Privacy Policy

Last updated: 2026

Fairholm & Wren Financial Consultants (Pty) Ltd (Pty) Ltd, trading as Fairholm & Wren, ("we", "us", "our") is committed to protecting the personal information of all users of the website fondazionesenatorecappelli.com ("the Website") in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA"). This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and what rights you have as a data subject.

1. Responsible Party

For the purposes of POPIA, the responsible party in respect of personal information processed through the Website is:

2. Information Officer

Enquiries, complaints, or requests relating to the processing of personal information, or requests to exercise data subject rights under POPIA, should be directed to our Information Officer at info@fondazionesenatorecappelli.com or 27 Belgravia Crescent, 5200 East London, South Africa. You may also lodge a complaint with the Information Regulator of South Africa at [email protected] should you believe your rights under POPIA have been infringed.

3. Personal Information We Collect

We collect personal information that you voluntarily provide to us, as well as information collected automatically when you use the Website. This includes:

• Contact and enquiry information: name, surname, email address, telephone number, and the content of any message submitted via our contact form or email.
• Account information (if applicable): username, password (stored in encrypted form), and profile details you provide.
• Technical and usage information: IP address, browser type and version, device identifiers, operating system, referring URLs, pages visited, and time and date of visits, collected via server logs and cookies.
• Transactional information (if applicable): billing details, invoicing information, and records of correspondence relating to any services purchased.

We do not knowingly collect special personal information (as defined in POPIA, including race, health, religious or political beliefs, sexual orientation, criminal history or biometric data) unless expressly volunteered by you and where processing is otherwise lawful.

4. Purpose and Legal Basis of Processing

In accordance with section 11 of POPIA, we process personal information only where at least one of the following lawful grounds applies:

• Consent: where you have given clear consent, for example when submitting a contact form or subscribing to marketing communications.
• Performance of a contract: where processing is necessary to provide services or products you have requested.
• Legal obligation: where we are required to process information to comply with tax, accounting, or other statutory obligations.
• Legitimate interest: where processing is necessary for our legitimate business interests, such as website security, fraud prevention, and improving our services, provided this does not override your rights and interests.

Specific purposes include: responding to enquiries; providing and administering services; sending administrative and, where consented to, marketing communications; maintaining Website security and functionality; complying with legal and regulatory requirements; and analysing Website usage to improve user experience.

5. Cookies and Similar Technologies

The Website uses cookies and similar tracking technologies to operate correctly, analyse traffic, and, where consented to, deliver relevant marketing content. Details of the categories of cookies used, their purposes, and how to manage your preferences are set out in our separate Cookie Policy. Non-essential cookies are only set with your prior consent, obtained via our cookie consent banner, in accordance with POPIA and the Electronic Communications and Transactions Act.

6. Contact Form and Correspondence

Where you submit information via our contact form or by email, we process the personal information provided (name, email address, telephone number, and message content) solely for the purpose of responding to your enquiry and any related follow-up correspondence. This information is not used for unrelated marketing purposes unless you separately opt in.

7. Hosting and Third-Party Processors

The Website and the personal information it collects may be hosted on servers operated by third-party service providers, which may be located inside or outside South Africa. Where personal information is transferred to a country outside South Africa, we ensure that the recipient is subject to a law, binding corporate rules, or a binding agreement affording an adequate level of protection substantially similar to POPIA, as required by section 72 of POPIA. We may also engage third-party operators (as defined in POPIA), including email service providers, analytics providers, and payment processors, who process personal information on our behalf under written agreements requiring them to maintain confidentiality and appropriate security safeguards.

8. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Contact form enquiries are generally retained for a period of 24 months from the date of last correspondence, after which they are securely deleted or anonymised. Financial and transactional records are retained for the period required under South African tax and companies legislation, typically five years.

9. Security Measures

We implement appropriate, reasonable technical and organisational measures, as required by section 19 of POPIA, to safeguard personal information against loss, unauthorised access, interference, modification, or disclosure, including encryption in transit, access controls, and staff confidentiality obligations. No method of electronic transmission or storage is entirely secure, and we cannot guarantee absolute security.

10. Data Subject Rights

Subject to POPIA, you have the right to:

• be notified that personal information about you is being collected or has been accessed or acquired by an unauthorised person;
• request access to the personal information we hold about you;
• request correction, updating, or deletion of inaccurate, irrelevant, excessive, outdated, incomplete, or unlawfully obtained personal information;
• object, on reasonable grounds, to the processing of your personal information;
• withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal;
• not be subject to a decision based solely on automated processing, including profiling, which affects you materially, without the opportunity to make representations;
• lodge a complaint with the Information Regulator of South Africa if you believe your rights under POPIA have been infringed.

To exercise any of these rights, please contact our Information Officer at info@fondazionesenatorecappelli.com or +27 43 7329 7463. We will respond to legitimate requests within a reasonable time and in any event within the timeframes prescribed by POPIA. We may request proof of identity before giving effect to a request.

11. Children's Information

The Website is not directed at children, and we do not knowingly collect personal information from children without the consent of a competent person as required by section 35 of POPIA. Should we become aware that we have inadvertently collected personal information relating to a child without appropriate consent, we will delete such information promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or otherwise. The updated version will be posted on this page with a revised "Last updated" date. We encourage you to review this policy periodically.

13. Contact Us

If you have any questions about this Privacy Policy or our processing of personal information, please contact us at: