this website and the information contained therein is entirely at your own risk and you assume full responsibility in respect of any loss or damage resulting from the use thereof. Neither Portfolio Analytics Consulting , its affiliated companies, holding company, subsidiaries or subsidiaries of its holding company, or their officers, agents, consultants or employees shall be liable for any direct, consequential or indirect loss or damages suffered by a visitor or any other person relating to the use of this website or the information contained therein.The visitor hereby indemnifies Portfolio Analytics Consulting and its suppliers from and against any and all losses, liability, cost or damages suffered or incurred by a visitor or any other person arising out of or in connection with the use of the website or any other website which can be accessed from this website, however such loss or liability may occur, and whether such loss or liability is foreseeable, financial, personal, consequential, incidental or otherwise.

8. Jurisdiction
These terms and conditions shall be governed by and construed in accordance with the laws of the Republic of South Africa.

9. Unit Trust Disclaimer
Figures quoted are from Morningstar for a lump sum investment, using NAV-NAV figures net of fees with income distributions reinvested on the ex-dividend date. Annualised performance quoted is the average return per year over the period. Collective Investment Schemes in Securities (CIS) prices are calculated on a Net Asset Value (NAV) basis, which is the total value of all assets in the Fund, including any income accrual and less all permissible deductions in terms of the Act, divided by the number of participatory interests in issue. Permissible deductions include brokerage, MST, auditor’s fees, bank charges, trustee fees and service charges of the manager. Different classes of participatory interests apply to certain portfolios and are subject to different fees and charges. Performance is shown for the most expensive class of the portfolio and individual investor performance may differ as a result of initial fees, actual investment date, date of any subsequent reinvestment and any dividend withholding tax. A schedule of fees, charges and maximum commissions is available on request from the manager. The annual management fee is levied monthly on the daily value of the Fund, and no performance fees are charged. Commission and incentives may be paid and if so, would be included in the overall costs.CIS are traded at ruling prices and can engage in scrip lending and borrowing. Transaction cut-off time is at 14h00 daily, and the Fund is valued daily at 15h00 or 24h00 using forward pricing. Fund prices are published each business day at www.cicollective.co.za and in select media publications. CIS are generally medium- to long-term investments. The value of participatory interests may go down as well as up and past performance is not necessarily a guide to the future. The manager does not provide any guarantee with respect to the capital or the return of the portfolios. Fluctuations or movements in exchange rates may cause the value of underlying international investments to go up or down.The portfolios may be closed to new investments at any time in order to be managed in accordance with its mandate.Ci Collective Investments (RF) (Pty) Limited’s trustee is FirstRand Bank Limited.Ci Collective Investments (RF) (Pty) Limited is an associate member of the Association for Savings & Investment SA (ASISA) and is registered under the CIS Control Act.

Regulation and Compliance
Portfolio Analytics Consulting is a licensed discretionary financial services provider and our business is regulated by the Financial Sector Conduct Authority (FSCA).Portfolio Analytics Consulting is committed to the Treating Customers Fairly (“TCF”). For further information on the TCF outcomes, please contact us directly.

Governing Law
• Financial Advisory and Intermediary Services Act, No 37 of 2002 ("FAIS")

Portfolio Analytics Consulting is an authorised financial services provider in terms of the Financial Advisory and Intermediary Services Act No. 37 of 2002 (FAIS). FSP number 18490. (Category II)

• Collective Investments Scheme Control Act, no 45 of 2002 ("CISCA")
Ci Collective Investments (RF) (Pty) Limited offers a range of institutional unit trust portfolios to meet the investment needs of its investors.

• Financial Intelligence Centre Act, no 38 of 2001 ("FICA")
As an accountable institution, we are required to comply with FICA and other anti-money laundering legislation such Protection of Constitutional Democracy Against Terrorist and Related Activities Act, No 33 of 2004 ("POCDATARA"). FICA requires us to establish and verify the identities of our client according to the ‘Know Your Client' provision of the Act, prior to transacting. In addition, FICA requires any suspicious transactions to be reported to the Financial Intelligence Centre.

• Securities Services Act, No 36 of 2004 ("SSA")The Securities Services Act replaced the Stock Exchanges Control Act, 1985, the Financial Markets Control Act, 1989, the Custody and Administration of Securities Act, 1992 and the Insider Trading Act, 1998. Apart from consolidating the above Acts, it also strives to maintain a healthy balance between investor protection and the enhancement of international competitiveness of securities services in South Africa.

• Promotion of Access to Information Act, no 2 of 2000
As per Section 51 of The Promotion of Access to Information Act No. 2 of 2000, please contact us directly regarding the procedures to be followed in requesting further information from us (for the purpose of exercising or protecting rights).

Corporate Governance
In terms of good corporate governance and in addition to complying with our primary legislation, Portfolio Analytics Consulting adheres to the following internal policies:
Code of Conduct Complaints handling and resolution Conflicts of Interest Management Policy Gifting - both receiving and giving Our internal compliance team is responsible for monitoring the following:Regulation compliance Mandate compliance Pre-trade and post-trade compliance Policy compliance Business Continuity Risk Management Portfolio Analytics Consulting has outsourced its compliance to Moonstone (Pty) Ltd.  Moonstone ensures overall compliance in terms of our primary legislation and keeps Portfolio Analytics Consulting abreast of legislative changes.

Institutional Administration
Our institutional administration is outsourced to Curo Fund Services.

Retail Administration
Our retail administration is outsourced to Silica Financial Administration Solutions (Pty) Limited.