Section 01
Who We Are
Prime Growth Capital Partners (Pty) Ltd ("PGCP", "we", "us", "our") is a South African boutique corporate finance and transaction advisory firm, registered under the Companies Act 71 of 2008 (Reg. No. 2016/227553/07) and authorised as a Category 1 Financial Services Provider by the Financial Sector Conduct Authority (FSP No. 55708).
This Privacy Policy applies to all personal information processed through our website at www.pgcp.co.za and through any enquiry or communication directed to us. It does not cover third-party platforms or services that we may link to.
We are committed to processing your personal information lawfully, fairly, and transparently. We collect only what we need, hold it only as long as necessary, and protect it with appropriate safeguards — consistent with our obligations under POPIA and our professional duties as an authorised FSP.
Section 02
Information We Collect
We collect personal information only through two channels on this website:
| Channel | Information Collected | Voluntary? |
|---|---|---|
| Contact Form | Full name, email address, phone number, and the content of your message | Yes — you choose to submit |
| Cookies & Analytics | IP address, browser type, pages visited, time on site, referral source (collected automatically via analytics tools) | Consent-based (see Section 05) |
We do not collect sensitive personal information (as defined in section 26 of POPIA) through this website, including information relating to race, health, financial records, or biometric data, unless you voluntarily include it in a message to us.
Section 03
How We Use Your Information
Personal information submitted via our contact form is used exclusively to:
- Respond to your enquiry or service request
- Assess whether there is a basis for an advisory engagement
- Comply with our legal and regulatory obligations as a licensed FSP
- Keep a record of communications where required by applicable law
We do not use contact form information for unsolicited marketing, and we do not add you to any mailing list without your explicit consent.
Analytics data is used in aggregate form only, to understand how visitors navigate our website so we can improve its content and usability. We do not build individual profiles from analytics data.
Section 04
Lawful Basis for Processing
Under POPIA, we must have a lawful ground for processing your personal information. We rely on the following grounds:
| Purpose | Lawful Ground (POPIA) |
|---|---|
| Responding to contact form enquiries | Legitimate interest / steps prior to entering a contract (s. 11(1)(d) & (f)) |
| Regulatory record-keeping | Legal obligation (s. 11(1)(c)) |
| Analytics & cookies | Consent (s. 11(1)(a)) |
Section 05
Cookies & Analytics
Our website may use cookies — small text files stored on your device — and third-party analytics tools (such as Google Analytics) to collect anonymised usage data.
On your first visit, you will be presented with a cookie consent notice. You may:
- Accept all cookies — enabling analytics and performance tracking
- Accept essential cookies only — the website will function normally; no analytics data is collected
- Withdraw consent at any time by clearing cookies in your browser settings
Essential cookies (those strictly necessary for the website to operate) are placed without consent, as they do not constitute personal information processing for purposes beyond the immediate technical operation of the site.
We do not use advertising, behavioural targeting, or third-party tracking cookies.
Section 06
Sharing Your Information
We do not sell, rent, or trade your personal information. We may share it only in the following limited circumstances:
- Service providers: Third parties who assist us in operating the website or managing communications (e.g., email hosting, analytics providers), bound by confidentiality obligations and data processing agreements
- Regulatory and legal requirements: Where disclosure is required by the FSCA, SARB, a court of law, or any other competent authority under South African law
- Professional advisors: Legal counsel, compliance officers, or auditors, subject to professional secrecy obligations
Any third party with whom we share personal information is required to process it only for the purpose for which it was shared, and to maintain equivalent standards of protection.
We do not transfer personal information outside the Republic of South Africa without ensuring adequate protection is in place, consistent with section 72 of POPIA.
Section 07
Retention of Information
We retain personal information only for as long as is necessary for the purpose for which it was collected, or as required by applicable law and regulation.
| Information Type | Retention Period |
|---|---|
| General website enquiries (no engagement) | 12 months from the date of enquiry, then securely deleted |
| Enquiries leading to a client engagement | 5 years from the end of the engagement, or as required by FSCA rules and FAIS legislation |
| Analytics data | Retained in aggregate, anonymised form; individual-level data not stored beyond 26 months |
When personal information is no longer required, it is securely destroyed or de-identified in a manner that prevents reconstruction.
Section 08
Security Measures
We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. These include:
- SSL/TLS encryption for all data transmitted through the website
- Access controls limiting who within PGCP can access personal data
- Regular review of our security practices and third-party provider arrangements
- Staff awareness of data protection obligations
No transmission over the internet is entirely risk-free. While we take our obligations seriously, we cannot guarantee absolute security. In the event of a data breach that poses a risk to your rights, we will notify the Information Regulator and affected data subjects as required by section 22 of POPIA.
Section 09
Your Rights
As a data subject under POPIA, you have the following rights in relation to your personal information held by PGCP:
- Right of access: Request confirmation of whether we hold your personal information and a copy of that information
- Right to correction: Request that inaccurate, incomplete, or outdated information be corrected
- Right to deletion: Request erasure of your personal information where we no longer have a lawful basis to retain it
- Right to object: Object to the processing of your personal information on grounds relating to your particular situation
- Right to withdraw consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing
- Right to lodge a complaint: Complain to the Information Regulator of South Africa if you believe your rights have been infringed
To exercise any of these rights, contact our Information Officer using the details in Section 12. We will respond within a reasonable period and, in any event, within 30 days of receiving your request.
Section 10
Complaints
If you believe we have handled your personal information in a manner that contravenes POPIA, we ask that you first raise the matter with our Information Officer (see Section 12) so we can attempt to resolve it directly.
If you remain dissatisfied, you have the right to lodge a complaint with the Information Regulator of South Africa:
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Email: inforeg@justice.gov.za
Website: www.inforegulator.org.za
Section 11
Changes to This Policy
We review this Privacy Policy at least annually and whenever there is a material change to how we process personal information. The effective date at the top of this document reflects the most recent revision.
Where changes are material, we will take reasonable steps to bring them to your attention. Continued use of the website after the revised policy has been published constitutes acceptance of the updated terms, to the extent permitted by law.
Section 12
Contact the Information Officer
All data protection queries, access requests, and complaints should be directed to our designated Information Officer:
Chief Executive Officer
Republic of South Africa
FSP No. 55708