Privacy Policy

1. Your Rights and How to Exercise Them

Under the Protection of Personal Information Act, 4 of 2013 ("POPIA"), you have specific rights in relation to the personal information Elmoria Financial Advisory (Pty) Ltd, trading as Elmoria ("we", "us", "our"), holds about you. These rights include the right to be informed of what personal information we hold about you and why; the right to request access to that information; the right to request correction or deletion of information that is inaccurate, out of date, incomplete, misleadingly obtained, or unlawfully obtained; the right to object to the processing of your personal information on reasonable grounds relating to your particular situation; the right to object to direct marketing communications at any time, free of charge; the right to withdraw consent to processing where processing is based on consent; the right to submit a complaint to the Information Regulator; and the right to institute civil proceedings regarding the alleged interference with the protection of your personal information.

We will respond substantively to any request made under this section within 20 (twenty) business days of receipt, as prescribed by POPIA for a Public Body or, in the case of a private body such as ours, within a reasonable period which we commit to as 20 business days. Where a request is complex or requires clarification, we will notify you within 5 business days of receipt and provide a revised timeline not exceeding a further 20 business days.

2. Contact for Privacy Requests

All requests concerning access, correction, deletion, objection, or withdrawal of consent should be directed to our Information Officer using the details below:

If you are not satisfied with our response, or if you believe we have not dealt with your request within the applicable timeframe, you may lodge a complaint with the Information Regulator of South Africa, whose contact details are published at www.justice.gov.za/inforeg. You may also approach the Regulator directly without first raising the matter with us, although we encourage you to contact us first so that we may resolve any concern within 20 business days.

3. Who We Are and What This Policy Covers

Elmoria provides financial consulting services ("Финансовый консалтинг") to clients and prospective clients. This policy explains how we collect, use, store, and protect personal information gathered through our website at elmoria.site, specifically through our contact form and our email subscription (newsletter) sign-up, as well as any related communications.

4. Personal Information We Collect and How

4.1 Contact Form

When you complete the contact form on elmoria.site to enquire about our financial consulting services, we collect the information you voluntarily submit, which typically includes your full name, email address, telephone number, the name of your company (where applicable), and the content of your message. This information is transmitted to our Information Officer's inbox and is used solely to respond to your enquiry, prepare a proposal, or otherwise engage with you regarding our services. We do not use contact form submissions for marketing purposes unless you separately subscribe to our mailing list.

4.2 Email Subscription

If you subscribe to our email list via the subscription form on our site, we collect your email address and, where provided, your first name. We use this information to send periodic updates, insights, and marketing communications about our financial consulting services. Every marketing email includes a functional unsubscribe link, and any unsubscribe request is processed within 2 business days.

4.3 Automatically Collected Information

Our hosting provider and any analytics tools we deploy may automatically log your IP address, browser type, device information, pages visited, and timestamps of visits, as further detailed in our Cookie Policy.

5. Legal Basis for Processing

We process personal information collected via the contact form on the basis that it is necessary to take steps at your request prior to entering into a service agreement, and/or on the basis of our legitimate interest in responding to business enquiries. We process personal information collected via the email subscription form on the basis of your consent, which you may withdraw at any time as described in Section 1. Where we are legally required to retain records (for example under the Financial Intelligence Centre Act or tax legislation), we rely on compliance with a legal obligation as the basis for that specific retention.

6. Cookies

Our website uses cookies categorised as necessary, analytics, and marketing cookies. Full details, including specific cookie names, purposes, and retention periods, are set out in our separate Cookie Policy, available at elmoria.site/cookies.html. Non-necessary cookies are only activated after you have given consent via our cookie banner.

7. Hosting and Third-Party Processors

Our website and the data submitted through it are hosted on servers operated by our hosting provider. Where our hosting provider or any other service provider (such as an email marketing platform used to manage our subscription list) processes personal information on our behalf, we ensure such processors are bound by written agreements requiring them to process personal information only on our instruction, apply appropriate security safeguards, and not retain personal information for longer than necessary to perform the contracted service. Where personal information is transferred outside South Africa (for example, to a cloud hosting facility located in another country), we ensure the recipient is subject to a law, binding corporate rules, or a binding agreement that provides an adequate level of protection substantially similar to POPIA.

8. Retention Periods

Contact form submissions are retained for 24 months from the date of your last communication with us, after which they are securely deleted unless a longer retention period is required to comply with a legal obligation, resolve a dispute, or enforce our agreements. Email subscription data is retained for as long as you remain subscribed, and is deleted within 30 days of unsubscribing. Financial and client records that we are required to retain for regulatory or tax purposes are kept for the statutory minimum period, currently 5 years, calculated from the end of the relevant financial year or the termination of the client relationship, whichever is later.

9. Security Measures

We implement reasonable technical and organisational measures to protect personal information against loss, unauthorised access, interference, modification, or destruction, including access controls, encrypted transmission (TLS) for data submitted via our website forms, and restricted internal access to personal information on a need-to-know basis. In the event of a security compromise where there are reasonable grounds to believe your personal information has been accessed or acquired by an unauthorised person, we will notify the Information Regulator and affected data subjects as soon as reasonably possible, in accordance with section 22 of POPIA.

10. Direct Marketing

In line with section 69 of POPIA, we will only send you direct marketing communications by email if you have provided your consent by subscribing to our email list, or if you are an existing client and the marketing relates to similar services, in which case you will be given a clear opportunity to opt out both at the time your details were collected and in every subsequent communication.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The date of the last update will be indicated at the foot of this page, and material changes will be communicated to active email subscribers at least 14 days before taking effect.

Last updated: 2026