Privacy Policy

Last updated: 1 June 2024

1. Who we are

TLM Financial Consulting (Pty) Ltd (trading as Talmiro), registration number 2016/384712/07, VAT number 4870219356, with its registered address at 45 Kloof Street, Cape Town, 8001, South Africa, is the responsible party for the processing of personal information described in this policy. We can be contacted at info@talmiro.pro or +27 21 418 3762.

Our appointed Information Officer for POPIA purposes can be reached at the same email address, marked "Attention: Information Officer".

2. Personal information we collect

We collect personal information that you voluntarily provide to us, including when you complete a contact or enquiry form, request an advisory consultation, or correspond with us by phone or email. This may include:

• Full name and contact details (email address, telephone number)
• Company or business details, where relevant to advisory services
• The content of any message, enquiry, or supporting documents you send us
• Technical data such as IP address, browser type and device information, collected automatically via cookies (see our Cookie Policy)

We do not knowingly collect special personal information (e.g. health, religious or political data) through this website, and we do not collect information from minors without appropriate consent.

3. Why we process your information

We process personal information for the following purposes, each with a lawful basis under POPIA:

• To respond to enquiries submitted via our contact form (contractual necessity / legitimate interest)
• To provide, administer and communicate about our wealth advisory and tax & compliance services (contract performance)
• To meet legal, regulatory and tax-reporting obligations applicable to financial advisory services in South Africa (legal obligation)
• To analyse and improve website performance, where you have consented to analytics cookies (consent)
• To send relevant marketing communications, where you have consented to marketing cookies or opted in directly (consent)

4. Cookies and website analytics

Our website uses cookies classified as Essential, Analytics and Marketing. Essential cookies are required for the site to function and cannot be disabled. Analytics and Marketing cookies are only activated with your consent, given via our cookie banner, and can be withdrawn at any time. For full details, please see our Cookie Policy.

5. Hosting and third parties

Our website and associated infrastructure are hosted with reputable service providers who process data on our behalf under appropriate confidentiality and security undertakings. We may share personal information with:

• IT and hosting providers who store website and enquiry data
• Professional advisors (auditors, legal counsel, regulators) where required by law
• Analytics providers, where you have consented to analytics cookies

We do not sell personal information to third parties. Where data is transferred outside South Africa (for example, to a cloud hosting provider), we ensure the recipient is subject to a law, contract, or binding agreement providing an adequate level of protection consistent with POPIA.

6. Retention

We retain personal information only for as long as necessary to fulfil the purposes described above, including to satisfy any legal, accounting, or reporting requirements applicable to financial services providers in South Africa. Enquiry and contact form data is generally retained for a period appropriate to our client relationship and legal obligations, after which it is securely deleted or anonymised.

7. Security

We implement reasonable technical and organisational measures to protect personal information against loss, unauthorised access, alteration or disclosure, in line with the security safeguard requirements of POPIA.

8. Your rights as a data subject

Under POPIA, you have the right to:

• Be notified that your personal information is being collected and for what purpose
• Request access to the personal information we hold about you
• Request correction or deletion of inaccurate, incomplete, or unlawfully obtained personal information
• Object to the processing of your personal information, including for direct marketing
• Withdraw consent at any time, where processing is based on consent
• Lodge a complaint with the Information Regulator of South Africa

To exercise any of these rights, please contact us at info@talmiro.pro. We will respond to legitimate requests within a reasonable timeframe as required by POPIA.

9. Information Regulator

If you believe we have not adequately addressed a privacy concern, you may lodge a complaint with the Information Regulator of South Africa:

Email: [email protected]
Website: www.justice.gov.za/inforeg

10. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "Last updated" date at the top of this page indicates the most recent revision. We encourage you to review this page periodically.

11. Contact us

For any questions regarding this Privacy Policy or our data practices, please contact:

TLM Financial Consulting (Pty) Ltd
45 Kloof Street, Cape Town, 8001, South Africa
Email: info@talmiro.pro
Phone: +27 21 418 3762