Privacy Policy

1. About this policy

This Privacy Policy explains how personal information is collected, used, shared, protected and retained when you visit this website, submit an enquiry, request a callback or arrange an appointment with a participating Discovery adviser or broker.

FGX Studios (Pty) Ltd (“FGX”, “we”, “us” or “our”) manages the website’s enquiry collection and related administration for participating advisers and brokers.

We handle personal information in accordance with applicable South African privacy law, including the Protection of Personal Information Act, 2013 (“POPIA”).

This policy should be read with the information displayed on the enquiry form and any privacy notice provided by your adviser, broker or the relevant Discovery entity.

2. Who handles your information

FGX Studios (Pty) Ltd is registered in South Africa under registration number 2015/430690/07.

Our business address is:

FGX is responsible for processing activities where it determines why and how personal information is used. Where FGX processes information on a client’s documented instructions, it acts as an operator for that client.

The adviser or broker identified on the relevant page or enquiry form is responsible for the information it uses to respond to your request and manage its advice or customer relationship with you. A relevant Discovery entity is responsible for information it processes for its own product, service or administration purposes.

For information about Discovery’s processing, please read the Discovery South Africa Privacy Statement (https://www.discovery.co.za/corporate/privacy-statement-discovery-sa).

Our Information Officer can help direct a privacy request to the appropriate party.

3. Personal information we collect

Depending on the form or service you use, we may collect:

• Your name and surname.
• Your telephone number and email address.
• Your preferred contact method and availability.
• The product or service you are interested in.
• Information you provide in an enquiry or appointment request.
• Answers to relevant questions shown on the form.
• Your consent choices and the wording presented when you gave permission.
• Submission dates, enquiry references, adviser allocation and delivery records.
• Correspondence and information needed to resolve an enquiry, complaint or privacy request.

Our website and campaign systems may also collect technical information, including your IP address, browser and device information, pages visited, referring website, campaign identifiers and cookie or similar identifiers.

We limit collection to information relevant to the stated purpose.

Please do not submit identity documents, banking details, detailed medical information or unrelated confidential records through an initial enquiry form. If further information is needed, your adviser or the relevant Discovery entity should explain why it is required and how to provide it securely.

4. How we collect your information

We collect information directly from you when you:

• Complete an enquiry or callback form.
• Request or book an appointment.
• Contact us or a participating adviser through the website.
• Correspond with us about your enquiry.
• Browse or interact with the website.

For this adviser lead-generation programme, we do not purchase third-party lead databases or treat a referral from another person as your consent to be contacted.

Where information is received from an authorised representative or another lawful source, its collection and use must have an appropriate legal basis.

5. Why we use your information

We use relevant personal information to:

• Respond to your enquiry and arrange the contact you requested.
• Route your request to the identified adviser or broker.
• Arrange and administer appointments.
• Record your permission and the delivery of your enquiry.
• Maintain accurate records and prevent duplicate or unauthorised allocation.
• Investigate submission failures, misuse, fraud or security incidents.
• Handle complaints, consent withdrawals and privacy requests.
• Meet applicable legal duties and resolve disputes.
• Understand website and campaign performance, subject to applicable privacy choices.

The lawful basis depends on the activity. It may include your consent, steps taken at your request before entering into a contract, performance of a contract, a legal obligation or another ground permitted by POPIA.

Before using information for a materially different purpose, we assess whether that use is lawful and provide further notice or obtain additional consent where required.

6. Your choices when submitting an enquiry

Submitting an enquiry is voluntary. Required and optional fields are identified on the form.

Where we rely on your consent to collect, share and arrange a response to your enquiry, we ask you to make a clear affirmative choice before submission. The form should identify the intended adviser or broker, the relevant Discovery recipient and the purpose of the requested contact.

If you do not provide required information or the permission needed for that consent-based enquiry, we may be unable to process your request through the form.

Reading this policy or browsing the website does not, by itself, constitute consent to marketing.

7. Who receives your information

Your enquiry information may be shared with:

• The adviser or broker identified for your enquiry.
• The relevant Discovery entity identified for the requested product or service, where necessary and authorised.
• Authorised FGX personnel who administer the enquiry.
• Service providers supporting website hosting, communications, appointment scheduling, enquiry records, security and related administration.
• Professional advisers or public authorities where disclosure is legally required or otherwise lawfully justified.

We limit sharing to information needed for the relevant purpose and require appropriate confidentiality, processing and security arrangements.

We do not distribute the same enquiry to multiple advisers for resale or share it with unrelated clients for their marketing.

If an enquiry needs to be reassigned, the reassignment must have a lawful basis, be explained to you and involve further permission where required.

8. Requested contact and future marketing

Permission to respond to an enquiry relates to the product or service you selected and the contact channels covered by your request.

It does not automatically authorise unrelated offers or continuing promotional messages from FGX, other advisers or other organisations.

Where future marketing relies on consent, the choice must be separate and optional, and explain the sender, relevant products or services and contact channels.

Unsolicited electronic direct marketing requires consent or an applicable lawful exception. Submitting an enquiry does not, by itself, make you an existing customer for every marketing purpose.

You may stop applicable marketing by using the opt-out method in the message or contacting our Information Officer. We may retain a minimal suppression record to help prevent further unwanted contact.

9. Cookies, analytics and advertising technology

This website may use cookies and similar technologies for essential functions, security, preferences, performance measurement and advertising.

Where optional tracking requires consent, the relevant choices should be presented through the website’s privacy controls. Optional tracking permission is separate from permission to process your enquiry or send future marketing.

You can manage cookies through your browser and any privacy controls provided on the website. Restricting some technologies may affect website functions.

Names, contact details, sensitive answers and full enquiry submissions must not be included in analytics URLs or ordinary advertising events. Any separate use of customer matching or conversion data requires an appropriate lawful basis and safeguards.

10. Service providers and international processing

We use service providers to support website operation, communications, enquiry administration and related services.

Some providers may store information or allow authorised support access outside South Africa. Hosting locations depend on the particular system and service configuration.

Where personal information is transferred outside South Africa, the transfer must meet the applicable requirements of POPIA, including appropriate protection through law, binding agreements or another permitted transfer ground.

You may contact our Information Officer for information about the providers and international processing relevant to your enquiry.

11. How information is protected

Our privacy and security requirements include:

• Limiting access to authorised people who need the information.
• Confidential handling of enquiry and consent records.
• Secure transmission and appropriate protection of stored information.
• Access and credential management.
• Appropriate supplier safeguards.
• Procedures for investigating and responding to security incidents.

Safeguards are selected according to the information involved and the risks of processing it.

If a security compromise triggers notification duties under POPIA, the responsible party must notify the Information Regulator and identifiable affected people as required by law.

Please report suspected misuse or unauthorised disclosure to our Information Officer promptly.

12. How long we keep information

We retain personal information only for as long as it is needed for its stated purpose or another lawful retention reason.

Relevant reasons may include handling your enquiry, maintaining necessary consent and disclosure evidence, meeting legal duties, investigating a complaint or resolving a dispute.

Our internal retention rules distinguish operational enquiry information from consent evidence, complaints, security records and suppression information. When retention is no longer justified, information is deleted, securely destroyed or irreversibly de-identified.

A minimal consent or disclosure record may remain after an enquiry closes. Minimal opt-out information may also be retained to prevent further unwanted marketing.

Legal holds and backup cycles may affect deletion timing. Information retained for those reasons remains restricted to its justified purpose.

Your adviser, broker or Discovery may retain separate customer records under its own legal duties and privacy notice.

13. Children’s information

The enquiry and appointment forms on this website are intended for people aged 18 or older.

We do not knowingly accept children’s enquiries through these forms. If children’s information is received unexpectedly, we restrict its use and assess the appropriate lawful response.

Any necessary processing of children’s information requires an applicable legal basis, appropriate permission and additional safeguards.

14. Your privacy rights

Subject to applicable law, you may:

• Ask whether we hold your personal information.
• Request access to that information.
• Ask for inaccurate or incomplete information to be corrected.
• Request deletion of information where retention is no longer lawful.
• Object to processing where the law allows.
• Withdraw consent for processing that relies on consent.
• Stop applicable direct marketing.
• Complain about how your information has been handled.
• Raise a concern about a decision based solely on automated processing that has a legal or substantial effect on you.

Withdrawing consent does not invalidate processing already lawfully completed. It may affect our ability to continue handling your enquiry.

We may need to verify your identity or authority before disclosing personal records or making a material change. A simple request to stop marketing does not require an identity document, payment or formal complaint form.

If a request concerns information controlled by an adviser, broker or Discovery, we can help direct it to that party.

Where a request cannot be fulfilled, we will explain the applicable legal reason.

15. Contact and complaints

Please direct privacy questions, complaints, objections, consent withdrawals and requests for access, correction or deletion to:

Please provide enough information for us to understand your request. Avoid sending unnecessary sensitive documents with your initial message.

Confirmation of whether we hold your personal information is free. Formal access requests may be subject to the procedures, fees and exemptions applicable under the Promotion of Access to Information Act, 2000 (“PAIA”). You may request our PAIA Manual from the Information Officer.

You may also complain directly to South Africa’s Information Regulator without first completing our internal complaints process. Complaint guidance and submission facilities are available through the Information Regulator’s eServices portal (https://eservices.inforegulator.org.za/).

16. Changes to this policy

We review this policy at least annually and when our processing activities or legal duties materially change.

The date at the top identifies the latest revision. Where a change requires further notice or fresh consent, we will provide that notice or request the necessary consent before relying on the changed processing.