01Introduction
Cleared Capital (Pty) Ltd ("we", "us", "our") respects your privacy and is committed to protecting your personal information in accordance with the Protection of Personal Information Act, 4 of 2013 ("POPIA") and other applicable South African privacy laws.
This Privacy Policy explains what personal information we collect about you, how we use it, who we share it with, and the rights you have in respect of your information.
This is a placeholder document for development purposes. Before launching, this Privacy Policy must be reviewed by a qualified South African legal professional and the appointed Information Officer must be registered with the Information Regulator.
02What we collect
We collect the following categories of personal information:
Information you provide directly
- Account information: name, surname, email address, phone number, country of residence, date of birth.
- Identity verification (KYC): ID number or passport, proof of address, selfie/liveness check.
- Banking information: bank name, account holder, account number, branch code (for payouts only).
- Communications: support tickets, emails, chat messages, and survey responses.
Information collected automatically
- Trading data: all trades, positions, equity curves, and risk metrics from your simulated trading account.
- Device & usage data: IP address, browser type, device identifiers, pages visited, referral source, timestamps.
- Cookies and similar technologies (see section 9).
Information from third parties
- Payment processors (e.g. PayFast): transaction status, payment method type, fraud signals.
- KYC providers (e.g. Sumsub, Veriff): identity verification results.
- Affiliate partners who refer you to us.
03How we use your information
We process your personal information to:
- Create and manage your account and provide the Service;
- Verify your identity and prevent fraud, money laundering, and abuse;
- Process payments and pay out Profit Shares;
- Monitor trading activity for breach of evaluation rules;
- Communicate with you about your account, transactions, and important updates;
- Respond to support requests and resolve disputes;
- Comply with legal, regulatory, and tax obligations (including FICA and POPIA);
- Improve our Service through analytics and aggregated insights;
- Send you marketing communications (only with your consent, and with the ability to opt out at any time).
04Legal basis for processing
We process your personal information on the following lawful bases under POPIA:
- Consent: for marketing and optional features.
- Contract: to provide the Service you have purchased.
- Legal obligation: to comply with FICA, tax, and other regulatory requirements.
- Legitimate interest: to prevent fraud, secure our systems, and improve our Service.
06How long we keep your information
We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, or reporting requirements.
- Account and trading data: retained for the lifetime of your account plus 5 years after closure (FICA requirement).
- Marketing data: retained until you withdraw consent.
- Support communications: retained for 3 years from the date of last interaction.
07Security
We implement reasonable and appropriate technical and organisational measures to protect your personal information against loss, misuse, unauthorised access, disclosure, alteration, or destruction. These include:
- Encryption of data in transit (TLS) and at rest;
- Access controls and the principle of least privilege;
- Regular security reviews and incident response planning;
- Multi-factor authentication for sensitive operations.
If we become aware of a security breach that compromises your personal information, we will notify you and the Information Regulator as required by POPIA.
08Your rights
Under POPIA you have the right to:
- Access the personal information we hold about you;
- Correct inaccurate or incomplete information;
- Delete personal information that we no longer have a lawful basis to retain;
- Object to processing for direct marketing or based on legitimate interest;
- Withdraw consent at any time where processing is based on consent;
- Lodge a complaint with the Information Regulator (see section 12).
To exercise these rights, contact us using the details in section 12. We will respond within 30 days.
10International transfers
Some of our service providers are located outside South Africa. Where we transfer your personal information internationally, we ensure that adequate safeguards are in place, including:
- Transfer to jurisdictions with comparable data protection laws (e.g. EEA, UK);
- Standard contractual clauses with the recipient;
- Your explicit consent, where applicable.
11Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be communicated via email and a notice on the website at least 14 days before they take effect.
12Contact & complaints
For privacy-related queries or to exercise your rights, contact our Information Officer:
- Email: privacy@clearedcapital.com
- Postal: Information Officer, Cleared Capital (Pty) Ltd, [Registered Office Address]
You may also lodge a complaint directly with the Information Regulator of South Africa:
- Website: www.inforegulator.org.za
- Email: complaints.IR@justice.gov.za