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POPIA Compliant

Privacy Policy

Effective Date: 23 June 2026  •  Version: 1.0  •  Thrive Financial Connect (Pty) Ltd  •  Reg No: 2026/489324/07

Information Officer / Contact: support@thriveconnect.co.za

About this Policy. This Privacy Policy explains how Thrive Financial Connect (Pty) Ltd collects, uses, shares, secures and retains your personal information when you use the Platform, and your rights under the Protection of Personal Information Act 4 of 2013 ("POPIA"). It should be read together with our Consumer Terms of Use and, where applicable, our Advisor Platform & Subscription Agreement.

1Who We Are

Thrive Financial Connect (Pty) Ltd (registration number 2026/489324/07) ("the Company", "we", "us" or "Thrive Connect") operates the technology marketplace utility at thriveconnect.co.za (the "Platform"). For the personal information described in this Policy that we determine the purpose and means of processing, we are the Responsible Party under POPIA.

All privacy queries, data-subject requests and complaints may be sent to our Information Officer at support@thriveconnect.co.za. This is our single monitored channel for data privacy matters.

2What This Policy Covers

This Policy covers personal information we process about Consumers who use the Platform, and Advisors who maintain a profile and subscription. It does not cover the independent processing carried out by Advisors after a connection is made (see clause 9), or by third-party websites we may link to.

3The Personal Information We Collect

3.1 Account information. When you register, we collect identification and contact details necessary to create and secure your account (such as name and email address) and authentication data.

3.2 Assessment inputs. When you use the Financial Health Priority & Gap Assessment, we process the limited, text-based inputs you provide so the tool can identify broad financial-planning priority areas and gaps. This is an educational tool only and does not produce a numeric or predictive score.

3.3 Connection inputs. When you submit a connection request to a selected Advisor, we collect and transmit your name, email address, cellphone number, province and priority areas, captured at the point of connect.

3.4 Advisor information. For Advisors, we process professional and regulatory details (such as FSP/FSCA registration details, name, contact details and specialty tags) and subscription and billing status.

3.5 Technical information. We process limited technical and session information necessary to operate, secure and deliver the Platform.

3.6 What we do not collect. To limit your data exposure, the Platform does not permit, request or store uploaded financial documents, statements or bank records, and the Company never collects, holds or routes consumer investment premiums, policy contributions or client money.

4How We Collect Personal Information

We collect personal information directly from you when you register, complete the assessment, build or maintain a profile, or submit a connection request; automatically through limited technical/session data when you use the Platform; and, for Advisors, from publicly available FSCA registers when verifying declared regulatory details.

5Why We Process It and Our Lawful Basis

We process personal information only where POPIA permits it, including on the following bases under section 11 of POPIA:

  • Performance of a contract or service you request — to create your account, run the assessment, and route a connection request to the single Advisor you select;
  • Your consent — for the point-of-connect transmission of your contact details to a selected Advisor, and for any optional processing;
  • Our legitimate interests or those of a third party — to operate, secure, maintain and improve the Platform and prevent fraud and abuse;
  • Compliance with a legal or regulatory obligation — where the law requires us to retain or disclose certain records.

6Consent and Connection Routing

6.1 Explicit, point-of-connect consent. No consumer data is shared automatically. Your contact details are transmitted only to the single Advisor you expressly select, and only after you complete a clear point-of-connect consent step.

6.2 No automatic rerouting. The Platform will never automatically reroute your data to any alternative or unselected Advisor.

6.3 Purpose limitation. Your point-of-connect consent authorises the selected Advisor to respond to your specific enquiry only. It is not consent to direct marketing (see clause 10).

7Operators and Sub-Processors

We use the following trusted third-party operators (sub-processors) to provide the Platform, each engaged under data-processing terms and required to process personal information only on our instructions and to apply appropriate security safeguards:

Sub-processorFunctionPersonal informationProcessing region
SupabaseDatabase, authentication and secure data hosting/isolationAccount, assessment inputs, connection recordsAs configured
VercelApplication hosting and deliveryTechnical/session dataAs configured
PayFastPayment processing for Advisor subscriptions onlyAdvisor billing data (no consumer payment data)South Africa
ResendTransactional email routing (connection notifications and confirmations)Name, email address, cellphone numberEuropean Union

8Cross-Border Data Routing

Connection notifications and confirmations are sent using transactional email infrastructure (Resend) that involves a cross-border data-routing mechanism processed in the European Union region. This means your connection inputs (name, email address and cellphone number) may be processed outside the Republic of South Africa for the limited purpose of delivering that email.

This transfer is undertaken in reliance on the grounds permitted under section 72 of POPIA, including your consent given at the point of connection and the necessity of the transfer for the performance of the service you request, supported by data-minimisation and processing-limitation measures and contractual processing safeguards with the recipient infrastructure.

9Advisors as Independent Responsible Parties

Once your connection inputs reach a selected Advisor's dashboard or inbox, that Advisor (and their principal FSP) processes your personal information independently and becomes a Responsible Party in their own right under POPIA. The Company is not responsible for an Advisor's independent processing. Advisors are contractually prohibited from using your details for direct marketing without obtaining separate, verifiable opt-in consent from you.

10Direct Marketing

We do not sell your personal information. Any electronic direct marketing by us will be sent only where permitted under POPIA and the Consumer Protection Act 68 of 2008, and you may opt out at any time by contacting support@thriveconnect.co.za. As stated above, Advisors may not use your point-of-connect details for direct marketing without your separate consent.

11Security Safeguards

We maintain reasonable, appropriate technical and organisational measures designed to protect personal information against loss, unauthorised access, and unlawful processing, including access controls, authentication, and data isolation through our hosting infrastructure. No system is perfectly secure; where a security compromise affects your personal information, we will notify you and the Information Regulator where POPIA requires us to do so.

12Retention

We keep personal information only for as long as necessary to fulfil the purposes described in this Policy, or for as long as the law requires. When you close your account, your personal information is flagged for erasure or anonymisation, subject to records we are required to retain under South African law for security, audit and fraud-prevention purposes.

13Your Rights as a Data Subject

Subject to POPIA, you have the right to:

  • be notified that your personal information is being collected or has been accessed without authorisation;
  • request access to the personal information we hold about you;
  • request correction, or deletion of personal information that is inaccurate, irrelevant, excessive, outdated or unlawfully obtained;
  • object, on reasonable grounds, to the processing of your personal information;
  • withdraw consent where processing is based on consent (this does not affect processing already carried out);
  • not be subject to a decision based solely on automated processing intended to profile you; and
  • lodge a complaint with the Information Regulator.

To exercise any of these rights, contact support@thriveconnect.co.za. We may need to verify your identity before acting on a request.

14Cookies and Similar Technologies

The Platform uses strictly necessary cookies and similar technologies required to authenticate users, maintain your session and keep the service secure. At launch we do not use third-party advertising or behavioural-tracking cookies. If this changes, we will update this Policy and, where required, request your consent.

15Children

The Platform is intended for users who are 18 years or older and is not directed at children. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact support@thriveconnect.co.za.

16Changes to This Policy

We may update this Policy from time to time. The current version and its effective date will always appear at the top of this document. Material changes will be communicated through the Platform or by email where appropriate.

17How to Contact Us and Lodge a Complaint

For any privacy query, data-subject request or complaint, contact our Information Officer:

Thrive Financial Connect (Pty) Ltd

support@thriveconnect.co.za

If you are not satisfied with our response, you may lodge a complaint with the Information Regulator (South Africa):

Website: inforegulator.org.za

POPIA complaints: POPIAComplaints@inforegulator.org.za

General enquiries: enquiries@inforegulator.org.za

Telephone: 010 023 5200 | Toll-free: 0800 017 160

18Governing Law

This Policy is governed by and interpreted in accordance with the laws of the Republic of South Africa.