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Privacy policy

FinMark Trust takes privacy and the protection of your personal information (PI) seriously and will only use your PI in accordance with this notice and applicable laws. It is important that you take all necessary and appropriate steps to protect your PI yourself (e.g. by ensuring that all passwords and access codes are kept secure).

This privacy policy has been compiled to better serve those who are concerned with how their personal information is being used. PI is information that can either be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your PI in accordance with our website and other information and data sources.

1. What FinMark Trust does

FinMark Trust (FMT) is an independent non-profit trust with the purpose of ‘Making financial markets work for the poor, by promoting financial inclusion and regional financial integration. We pursue our core objective of making financial markets work for the poor through two principal programmes. The first happens through the creation and analysis of financial services demand side data to provide in-depth insights on both served and unserved consumers across the developing world. The second is through systematic financial sector inclusion and deepening programmes to overcome regulatory, supplier, and other market level barriers hampering the effective provision of services. Through a symbiotic relationship between rigorous data collection and research activities, these programmes unlock financial and economic inclusion. Our work in data supports a global agenda, with focus being placed in the SADC region on the programmatic work.

FMT's mission of making financial markets work for the poor extends to ensuring economic inclusivity and linking financial inclusion to the real economy. This renewed focus of building inclusive financial sectors for individuals, MSME’s and small-scale farmers is robust and supported within the FMT development framework. Regionally, FMT works closely with key stakeholders which include the Southern African Development Community (SADC), SADC Banking Association (SADC BA) and the Committee of Central Bank Governors in SADC (CCBG). At country level engagement with key partners at include Central Banks, Ministries of Finance, Ministries of SMME, Treasury Departments and National Statistics Officers.

2. Whose information do we collect?

    1. We collect data on market systems and the role players in them, which can include data in the public domain or primary data collected through engagements with individuals representing themselves or those representing entities, including private enterprises, government agencies or other interested parties.
    2. We engage with stakeholders through having data about who they are and what their interests in the markets are.
    3. We engage sub-contractors to perform data collection and processing activities on our behalf.
    4. We develop and disseminate insights based on the collection, analysis, reporting, and presentation of data. These insights may be considered sensitive by the parties instrumental in supplying the underlying data.
    5. Executives, employees, officials or customers of financial institutions and banks with which the FinMark Trust deals or interacts in the course or performance of work, including executives and other employees or officials in government or another regulatory or government agencies in the Republic of South Africa or other countries, financial institutions, global development institutions, payment system providers, payment system participants, payments industry associations and their members, and clearing and settlement facility applicants and licensees.
    6. FinMark Trust employees and their families or beneficiaries, and applicants for employment with FinMark Trust.
    7. FinMark Trust Retirement Fund pensioners and/or their spouses and/or nominated beneficiaries.
    8. Executives, employees, officials of suppliers and service providers to FinMark Trust and of organisations tendering to provide goods or services to FinMark Trust, including through the submission of quotations or tenders.
    9. Trustees of FinMark Trust.
    10. Visitors to FinMark Trust premises and facilities.
    11. Individuals who register to access any website or portal hosted by FinMark Trust.
    12. Media contacts.
    13. Participants of surveys, conferences and workshops hosted or arranged by FinMark Trust.
    14. Members of the public if they request information or make a complaint, ask to be placed on a mailing list, or make submissions to FinMark Trust.
    15. Media contacts.

3. Personal information we collect from visitors to

    1. When registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address or other details to help you with your experience.

4. Types of personal information we process

Depending on the circumstances, FinMark Trust may collect the following information about you:

    1. Name, surname, any identifying numbers or symbols, email address, physical address, telephone number, location information, online identifiers or other particulars assigned to you.
    2. Correspondence sent by you that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence.
    3. Your personal opinions, views or preferences and/or the views or opinions of another individual about you.
    4. Information relating to your biometrics, race, gender, sex, pregnancy, marital status, nationality, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person.
    5. Information relating to your education and medical, financial, criminal or employment history.

5. How we use the information

We may use the information we collect from you when you register, make a query, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

    1. To generate aggregated market insights from survey data.
    2. Personalising your experience and allow us to deliver the type of content and product offerings in which you are most interested.
    3. Improve our website to better serve you.
    4. Allowing us to better service you in responding to your customer service requests.
    5. Administering a contest, promotion, survey or other site feature.
    6. Asking for ratings and reviews of services or products.
    7. Following up after correspondence (live chat, email or phone inquiries).
    8. For any regulatory purposes.
    9. In the fulfilment of an obligation of law.
    10. In the fulfilment of the work of FinMark Trust.
    11. As part of the procurement of goods and services.
    12. As part of the recruitment of employees.
    13. For identifying individuals who access the FinMark Trust websites and portals.
    14. As part of identifying visitors to FinMark Trust premises.
    15. As part of social and economic research, and statistics.
    16. As part of selling products and services to clients, funders and development partners.
    17. For detection and prevention of fraud and money laundering and/or in the interest of security and crime prevention.
    18. For improving or evaluating the effectiveness of FinMark Trusts services or offerings through surveys and research.

6. How we collect information

    1. If it is reasonable and practical to do so, FinMark Trust will collect PI directly from you. We may do this through applications or other forms, over the telephone, the internet or in person.
    2. We also collect information automatically about your visits to our website, such as browsing patterns (please see section on cookies). However, information collected in this way is only used in aggregate form rather than being linked to identifiable individuals.
    3. We many collect website information using ‘cookies’ which allows us to collect standard Internet visitor usage information.
    4. We collect information from you when you register on our site, subscribe to a newsletter, respond to a survey, fill out a form, Use Live Chat, Open a Support Ticket or enter information on our site.
    5. We may also need to collect PI about you from other institutions.
    6. We may also collect your PI from your appointed agent, any regulator or other third party that may hold such information.
    7. We many collect website information using ‘cookies’ which allows us to collect standard Internet visitor usage information.
    8. When you provide us with feedback on our products or services.
    9. We may also collect information through electronic equipment such as closed-circuit television (CCTV) facilities.
    10. Through research projects/surveys for funders/development partners/clients.
    11. If you consent to take part in market research, you will be given details of the information we would like to collect at the time you give consent. We may collect data: from the information you provide to us, or one of our agents or contractors when you initially consent to take part in market research.
    12. When you sign to receive your incentive for face-to-face research.
    13. If you enter your personal details into an online questionnaire.
    14. As a voice recording of an interview for a face-to-face or telephone research project.
    15. As a video recording of an interview for a face-to-face project.
    16. If, as part of a market research project, you send details about yourself to us (e.g. a daily diary study, where paper or video diaries are kept as part of the research project).
    17. We may be passed your data, lawfully by our clients, who would like us to ask you if you would like to participate in market research, advisory boards, or other projects.
    18. We may collect your data from publicly available sources.
    19. Disclosure of your information
    20. We will only share your PI with others when we are legally permitted to do so.
    21. Your PI may be shared within the various business units of FinMark Trust, with our agents and subcontractors, and selected third parties who process the information on our behalf. This are done in accordance with the necessary legal obligations.
    22. FinMark Truist may be required to process PI in other countries. We contractually require such third parties to whom we transfer PI to agree to abide by our information processing standards and requirements.

7. Change of purpose

    1. We will only use your PI for the purposes for which it is collected, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose.

8. How we protect your information

    1. We have put in place appropriate security measures to prevent your PI from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
    2. If you suspect that your information may have been breached, you must immediately report the breach to FinMark Trust at
    3. Our website is scanned on a regular basis for security holes and known vulnerabilities to make your visit to our site as safe as possible.
    4. We use and upgrade our malware and virus protection software.
    5. Your personal information is contained behind secured networks and only accessible by a limited number of persons who have special access rights to such systems, who are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
    6. We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.

9. Use of 'cookies'

    1. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your report (dashboards). They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
    2. We use cookies to:
      1. Help remember and process the items in the report (dashboards).
      2. Understand and save user's preferences for future visits.
      3. Compile aggregate data about site traffic and site interactions to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
      4. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browsers differ, look at your browser's Help Menu to learn the correct way to modify your cookies.
    3. If you turn cookies off, some features will be disabled, some of the features that make your site experience more efficient and may not function properly, the report function (Dashboard) will be disabled.

10. Third-party disclosure

    1. We do not sell, trade, or otherwise transfer your Personally Identifiable Information to outside parties unless we provide users with advanced notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect our or others' rights, property or safety.
    2. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

11. Third-party links

    1. We do not include or offer third-party products or services on our website.

12. Google

13. COPPA (Children Online Privacy Protection Act)

    1. When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
    2. However, we do not specifically market to or collect survey data from children under the age of 13 years old.

14. POPIA and PAIA Practices

    1. POPIA and PAIA Principles form the backbone of privacy law in South Africa and the concepts they include have played a significant role in the development of data protection laws. Understanding the POPI and PAIAP principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
    2. To be compliant with POPIA and PAIA, we will take the following responsive action, should a data breach occur:
      1. We will notify you via email from

15. CAN SPAM Act

    1. The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
    2. We collect your email address to be in accordance with CANSPAM, we agree to the following:
      1. If, at any time, you would like to unsubscribe from receiving future emails, you can email us at, and we will promptly remove you from all correspondence.

16. How we retain your information

    1. We will only retain your PI for as long as necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, accounting or reporting requirements.

17. As a Data Subject, you have the right to the following:

    1. Accurate and current PI. Please keep us informed if your PI changes during your working relationship with us.
    2. Request access to or copies of your PI. (Please note such access request may be subject to the payment of a legally allowable fee.)
    3. Request correction of the PI that we hold about you.
    4. Request the erasure of your PI.
    5. Object to the processing of your PI as well as the right to object where we are processing your PI for direct marketing purposes.
    6. Request the restriction of the processing of your PI.
    7. If you want to exercise the any of the rights listed above, you may contact FinMark Trust at

18. Contacting Us

FinMark Trust
Block B West, First Floor
Central Park, 400 16th Rd, Randjespark
Midrand, 1685, Johannesburg, South Africa.
+27 (0) 67 594 9291

19. Complaints

Should you believe that FinMark Trust has not utilised your PI in compliance with the Applicable Laws, you should undertake to first attempt to resolve any concerns with FinMark Trust. If you are not satisfied with such process, you have the right to lodge a complaint with the Information Regulator, using the following contact details:
Tel: 012 406 4818
Fax: 086 500 3351

20. Changes to this privacy notice

    1. We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when any substantial updates are made.
    2. Any such amendment will come into effect and become part of any agreement you have with FinMark Trust when notice is given to you of the change by publication on our website. It is your responsibility to check the website on a regular basis.

Last updated on 2024-05-22

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