Privacy Policy

This policy is issued by Brenivo Capital (Pty) Ltd (Proprietary Limited (Pty) Ltd), trading as Brenivo Capital, with its registered address at 58 Katherine Street, 2196 Johannesburg, South Africa, registration number 7987784921 (CIPC). Any query concerning this policy or the personal information described below should be directed to [email protected] or +27 11 733 7641. Brenivo Capital determines the purpose and means of processing personal information collected through brenivo.site and is accordingly the "responsible party" as that term is used in the Protection of Personal Information Act 4 of 2013 ("POPIA").

Terms Used in This Policy

Personal information
Information relating to an identifiable, living natural person or, where applicable, an existing juristic person, as defined in section 1 of POPIA.
Processing
Any operation performed on personal information, including collection, storage, use, transmission, and deletion.
Responsible party
The party that determines the purpose and means of processing personal information — here, Brenivo Capital (Pty) Ltd.
Operator
A party that processes personal information on behalf of the responsible party, such as a hosting or email-delivery provider, under a contract or mandate.
Data subject
The natural or juristic person to whom personal information relates.
Consent
Any voluntary, specific, and informed expression of will in terms of which permission is given for the processing of personal information.
Special personal information
Personal information as defined in section 26 of POPIA, including religious belief, race, health, or criminal behaviour. Brenivo Capital does not intentionally collect this category of information.

A. What We Collect and Why

A.1 Contact Form

When a visitor submits an enquiry through the contact form on brenivo.site, Brenivo Capital collects the name, email address, phone number (where supplied), and the content of the message, including any financial or business information the visitor chooses to include in order to describe their consulting needs. This information is used solely to respond to the enquiry, to assess whether Brenivo Capital can offer the requested financial consulting services, and, where a client relationship follows, to prepare a formal engagement.

A.2 Email Subscription

Visitors who subscribe to receive updates, market commentary, or service announcements from Brenivo Capital provide their email address, and optionally their name, through the subscription form. This information is used to send the requested communications and is not used for any other purpose without further notice.

A.3 Automatically Collected Information

Our hosting and analytics providers may automatically log IP addresses, browser type, device information, and pages visited, for the purposes described in the accompanying Cookie Policy.

B. Legal Basis for Processing

B.1 Consent

Processing of the email subscriber's address and name is based on the data subject's consent, given by submitting the subscription form. This consent may be withdrawn at any time by using the unsubscribe link in any email received, or by contacting [email protected].

B.2 Legitimate Interest and Pre-Contractual Steps

Processing of contact-form data is based on Brenivo Capital's legitimate interest in responding to business enquiries and, where relevant, on steps taken at the data subject's request prior to entering into a service agreement, in accordance with section 11(1)(f) and section 11(1)(b)(i) of POPIA respectively.

B.3 Legal Obligation

Where Brenivo Capital is required to retain client or transactional records under the Financial Intelligence Centre Act 38 of 2001 or other applicable financial-sector legislation, processing is based on compliance with a legal obligation under section 11(1)(c) of POPIA.

C. Cookies

brenivo.site uses cookies falling into necessary, analytics, and marketing categories. Full details of each category, their duration, and how consent is managed are set out in our separate Cookie Policy, which forms part of this privacy framework.

D. Hosting and Third-Party Operators

The website and the data submitted through it are hosted and processed with the assistance of third-party service providers acting as operators on Brenivo Capital's behalf, including our hosting provider and our email delivery provider. These operators process personal information strictly under written instruction and are contractually bound to implement appropriate security safeguards as required by section 21 of POPIA. Where any operator is located outside South Africa, Brenivo Capital ensures that 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, as required by section 72 of POPIA.

E. Retention

Contact-form enquiries that do not result in a client relationship are retained for twelve months from the date of the last communication, after which they are deleted. Where an enquiry leads to an engagement, records are retained for the period required by applicable financial and tax legislation, typically five years from the end of the engagement. Subscriber email addresses are retained for as long as the subscription remains active and are deleted within thirty days of unsubscribing.

F. Data Subject Rights

Subject to the limitations set out in POPIA, a data subject has the right to:

Requests may be submitted to [email protected] or +27 11 733 7641. Brenivo Capital will respond within the timeframes prescribed by POPIA, and may request proof of identity before acting on a request.

G. Complaints to the Regulator

If a data subject believes that Brenivo Capital has processed their personal information unlawfully, they may lodge a complaint with the Information Regulator of South Africa, whose contact details are published at www.justice.gov.za/inforeg. Brenivo Capital encourages data subjects to first raise concerns directly with us at [email protected] so that we may attempt to resolve the matter.

H. Security Safeguards

Brenivo Capital implements reasonable technical and organisational measures, in accordance with section 19 of POPIA, to secure the integrity and confidentiality of personal information in its possession, including access controls, encrypted transmission of form submissions, and restricted staff access to stored enquiries and subscriber lists.

I. Changes to This Policy

This policy may be updated from time to time to reflect changes in our processing activities or in applicable law. The date of the most recent revision will be indicated at the foot of this page. Material changes affecting email subscribers will be notified by email where practicable.

Last updated: 2026.