This Privacy Policy explains how K2026770168 (South Africa) (Pty) Ltd, trading as Distribution Partners Group ("DPG", "we", "us" or "our") collects, uses, shares and protects personal information. It applies to information we process through this website, through our referral partner programme and when people are introduced to licensed professionals through our channels.
We process personal information in line with the Protection of Personal Information Act 4 of 2013 ("POPIA"). Terms such as "personal information", "processing", "data subject", "responsible party" and "operator" have the meanings given to them in POPIA.
1. Who we are
| Item | Detail |
|---|---|
| Responsible party | K2026770168 (South Africa) (Pty) Ltd, trading as Distribution Partners Group |
| Registration number | 2026/770168/07 |
| Physical address | 11 Ormonde Street, Bryanston, Sandton, 2191 |
| Information Officer | Nathan Herrick (registered with the Information Regulator, registration number 2026-068465) |
| Privacy contact | nathan@distributionpartners.co.za |
DPG is a distribution and marketing business. DPG is not an authorised financial services provider and does not provide financial advice or intermediary services. Introductions are made only with consent, to licensed financial advisers who are solely responsible for any advice or services they provide. One of DPG's directors is a licensed financial adviser; when he receives an introduction, he processes the referred person's information as a representative of his financial services provider, not on behalf of DPG.
2. Whose personal information we process
We process personal information about the following people:
- Website visitors who browse this website.
- Enquirers who contact us through the contact form, by email or otherwise.
- Prospective and approved referral partners, including the individuals who represent partner organisations.
- Referred persons: individuals and representatives of businesses who are introduced, with their consent, to a licensed professional through DPG's channels.
- Licensed professionals and service providers we work with, and their representatives.
3. What personal information we collect
We collect only the information we need for the purpose concerned.
Website enquiries and contact forms. Your name, email address, phone number (optional), the topic of your enquiry, your message and a record of your consent.
Referral partner enquiries. Your name, organisation, the description that best fits your organisation, email address, phone number (optional), province (optional), the nature of your request, any message you choose to include and a record of your consent.
Approved referral partners. Information needed to onboard you and to manage the partnership, such as identity or registration details, contact details, banking details for the payment of agreed fees, signed agreements, and records of introductions you make.
Referral submissions (introductions). When a partner introduces someone to us, we receive only the information needed to make contact: typically the person's name, contact details, the general area of interest and confirmation of their consent to be contacted. We do not ask partners for, and they are instructed not to share, special personal information (for example health information), identity numbers or financial account details of referred persons. Any such information required for advice is collected directly by the licensed professional.
Technical information. When you visit the website, our hosting provider automatically processes technical information such as your IP address, browser type, device information and the pages requested, for security and to deliver the website. We also use Vercel Web Analytics to count page visits in aggregate; it does not use cookies and does not identify individual visitors. See our Cookie Policy.
4. Why we process personal information, and on what basis
| Purpose | Lawful basis under POPIA (section 11) |
|---|---|
| Responding to website and contact form enquiries | Your consent, and our legitimate interest in responding to people who contact us |
| Assessing and responding to referral partner enquiries | Your consent, and steps taken at your request before concluding an agreement |
| Onboarding and managing referral partners, including payment of agreed fees | Conclusion and performance of a contract; compliance with legal obligations (for example tax) |
| Receiving introductions and passing them to an appropriate licensed professional | The referred person's consent |
| Keeping records of consent and introductions to demonstrate compliance | Compliance with legal obligations, and our legitimate interest in operating responsibly |
| Website security, fraud and abuse prevention | Our legitimate interest in protecting our website, users and systems |
| Meeting legal, regulatory and tax obligations | Compliance with an obligation imposed by law |
We will not process personal information for a purpose that is incompatible with the purpose for which it was collected, unless POPIA permits it.
5. Consent-based introductions
Introductions are central to what we do, so we apply clear rules:
- A partner may introduce someone only after that person has agreed to be contacted and to have their details shared.
- The partner must be able to show that consent. Our partner agreements require partners to keep records of consent and to provide them on request.
- We share a referred person's details only with the licensed professional who will contact them.
- A referred person may withdraw consent at any time by contacting us. Withdrawal does not affect processing that took place before it.
6. Who we share personal information with
We do not sell personal information. We share it only where necessary:
- Licensed professionals, to whom a referred person has consented to be introduced. They, or the financial services providers they represent, process the information as separate responsible parties under their own privacy policies. This includes the DPG director who is a licensed adviser, when acting in that capacity.
- Operators (service providers) who process information on our behalf, such as website hosting, email delivery, cloud storage and IT support providers. They may process the information only on our instructions and must keep it secure and confidential, as section 21 of POPIA requires.
- Professional advisers, such as auditors and legal advisers, under duties of confidentiality.
- Authorities, where the law requires us to, or to protect our rights.
Our operators currently include Vercel Inc. (website hosting and anonymous website statistics), FormSubmit (delivery of website form submissions by email), Cloudflare Inc. (bot protection on website forms, where enabled) and Microsoft (Microsoft 365 email and document storage).
7. Cross-border transfers
Some of our operators store or process information outside South Africa, mainly in the United States and the European Union (for example, website hosting, form email delivery and bot protection). Where this happens, we transfer personal information only as section 72 of POPIA permits, for example where the recipient is subject to a binding agreement or law that provides an adequate level of protection, or where you have consented.
8. How we protect personal information
We take appropriate, reasonable technical and organisational measures to protect personal information against loss, damage, unauthorised destruction and unlawful access or processing. These include encrypted connections (HTTPS) for this website, access limited to authorised people who need the information, controlled channels for introductions, and agreements with operators that require them to protect information.
If we have reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, we will notify the Information Regulator and affected data subjects as required by section 22 of POPIA.
9. How long we keep personal information
We keep personal information only as long as needed for the purpose for which it was collected, unless a longer period is required or permitted by law or by a contract, or you have consented. As a guide:
| Information | Typical retention |
|---|---|
| Website and contact form enquiries that do not lead to a relationship | Up to 12 months after our last contact |
| Referral partner enquiries that do not lead to an agreement | Up to 12 months after our last contact |
| Referral partner records, agreements and fee payment records | Duration of the partnership plus 5 years |
| Introduction and consent records | 5 years from the date of the introduction |
When information is no longer needed, we delete or destroy it, or de-identify it so that it can no longer be linked to a person.
10. Direct marketing
We do not send unsolicited electronic direct marketing. We will send marketing communications by electronic means only where POPIA (section 69) permits, for example with your consent. You can opt out of any marketing communication at any time, free of charge, using the opt-out option in the message or by contacting us.
11. Children
This website and our services are not directed at children (persons under 18). We do not knowingly collect personal information about children through this website.
12. Your rights
Under POPIA you have the right to:
- ask whether we hold personal information about you, and request access to it;
- ask us to correct or delete personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully;
- ask us to destroy or delete a record of personal information we are no longer authorised to keep;
- object, on reasonable grounds, to the processing of your personal information, and object at any time to processing for direct marketing;
- withdraw your consent at any time, where we rely on consent;
- not be subject to decisions based solely on automated processing that have legal or similarly significant effects (we do not make such decisions); and
- lodge a complaint with the Information Regulator.
To exercise these rights, contact our Information Officer using the details in section 1. We may ask you to verify your identity. Objections may be submitted on Form 1, and correction or deletion requests on Form 2, of the Regulations to POPIA, although any clear written request will be accepted. Requests for access to records are dealt with under our PAIA Manual.
13. The Information Regulator
If you are not satisfied with how we have handled your personal information, you may lodge a complaint with the Information Regulator (South Africa):
- Website: inforegulator.org.za
- General enquiries: enquiries@inforegulator.org.za
- POPIA complaints: POPIAComplaints@inforegulator.org.za
We would appreciate the chance to address your concern first, so please contact us before approaching the Regulator.
14. Changes to this policy
We may update this Privacy Policy from time to time. The latest version will always be published on this page with its effective date. Material changes will be highlighted on the website.
Effective date: 19 October 2026