1. About this policy

Tutela Consulting respects your privacy and is committed to processing personal information lawfully, reasonably and transparently. This policy explains what information we collect, why we use it, who we may share it with, how we protect it and the rights available to you.

This policy applies when you visit tutela.co.za, contact us, use our online tools, download resources, attend a workshop, ask for financial advice, become a client, act for a client, are named as a dependant or beneficiary, apply for a financial product through us, or otherwise interact with Tutela.

This policy must be read with Tutela's PAIA Manual, website terms, statutory disclosures and any product-provider privacy notices that apply to a particular application or service.

2. Who is responsible for your information

The responsible party isTUTELA CONSULTING CC, trading as Tutela Consulting ("Tutela", "we", "us" or "our"), an authorised financial services provider, FSP 17385.

Registered/physical address: 8 Tobago Place, Lonehill, Sandton, 2062, South Africa

General enquiries: tanja@tutela.co.za | +27 83 440 3249

Information Officer: tanja@tutela.co.za | +27 83 440 3249 |

PAIA requests: Link to PAIA MANUAL

3. What personal information we collect

The information we collect depends on your relationship with us and the advice or service you request. It may include:

Identification information, such as your name, identity or passport number, date of birth, nationality, photographs, signatures and verification information.

Contact information, such as your residential, postal and business addresses, telephone number, email address and communication preferences.

Personal and family information, such as marital status, dependants, beneficiaries, next of kin and household circumstances.

Employment and business information, including employer, occupation, income, directorships, business ownership and related records.

Financial information, including income, expenses, budgets, assets, liabilities, bank details, tax information, investment holdings, retirement interests, policies, benefits and financial goals.

Financial-product and service records, including quotations, needs analyses, records of advice, applications, instructions, replacement advice, transactions, premiums, contributions, claims and ongoing servicing information.

FICA and risk-management information, including proof of identity and address, source of funds or wealth, beneficial ownership, politically exposed person or prominent influential person status, sanctions-screening results and information required to prevent fraud, money laundering or other unlawful activity.

Special personal information, where relevant and lawfully permitted, including health, medical, disability, biometric or criminal-behaviour information required for underwriting, claims, risk assessment or legal compliance.

Information about children, dependants or beneficiaries where this is necessary for financial planning, insurance, estate planning, benefits or a product application and where a competent person has authorised the processing or another legal ground applies.

Communications and service records, including emails, messages, meeting notes, call records, complaints, queries and documents you provide.

Website and device information, such as your IP address, browser and device type, pages visited, referring page, timestamps, cookie identifiers and website interaction data.

Marketing and event information, such as your consent, interests, workshop attendance and response to communications.

4. Where we obtain personal information

We generally collect information directly from you. We may also obtain it from:

a person authorised to act for you, your employer, business, family member, guardian or representative;

insurers, investment managers, retirement funds, medical schemes, administrators, underwriting managers, banks and other product or service providers;

credit bureaus, identity-verification, fraud-prevention, sanctions-screening and FICA service providers where legally permitted;

regulators, public registers, government bodies, law-enforcement agencies and lawful public sources; and

our technology, website, communications and professional-service providers.

If you give us information about another person, you confirm that you are authorised to do so and that you have told them how Tutela will use their information, unless the law permits otherwise.

5. Why we process personal information

We process personal information only for a specific, lawful purpose, including to:

respond to enquiries, arrange consultations and communicate with you;

understand your circumstances, needs, goals and risk profile;

provide financial education, financial planning, advice and intermediary services;

obtain quotations, prepare recommendations, submit and administer applications, policies, investments, benefits, claims and instructions;

service and review your financial plan and products over time;

verify identity, perform due diligence, assess risk, prevent fraud and comply with FICA, sanctions and anti-money-laundering obligations where applicable;

comply with FAIS, POPIA, PAIA, FICA, tax, regulatory, court-order and other legal obligations;

keep records of advice, instructions, transactions, communications, disclosures, complaints and compliance monitoring;

manage our business, quality assurance, training, audits, professional advice, security and dispute resolution;

operate, secure, analyse and improve our website, forms, resources and services;

send service updates and, where permitted, relevant marketing or financial-education communications; and

protect the legitimate interests and rights of Tutela, our clients, product providers and the public.

6. Our lawful grounds for processing

Depending on the circumstances, we process your personal information because:

you have consented to the processing;

the processing is necessary to take steps at your request or to perform a contract with you;

the law requires or permits us to process the information;

the processing protects your legitimate interests;

the processing is necessary for our legitimate interests or those of a third party, provided your rights and interests do not override them; or

another lawful justification under POPIA applies, including a lawful basis for special personal information or children's information.

Where information is mandatory for legal, regulatory, underwriting or contractual reasons, we will explain this where practical. If you do not provide necessary information, we may be unable to advise you, submit an application, complete due diligence or provide the requested service.

7. Special personal information and children's information

Financial planning and product applications may require sensitive information, particularly health and medical information for life, disability, severe-illness, income-protection or medical-related products. We process this information only where POPIA permits it and only to the extent necessary for advice, underwriting, administration, claims or legal compliance.

We do not knowingly collect children's information through general website forms. We may process information about a child or dependant when a competent person provides or authorises it, when it is necessary for a product or financial plan, or when another lawful ground applies. Please do not submit unnecessary medical or children's information through the website contact form.

8. Who we may share information with

We do not sell personal information. We may share relevant information, on a need-to-know basis, with:

insurers, asset managers, retirement funds, medical schemes, administrators, underwriting managers, banks, platforms and other product providers;

medical practitioners, laboratories, assessors, claims specialists and underwriting service providers where required for an application or claim;

your employer, trustees, authorised representative, accountant, attorney or other adviser where you authorise this or the law permits it;

Tutela's compliance officer, auditors, legal advisers, accountants, consultants and professional-indemnity insurers;

identity-verification, FICA, screening, fraud-prevention and information service providers;

website hosting, cloud storage, email, form, spreadsheet, analytics, security, backup and IT support providers acting as operators;

the FSCA, Financial Intelligence Centre, Information Regulator, SARS, courts, law-enforcement bodies and other authorities where required or permitted; and

a successor or potential purchaser in a lawful business transfer, subject to appropriate confidentiality and data-protection safeguards.

Third parties may act as operators on Tutela's instructions or as responsible parties in their own right. Product providers may have their own privacy notices, which also apply to their processing of your information.

9. Operators and international transfers

We use carefully selected service providers to support our operations. Where a provider processes personal information for us, we require appropriate confidentiality, security and data-protection commitments.

Some website, cloud, email, analytics or product-provider systems may store or process information outside South Africa. We will transfer personal information across borders only where POPIA permits it, including where the recipient is subject to an adequate law, binding agreement or corporate rules, where you consent, or where another section 72 ground applies.

10. Website forms, budgeting tools and downloads

Contact form. When you submit the contact form, we collect the information shown on the form and the content of your message so that we can respond.

Budget calculator. The simplified budget calculator is designed to calculate figures in your browser. Tutela does not intend to receive or store the amounts entered into the calculator unless you separately submit them through a form, email or consultation. Do not enter account numbers, identity numbers or other unnecessary sensitive information into the calculator.

Budget-planner download. If you complete the download form, we collect the details displayed on that form, such as your name, email address and telephone number, to deliver the spreadsheet, record your request, contact you about the resource or your enquiry, and send marketing only where permitted. You may unsubscribe from marketing at any time.

Estimates only. Website calculators and resources are educational tools and do not constitute financial advice, a recommendation or a financial-needs analysis. Results depend on the information entered and should be discussed with an authorised adviser before you make a financial decision.

11. Cookies, analytics and third-party features

Tutela’s website does not currently use non-essential cookies for analytics, advertising, remarketing or behavioural profiling. Tutela does not use Google Analytics, Meta Pixel or similar third-party marketing technologies on this website.

The website uses Framer’s built-in, privacy-focused analytics to provide Tutela with aggregated information about website activity, such as page views, general traffic sources, device types and approximate geographic information. Framer Analytics does not use cookies or persistent identifiers and is not intended to identify individual visitors or track them across different websites.

To calculate daily visitor statistics, Framer processes technical information such as a visitor’s IP address and browser information using a daily rotating cryptographic value. The resulting identifier resets each day and is not used to recognise a visitor over an extended period.

Certain essential technical processes may still be required for the website to function securely, process forms, prevent spam or deliver requested content. These processes are not used for advertising or behavioural profiling.

Because the website does not currently use non-essential analytics or marketing cookies, Tutela does not presently display a cookie-consent banner. Should Tutela introduce any technology that uses non-essential cookies or similar tracking technologies in the future, this Privacy Policy will be updated and an appropriate consent facility will be implemented where required.

12. Direct marketing

We may send relevant news, financial-education content, invitations or service information where you have consented or where POPIA otherwise permits it. Every electronic marketing message will provide a reasonable way to opt out. You can also ask us to stop marketing at any time by emailing tanja@tutela.co.za.

Opting out of marketing will not prevent us from sending important communications about an existing service, application, policy, investment, legal obligation or security matter.

13. How long we keep information

We keep personal information only for as long as it is needed for the purpose for which it was collected, to provide ongoing services, or to meet legal, regulatory, contractual, audit, complaint and dispute-resolution obligations.

As a financial services provider, Tutela may be required to keep specified advice, transaction, due-diligence and client records for at least five years, calculated from the event prescribed by the applicable law or code. Some records may need to be retained longer where a product remains active, a complaint or claim is possible or underway, a regulator directs us to preserve records, or another law requires it.

When information is no longer required, we will delete or destroy it securely, or de-identify it so that it cannot reasonably be linked to you.

14. Information security

We use reasonable and appropriate technical and organisational safeguards designed to protect personal information against loss, damage, unauthorised destruction, unlawful access, alteration or disclosure. Measures may include access controls, authentication, secure devices and systems, encryption where appropriate, backups, staff confidentiality, operator due diligence, monitoring and incident-response procedures.

No internet or email transmission can be guaranteed to be completely secure. Please use secure channels supplied by Tutela for identity documents, medical records, bank details and other highly sensitive information rather than sending them through a general website form.

If we have reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, we will investigate and notify the Information Regulator and affected data subjects as required by POPIA.

15. Your rights

Subject to POPIA, PAIA and other applicable laws, you may:

ask whether we hold personal information about you and request access to it;

ask us to correct or update inaccurate, incomplete, excessive, misleading or outdated information;

request deletion or destruction where we are no longer authorised to keep the information;

object, on reasonable grounds, to certain processing;

object to direct marketing at any time;

withdraw consent where processing is based on consent, without affecting processing already carried out lawfully;

ask for information about the identity of third parties who have had access to your information, where applicable; and

lodge a complaint with Tutela or the Information Regulator.

Some rights are not absolute. We may retain or continue processing information where the law requires or permits it, including to meet FAIS or FICA record-keeping duties, establish or defend legal claims, or protect another person's rights.

16. Automated decision-making

Tutela does not intend to make decisions through the public website that have legal or substantial effects on you solely by automated means. Calculator results are generated automatically from the figures entered, but they are educational estimates and are not approval, underwriting or financial-advice decisions. Product providers may use automated tools under their own policies and legal obligations.

17. How to exercise your rights or complain

Please contact Tutela's Information Officer first so that we can try to resolve your request promptly:

Information Officer: Tanja Ehmke
Address: 8 Tobago Place, Lonehill, Sandton, 2062, South Africa
Email: tanja@tutela.co.za
Telephone: +27 83 440 3249

We may need to verify your identity before acting on a request. Access requests may also be handled under Tutela's PAIA Manual and the prescribed forms. Any fee will be charged only where the law permits it.

You may also lodge a POPIA complaint through the Information Regulator's eServices Portal or contact the Regulator:

Information Regulator (South Africa)
Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
Telephone: 010 023 5200 | Toll-free: 0800 017 160
Email: enquiries@inforegulator.org.za

Information Regulator complaints and eServices

18. Changes to this policy

We may update this policy when our services, technology or legal obligations change. The current version will be published on tutela.co.za with its effective or last-updated date. Material changes may also be communicated through an appropriate channel.

19. Contact Tutela

Tutela Consulting
Authorised Financial Services Provider - FSP 17385
Address: 8 Tobago Place, Lonehill, Sandton, 2062, South Africa
Email: tanja@tutela.co.za
Telephone: +27 83 440 3249
Website: https://tutela.co.za/