PRIVACY (POPIA) POLICY
Version date: March 2026 | Henceforward (Pty) Ltd | Reg No 2020/491620/07
1. INTRODUCTION
⦁ Henceforward (Pty) Ltd (Registration No 2020/491620/07) is a Graviton Partner. Our advisers are appointed on the Graviton Wealth Management licence (FSP 8772), an authorised Financial Services Provider. Graviton Wealth Management is a subsidiary of Sanlam Investments, itself part of the Sanlam Limited Group. Graviton’s registered address is 55 Willie van Schoor Avenue, Tygervalley, Bellville, 7530.
⦁ As a financial services firm, Henceforward is obliged to comply with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and all other applicable privacy and data protection legislation.
⦁ POPIA requires Henceforward to inform clients as to how their Personal Information is collected, used, disclosed, retained and destroyed.
⦁ Henceforward is committed to protecting our clients’ privacy and ensuring that Personal Information is used appropriately, transparently, securely and in accordance with applicable law.
⦁ This Policy sets out how Henceforward deals with Personal Information and the purposes for which it is used. It is published on our website and is available on request.
⦁ POPIA defines “Personal Information” as information relating to an identifiable, living, natural person (and, where applicable, an identifiable, existing juristic person). This includes, but is not limited to, your name, identity number, contact details, financial information and any special personal information (such as health or biometric data).
⦁ Where Sanlam’s broader privacy practices are relevant — particularly in respect of processing that occurs within the Sanlam Group’s infrastructure — clients may also refer to the Sanlam Group Privacy Notice, available at www.sanlam.co.za.
2. THE PERSONAL INFORMATION WE COLLECT
⦁ Henceforward collects and processes Personal Information relevant to clients’ financial planning needs. The type of information collected will depend on the purpose for which it is required and will be processed for that purpose only. We will inform clients, wherever possible, which information is required and which is optional. Examples of Personal Information we may collect include, but are not limited to:
- Identity and personal details: full name, identity number, date of birth, nationality, marital status, number of dependants and tax number;
- Contact details: residential and postal address, email address and telephone number;
- Financial information: description of assets, liabilities, income, expenses, investments and retirement provisions;
- Estate and legal information: details of wills, trusts and estate planning structures; and
- Any other information required to conduct an accurate financial planning needs analysis.
⦁ Henceforward may also collect and process Personal Information for communication purposes, to ensure our services remain relevant to clients and prospective clients.
⦁ We have agreements in place with all third-party service providers, platforms and product suppliers to ensure mutual compliance with privacy and data protection obligations. Our suppliers are subject to the same regulatory requirements as Henceforward.
⦁ We may supplement information provided by clients with information received from other sources in order to provide a more consistent and accurate service.
⦁ For the purposes of this Policy, “client” includes both existing and prospective clients.
3. HOW WE USE YOUR PERSONAL INFORMATION
⦁ Personal Information will only be used for the purpose for which it was collected and agreed. This may include:
- Providing financial planning advice and ongoing wealth management services;
- Conducting a needs analysis and recommending appropriate financial products and strategies;
- Confirming, verifying and updating client details;
- Detecting and preventing fraud, money laundering or other unlawful activity;
- Conducting market or client satisfaction research;
- Audit, record-keeping and compliance purposes;
- Legal proceedings or compliance with legal obligations; and
- Communicating regulatory or service-related matters affecting clients.
⦁ In terms of POPIA, Personal Information may only be processed if one or more of the following conditions are met:
- Client consent — consent is obtained during the introductory and needs analysis stages of our engagement;
- Necessary for financial planning — accurate analysis of a client’s financial planning needs requires certain Personal Information;
- Legal obligation — the Financial Advisory and Intermediary Services Act (“FAIS”) requires FSPs to conduct a needs analysis and obtain client information in order to provide appropriate advice; and
- Legitimate interest — processing is necessary for the legitimate interests of Henceforward and its clients in delivering sound financial planning outcomes.
4. DISCLOSURE OF PERSONAL INFORMATION
1. We may disclose Personal Information to product providers, platforms and insurers whose services or products clients elect to use. All such parties are contractually bound to comply with confidentiality and privacy requirements.
2. Personal Information may be shared with Graviton Wealth Management and, where necessary for operational or regulatory purposes, with Sanlam Investments or other entities within the Sanlam Group. Such sharing is limited to what is required for the purposes described in this Policy.
3. We may share or obtain client information from third parties as described in section 2.4 above.
4. We may disclose Personal Information where we are legally obliged or entitled to do so, including to regulators such as the Financial Sector Conduct Authority (“FSCA”) or Prudential Authority (“PA”).
5. SAFEGUARDING YOUR PERSONAL INFORMATION
1. Henceforward is committed to protecting the integrity and confidentiality of Personal Information. We continuously review our security controls and processes to ensure that Personal Information is kept secure and protected against unauthorised access, loss or disclosure.
2. Third parties contracted to process Personal Information on our behalf are required to apply appropriate security, privacy and confidentiality measures.
3. Where Personal Information is transferred to another country for processing or storage, we ensure that the recipient agrees to protect such information in accordance with standards equivalent to those required by POPIA.
6. ACCESS AND CORRECTION OF PERSONAL INFORMATION
1. Clients have the right to access the Personal Information held about them and to request that it be updated, corrected or deleted on reasonable grounds. Once a client objects to the processing of their Personal Information, Henceforward may no longer process that information. We will take all reasonable steps to verify a client’s identity before disclosing or amending their information.
2. Requests for access or correction may be directed to our Information Officers, whose details are set out below.
INFORMATION OFFICER DETAILS
Information Officers: Steven Hall and Carl-Peter Lehmann
Telephone: 021 200 0053
Email:
[email protected]
Website: www.henceforward.co.za
HEAD OFFICE
Physical Address: 2nd Floor, Imperial Executive Suites, Imperial Terraces, Carl Cronje Drive, Tyger Waterfront, 7530
Graviton Wealth Management (FSP 8772): 55 Willie van Schoor Avenue, Tygervalley, Bellville, 7530
7. THE INFORMATION REGULATOR
1. Whilst we welcome the opportunity to address any concerns regarding our processing of Personal Information directly, clients have the right to lodge a complaint with the Information Regulator:
The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Complaints:
[email protected]
Enquiries:
[email protected]
8. AMENDMENTS TO THIS POLICY
This Policy will be reviewed on an ad hoc basis and at least annually. Clients are advised to check our website periodically for the most current version. Where material changes are made, clients will be notified directly. This Policy was last updated in March 2026.
Henceforward (Pty) Ltd | Reg No 2020/491620/07 | A Graviton Partner | Graviton Wealth Management FSP 8772 | [email protected]
