Privacy and Cookies Policy

1. INTRODUCTION

YWO (PTY) Ltd (“we”, “our”, “us”) is an authorised Financial Services Provider, licensed and regulated by the Financial Sector Conduct Authority (FSCA) of South Africa with license number 54357.

Your privacy is important to us. This Privacy & Cookies Policy explains how we collect, use, store, share, and protect Personal Information when you interact with our website or contact us.

As an FSP acting solely as an intermediary and not as a product supplier, we do not onboard clients, operate trading platforms, execute transactions, collect KYC documents, or process financial transactions.

Our role is limited to providing a website through which visitors may be directed to the product supplier’s website.

By using our website, you acknowledge that you have read and understood this Privacy and Cookies Policy (“Policy”).

2. WHAT IS PERSONAL INFORMATION

For the purposes of this Policy and in accordance with the Protection of Personal Information Act, 2013 (“POPIA”), “Personal Information” means information relating to an identifiable, living natural person, and where applicable, an identifiable juristic person. Personal Information includes, but is not limited to:

• Identification information such as your name, surname, email address, telephone number, online identifiers, IP address or device information
• Demographic information such as age, gender, nationality, language or other preference-related details
• Contact information such as physical address or location data
• technical information such as browser type, operating system, device identifiers and other information collected through cookies or similar technologies
• Communication records, including any correspondence you choose to send to us
• Opinions, views, preferences or any other information that may be linked to you as an identifiable individual

Personal Information does not include de-identified, aggregated, or anonymised data that cannot reasonably be linked back to you.

3. GROUNDS FOR PROCESSING PERSONAL INFORMATION

We process personal information in compliance with the POPIA, the Promotion of Access to Information Act 2 of 2002 (“PAIA”), applicable laws of South Africa and this Privacy and Cookies Policy.

We do so, only when one or more of the following lawful grounds apply:

• To fulfil our legitimate business purpose of providing marketing and intermediary services relating to CFDs offered by the product supplier.
• To comply with legal or regulatory obligations applicable to us under the FAIS Act or any other law.
• To protect our legitimate interests, including fraud prevention and website security.
• Where you have given your consent (e.g., for marketing communications or newsletter subscriptions).

4. INFORMATION WE COLLECT

Because YWO acts only as an intermediary, we collect limited Personal Information, primarily relating to website usage and voluntary communication.

We may collect the following categories of Personal Information:

a) Personal and Contact Information

• Name, surname and email address (only if you voluntarily provide it through our contact forms or communication channels)

b) Technical and Website Interaction Data

• IP address, browser type, device identifiers, operating system, location data, and general website interaction information.
• Data collected through cookies and similar technologies (see Section 11).

c) Voluntary Information

• Any information you choose to share with us when contacting our support team, submitting enquiries, or providing feedback

d) Marketing and Communication Preferences

• Information relating to your marketing consents or subscription preferences (if applicable).

We do not collect or process trading activity, KYC documents, financial records, banking details, or identity documents, as these functions are carried out solely by the product supplier.

5. HOW WE USE YOUR INFORMATION

We process Personal Information for clearly defined purposes, including:

• To operate and improve our website and ensure its functionality, performance, and security.
• To monitor website usage trends and improve user experience.
• To respond to enquiries, requests, or communications received from website visitors.
• To provide individuals with information or marketing material about the product supplier’s services where consent has been obtained.
• To maintain internal records, statistics, and reporting related to our marketing activities.
• To protect our systems and prevent fraudulent or unauthorised access.
• To comply with any applicable legal or regulatory requirements.

6. SHARING OF INFORMATION Your Personal Information is treated as confidential. We do not sell or rent Personal Information. We may disclose Personal Information only:

• To service providers who assist us with website hosting, analytics, IT support, email delivery, or marketing tools (on a need-to-know basis only).
• To regulatory authorities or law enforcement where required by law.
• To legal advisers, auditors, or other professional advisers as necessary.
• If disclosure is required for the protection of our legitimate interests, fraud prevention, or network security.
• If you provide consent.
• To the product supplier if you voluntarily request us to forward any specific communication or enquiry.

All third-party service providers must comply with confidentiality and data-protection obligations.

7. RETENTION OF PERSONAL INFORMATION We retain Personal Information only for as long as necessary to fulfil the purposes described in this Policy.

Information collected automatically through cookies may be retained in accordance with standard analytics practices.

Information voluntarily provided through enquiries or communication is retained only as long as needed to address your request or as required by law.

After expiry of the retention period, data is securely deleted or anonymised.

8. YOUR RIGHTS

Under POPIA and PAIA, you have the right to:

• Be informed about how your personal information is processed.
• Request access to your personal information.
• Request correction or updating of inaccurate or incomplete data.
• Request deletion or restriction of processing, subject to legal and regulatory retention requirements.
• Object to processing, including for direct marketing.
• Withdraw consent where processing is based on consent (without affecting prior lawful processing).
• Lodge a complaint with the Information Regulator of South Africa

All requests must be submitted in accordance with our PAIA Manual which is published on our website.

9. DATA SECURITY

We apply industry-standard technical and organisational security measures to protect personal information, including:

• Encryption of sensitive data in transit and at rest.
• Firewalls, intrusion detection systems, and secure servers.
• Multi-factor authentication and access controls.
• Regular monitoring, testing, and risk assessments.
• Employee confidentiality agreements and data protection training.

Despite these safeguards, no system can guarantee absolute security. We therefore encourage to maintain strong security practices, including secure passwords and vigilance against phishing attempts.

10. INTERNATIONAL TRANSFERS

Where personal data is transferred outside South Africa (e.g., to cloud service providers or group entities in other jurisdictions), we ensure that adequate safeguards are in place, including data transfer agreements that comply with POPIA and international best practices.

11. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse website performance, and support our marketing activities. Cookies help us understand how visitors interact with our website and allow us to provide a more efficient and personalised experience.

11.1. What Cookies are

Cookies are small text files stored on your device when you visit a website. These files allow the website to recognise your device, remember your preferences, and record certain information about your browsing activity. Cookies do not contain any executable code and cannot transmit viruses or malware.

11.2. Why we use Cookies

We use cookies to:

• Ensure the proper and secure functioning of our website
• Analyse traffic patterns and understand how visitors use our site
• Improve the content, structure and navigation of our website
• Store your language and region preferences
• Support our advertising, referral and marketing efforts
• Help identify any technical issues or performance inefficiencies.

Cookies also help us determine which pages are most popular, how visitors move between pages, and whether users were referred to our website by third-party websites or adverts.

11.3. Types of Cookies we use

We use several types of cookies:

a) Strictly necessary cookies

These cookies are essential for the proper functioning of our website. They allow you to navigate the website and use its features. Without these cookies, certain website features may not operate correctly. These typically include session cookies that expire once you close your browser.

b) Performance & Analytical Cookies

These cookies help us analyse visitor behaviour. Information collected is aggregated and anonymous and used only for statistical purposes. They help us understand:

• Which pages are visited most frequently
• How users navigate our website
• Which referral links or campaigns are most effective.

We may use Google Analytics or similar tools, which may store information on external servers. This may include your IP address and device details. Third parties may process this information strictly for analytics purposes.

c) Functional Cookies

These cookies allow our website to remember your preferences (such as language or region) and enhance the user experience. They help ensure that the website loads preferences automatically, reducing the need for repeated input.

d) Marketing & Targeting Cookies

These cookies are used, only with your consent, to deliver advertisements and content tailored to your interests. They help us and third-party partners:

• Track the effectiveness of advertising campaigns
• Identify whether you have visited our website before
• Display content more relevant to your interests.

These cookies may be set by third-party advertising networks.

11.4. Third-Party Cookies

Our website may use cookies from third-party service providers, including:

• Analytics tools (e.g., Google Analytics)
• Advertising networks
• Referral/affiliate marketing systems
• Cloud hosting or performance monitoring tools.

We do not control or access third-party cookie data and are not responsible for how such third parties manage, store, or use that information. Third parties may process cookie data in accordance with their own privacy policies.

11.5. Managing Cookies

You may manage or disable cookies through your browser settings at any time. However, please note:

• Some website features may not function correctly without certain cookie
• Disabling certain cookies may limit website functionality or reduce performance
• You may not be able to access certain features or pages if cookies are disabled.

Instructions for managing cookies can typically be found in your browser’s help section or at: www.aboutcookies.org

11.6. Additional Information

If you have any questions about how we use cookies or wish to understand cookie categories in more detail, please contact us at support@ywo.com

12. UPDATES TO THIS POLICY

We may update this Policy from time to time to reflect legal, technical or operational changes. Updated versions will be posted on our website, and continued use of our services constitutes acceptance of the updated Policy.

13. CONTACT US

If you have any questions about this Policy or how we handle your personal information, please contact us:

YWO (PTY) Ltd 29 First Avenue East, Parktown North, Johannesburg, Gauteng, 2193, South Africa support@ywo.com

You may also contact the Information Regulator of South Africa at https://inforegulator.org.za/ if you are unsatisfied with our response.