Legal · POPIA

Privacy Policy

Last updated 14 May 2026 · Compliant with the Protection of Personal Information Act, 2013

Cleared Capital (Pty) Ltd ("Cleared Capital", "we", "us") is committed to protecting your personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA"). This Privacy Policy sets out how we collect, use, store, and protect your personal information.

01Responsible party

  • Responsible Party: Cleared Capital (Pty) Ltd
  • Registration number: [NUMBER]
  • Registered office: [ADDRESS]
  • Information Officer: [NAME]
  • Contact: privacy@clearedcapital.com

We are registered with the Information Regulator of South Africa.

02Personal information we collect

2.1 Information you provide:

  • Identification: full name, date of birth, ID or passport number, photograph of identity document, proof of address;
  • Contact: email address, phone number, residential address;
  • Financial: bank account details (collected only for Performance Reward payment);
  • Account credentials: encrypted password, security questions;
  • Communications: support correspondence, feedback.

2.2 Information collected automatically:

  • Device and technical: IP address, browser type, operating system, device identifiers;
  • Usage: pages visited, features used, session duration, click patterns;
  • Trading platform: simulated trade history, performance metrics, login timestamps;
  • Cookies and similar technologies (see clause 9).

2.3 Information from third parties:

  • Identity verification providers;
  • Payment processors (confirmation of payment, not card details);
  • Anti-fraud and watchlist screening services;
  • Marketing partners (where you have consented).

03Lawful basis for processing

We process your personal information on one or more of the following lawful bases under POPIA:

  • Performance of contract — to provide the services you have purchased;
  • Compliance with legal obligation — including FICA, tax law, and regulatory requirements;
  • Legitimate interest — for fraud prevention, security, and service improvement;
  • Consent — for marketing communications, where explicitly given.

04Purposes of processing

We process your personal information for the following purposes:

  • account registration, verification, and management;
  • provision of Challenge access and platform services;
  • processing payments and Performance Rewards;
  • identity verification (KYC) and FICA compliance;
  • detection and prevention of fraud, abuse, and Forbidden Trading Practices;
  • compliance with legal, regulatory, and tax obligations;
  • communication with you about your account and our services;
  • marketing communications (only with your consent);
  • analysis and improvement of our platform and services;
  • defence of legal claims and dispute resolution.

05Sharing of personal information

5.1 We share personal information with the following categories of recipients:

  • trading infrastructure and platform providers (for the operation of the Simulated Account);
  • payment processors (PayFast, Peach Payments, or equivalent);
  • identity verification and anti-fraud service providers;
  • cloud hosting and IT service providers;
  • professional advisors (legal, accounting, audit) under confidentiality obligations;
  • regulators, law enforcement, and government authorities where legally required;
  • potential purchasers in the event of a sale, merger, or restructuring of Cleared Capital (subject to confidentiality).

5.2 We do NOT sell your personal information to third parties for their independent marketing purposes.

5.3 Cross-border transfers: Some service providers operate outside South Africa. Where personal information is transferred outside South Africa, we ensure that the transfer complies with section 72 of POPIA, either by:

  • confirming the recipient country provides adequate protection under POPIA;
  • implementing binding contractual safeguards equivalent to POPIA standards.

06Retention periods

We retain personal information only as long as necessary:

  • Identity and KYC records: 5 years after account closure (FICA requirement);
  • Transaction and financial records: 5 years after the transaction (Tax Administration Act);
  • Marketing data: until you withdraw consent;
  • Support communications: 3 years from last interaction;
  • Platform activity logs: 2 years;
  • Closed account data (non-FICA): deleted or anonymised within 12 months of account closure.

07Security

7.1 We implement reasonable technical and organisational measures to protect your personal information, including:

  • TLS/SSL encryption of data in transit;
  • encrypted storage of passwords and sensitive data;
  • access controls, role-based permissions, and authentication;
  • regular security reviews and vulnerability assessments;
  • staff training on data protection.

7.2 No security measures are absolute. You acknowledge that no electronic transmission or storage is 100% secure, and you accept the residual risk inherent in online services.

7.3 In the event of a data breach affecting your personal information, we will notify you and the Information Regulator in accordance with POPIA section 22.

08Your rights under POPIA

8.1 You have the following rights:

  • to request access to the personal information we hold about you;
  • to request correction of inaccurate or outdated information;
  • to request deletion of personal information no longer required (subject to retention obligations);
  • to object to processing for direct marketing;
  • to withdraw consent for processing based on consent;
  • to lodge a complaint with the Information Regulator.

8.2 To exercise any of these rights, contact: privacy@clearedcapital.com. We will respond within 30 days.

8.3 Information Regulator contact:

8.4 We may refuse requests where:

  • we are legally required to retain the information;
  • the request is manifestly unfounded, excessive, or repetitive;
  • the request would compromise fraud prevention or legal investigation.

09Cookies

9.1 We use cookies and similar technologies for:

  • essential functionality (authentication, session management);
  • preferences and personalisation;
  • analytics (Google Analytics or equivalent);
  • marketing (with your consent).

9.2 You may manage cookie preferences via your browser settings. Disabling essential cookies will impair platform functionality.

10Children

We do not provide services to anyone under 18 and do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a minor, we will delete it promptly.

11Changes to this policy

We may amend this Privacy Policy from time to time. Material changes will be notified by email to registered Customers. The current version is always available on our website.

12Contact