Privacy Policy

INTRODUCTION

1.1 BCS Markets SA (Pty) Limited (herewith "BCS", the "Company" or "We") is incorporated under the laws of South Africa and is registered by the Companies and Intellectual Property Commission with registration number 2020/523823/07. BROKSTOCK is a brand operated by BCS Markets SA (Pty) Ltd, a company incorporated and registered under the laws of South Africa and an investment firm regulated by the Financial Sector Conduct Authority ("FSCA") with license number 51404.

1.2 In accordance with the Constitution, the Financial Advisory and Intermediary Services Act, 2002 and the Protection of Personal Information Act, 2013, the Company outlines in this privacy policy ("Privacy Policy") its practices pertaining to personal data. This Privacy Policy applies to the Company's apps, websites, media channels and related digital services ("BCS Platform").

1.3 For the purposes of this Privacy Policy, unless the context indicates otherwise, "you", "your" and "user" means you, the user (client) of the BCS Platform and includes previous, existing and prospective clients and new and existing employees of the Company. "Information" means all and any information we collect about you or provided by you and includes your personal data.

1.4 If you do not agree with the terms of this Privacy Policy, you should not use the BCS Platform.

1. CHANGES TO THE PRIVACY POLICY

1.5 We will generally notify all users of any material changes to the Privacy Policy, through a notice provided via the website or via email. However, you should look at this Privacy Policy regularly to check for any changes. We will also update the "Last Updated" date at the top of this Privacy Policy, which reflects the effective date of the Privacy Policy. Your continued access to or use of the BCS Platform after the date of the updated Privacy Policy constitutes your acceptance of the updated Privacy Policy. If you do not agree to the updated Privacy Policy, you must stop accessing or using the BCS Platform.

2. THE TYPES OF PERSONAL DATA WE USE

1.6 The Information we collect depends on how you use the BCS Platform and the choices you make. We collect information about you from different sources and in various ways when you use our products, including Information you provide directly, third-party data, Information collected automatically, and data we infer or generate from other data. More Information about the categories and sources of Information is provided below.

1.7 Information you choose to provide

1.8 You are under no obligation to provide personal Information of any kind, however this may prevent you from opening an account with the Company, using certain features of the BCS Platform or being provided with certain products or services.

1.9 Financial data

1.9.1 This is financial Information, such as data related to a payment method (e.g., debit card number, card brand and expiration date) that the Company may collect when you purchase, order, return, exchange or request Information about the Company's services from the BCS Platform.

1.10 Data from contests, giveaways, and surveys

1.10.1 This is Information that you may provide when entering contests or giveaways and/or responding to surveys.

1.11 Information we collect automatically

1.11.1 Derivative data

1.11.1.1 This is Information that the Company's servers automatically collect when you access the BCS Platform, such as IP address, browser type, operating system, access times and the pages you have viewed directly before and after accessing the BCS

Platform. In the case of the mobile application this Information may also include device name and type, operating system, phone number, country, other interactions with the application and other users via server log files.

1.11.2 Mobile device data

1.11.2.1 The Company may collect the following Information in relation to your mobile device:

1.11.2.1.1 Geo-location information - the Company may request permission to access and track location-based Information from your mobile device, either continuously or during use of the mobile application. You may change access permissions at any time on your device settings.

1.11.2.2 Mobile device access - the Company may request permission to access certain features of your mobile device including bluetooth, calendar, camera, contacts, microphone, reminders, sensors, messages, social media accounts and storage. You may change access permissions at any time on your device settings.

1.11.2.3 Mobile device data - the Company may collect device Information such as a mobile device ID, model, manufacturer, operating system, version Information and IP address.

1.11.2.4  Push notifications - the Company may request to send you push notifications regarding your account or the BCS Platform. You may opt out of these notifications at any time on your device settings.

1.11.3 Information received from third-parties

1.11.3.1 Social media networks - if you connect a social media network account to the BCS Platform, we will collect Information from such network that is made available to use. This will depend on your permissions and settings on the particular social media network.

1.11.3.2 Business partners - if you choose to register to use the BCS Platform using your social media network account details (e.g. Facebook, Twitter, Instagram, Google), you will provide us or allow your social media network to provide us with your username and public profile. We will share certain Information with the relevant social media network such as your application ID, access token and the referring URL.

1.11.3.3  Advertisers and advertising networks - the Company may use the Information collected from you and your interaction with the BCS Platform and other third- party sites to infer your likely interests to provide you with more relevant advertising.

1.11.4 Information we create or generate

1.11.4.1 We infer new Information from other data we collect including using automated means to generate Information about your likely preferences, other characteristics or inferences. We infer your general geographic location (such as city, state and country) based on your IP address, system region, mobile country code, mobile network code and mobile carrier Information.

3. COOKIES, MOBILE IDS AND SIMILAR TRACKING TECHNOLOGIES

1.12 Cookies and web beacons

1.12.1  The Company may use cookies, web beacons, tracking pixels and other tracking technologies on the BCS Platform to help us customize the BCS Platform and improve the user's experience. When you access the BCS Platform, your personal Information is collected through the use of tracking technology. Most browsers are set to accept cookies by default. You may remove or reject cookies or decline web beacons but such action may affect your availability and functionality of the BCS Platform.

1.12.2  Please be aware that getting a new computer, installing a new browser, upgrading an existing browser or erasing or altering your browser's cookies files may also clear certain opt-out cookies, plug-ins or settings.

1.12.3  For more Information on how the Company uses cookies, please refer to our Cookie Policy which is also posted on the BCS website and which is incorporated hereto by reference.

1.13 Controls for do-not-track features

1.13.1 Some browsers have incorporated "Do Not Track" ("DNT") features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is no common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.

4. INTERNET-BASED ADVERTISING

1.14  The Company may use third-party software to serve advertising on the BCS Platform, implement email marketing campaigns, and manage other interactive marketing initiatives which may use cookies or other similar tracking technologies.

5. WEBSITE ANALYTICS

1.15  The Company may partner with third-party vendors to allow tracking technologies and remarketing services on the BCS Platform through the use of first party and third-party cookies to, amongst other things, analyze and track users' use of the BCS Platform and better understand online activity. By accessing the BCS Platform, you consent to the collection and use of this Information. Such Information is not however transferred to these third-party vendors.

1.16  The BCS Platform may contain links to third-party websites and applications, including advertisements and external services that are not affiliated with the Company. Once you access these links to leave the BCS Platform, any Information provided by you to these third parties is not covered by this Privacy Policy and the Company cannot guarantee the safety and privacy of such Information. Further, the Company is not responsible for the content or privacy and security practices and policies (if any) of any such third parties, including other websites, services or applications that may be linked to the BCS Platform.

7. HOW WE USE YOUR INFORMATION

1.17  We use your Information to provide the BCS Platform to you and to improve and administer it. We use each of the Information collected for the following purposes:

8. DISCLOSURE OF INFORMATION

User's Information may be disclosed as follows:

1.18 By law or to protect rights

1.18.1 If the Company believes the release of Information about the user is necessary to respond to legal process, to investigate or remedy potential violations of the Company's policies, or to protect the rights, property, and safety of others, the Company may share the user's Information as permitted or required by any applicable law, rule, or regulation. This includes exchanging Information with other entities for fraud protection and credit risk reduction.

1.19 Third-party service companies

1.19.1 The Company may share the user's Information with third parties that perform services for the Company or on the Company's behalf, including payment processing, data analysis, email delivery, hosting services, customer service and marketing services.

1.20 Marketing communications

1.21 With the user's consent, the Company may share the user's Information with third parties for marketing purposes, as permitted by law.

1.22 Third-party advertisers

1.22.1.1 The Company may use third-party advertising companies for advertising when the user visits the BCS Platform. These companies may use Information about the user's visits to the BCS Platform and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to the user.

1.23 Affiliates

1.23.1 The Company may share the user's Information with its affiliates, in which case the Company will require those affiliates to honor this Privacy Policy. Affiliates include the Company's parent company, any subsidiaries, joint venture partners or other companies that the Company controls or that are under common control of the Company.

1.24 Offer wall

1.24.1 The Company's mobile application may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts or other items to the users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in the mobile application and be displayed to the user based on certain data, such as the user's geographic area or demographic Information. When the user clicks on an offer wall, the user will leave the BCS Platform. A unique identifier, such as the user ID will be shared with the offer wall Company in order to prevent fraud and to correctly credit the user account.

1.25 Other Third Parties

1.25.1 The Company may share the user's Information with advertisers and investors for the purpose of conducting general business analysis. The Company may also share the user's Information with such third parties for marketing purposes, as permitted by law.

9. SALE OR BANKRUPTCY OF THE BUSINESS

1.26 If the Company reorganises or sells all or a portion of its assets, undergoes a merger, or is acquired by another entity, the Company may transfer the user's Information to the relevant buyer entity. If the Company goes out of business or enters bankruptcy, the user Information would be an asset transferred or acquired by a third-party. You acknowledge that such transfers may occur and that the transferee may amend this Privacy Policy.

10. SECURITY OF YOUR INFORMATION

1.27 We take reasonable and appropriate technical and organisational measures to help protect personal data from unauthorised access, use, disclosure, alteration and destruction.

1.28 Unfortunately, the transmission of Information via the internet is not completely secure and we cannot guarantee the security of your Information transmitted via the BCS Platform and any transmission of such Information is at your own risk. To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

11. INFORMATION RELATING TO CHILDREN

1.29  The BCS Platform is not directed at persons under the age of 18. If you believe that we have personal data about or collected from a person under 18, please contact us at info@brokstock.co.za.

12. YOUR CHOICES AND RIGHTS

1.30 Account information

1.30.1 You may at any time review or change the Information in your account or terminate your account by accessing your account settings and making the relevant changes or contacting us using the contact Information provided below. Upon a request to terminate an account, the Company will deactivate or delete the account and the user's personal Information from the Company's active databases. However, some Information may be retained by the Company to prevent fraud, troubleshoot problems, assist with any investigations, enforce terms of use and/or comply with legal obligations.

1.31 Emails and communications

1.31.1 If you no longer wish to receive correspondence, emails or other communications from the Company, you may opt-out by noting such preferences at the time of account registration, logging into account settings and updating preferences or contacting us using the contact Information provided below. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting such third-party directly.

1.32 Training and communication of employees

1.32.1 Training on this Privacy Policy forms part of the induction process for all new employees. All existing employees will receive regular and relevant training on how to implement and adhere to this Privacy Policy. In addition, all employees will be asked to formally accept conformance with this Privacy Policy on an annual basis. We have a zero-tolerance policy to bribery and corruption which employees are obligated to communicate to all contractors and business partners at the outset of a business relationship and as appropriate thereafter.

13. CONTACT INFORMATION OF THE BUSINESS

1.33 Questions, comments and requests regarding this Privacy Policy or other related policies and documents should be addressed to compliance@brokstock.co.za.

14. AMENDMENTS TO THIS POLICY

1.34 Amendments to this Policy will take place from time to time subject to the discretion of BCS and pursuant to any changes in the law. Such changes will be brought to the attention of employee's, members and clients where it affects them.

15. OWNERSHIP OF THIS POLICY

1.35 This Policy is owned by BCS Markets SA (Pty) Ltd, trading as BROKSTOCK, an authorised financial services provider in terms of the Financial Advisory & Intermediary Services Act (37 of 2002) and subordinate legislation, with FSP number 51404.

1.36 The Key Individual of BCS Markets SA (Pty) Ltd hereby confirms the adoption of this Policy on behalf of the governing body of the BCS Markets SA (Pty) Ltd and accepts responsibility for the successful training of employees and implementation of this Policy.

1.37 This document will be updated whenever material changes are made to it.