Privacy Policy

1. INTRODUCTION AND COMMITMENT

Smart Online Trader S.A. (a brand of Diversit-e Smart Trade College (Pty) Ltd, Registration No. 2026/199265/07) and Smart Online Trader LLC (Tax ID: 37-2060884), collectively referred to as “SOT”, “we”, “us”, or “our”, are committed to protecting the privacy and security of your personal information.
This Privacy Policy (“Policy”) explains how we collect, use, process, store, share, and protect personal information obtained from you when you visit our Website (www.smartonlinetrader.com), register as a lead or prospect, purchase any Product or Service, or use the Smart Online Trader Community Hub (hub.smartonlinetrader.com).

This Policy complies with the Protection of Personal Information Act, 4 of 2013 (“POPIA”) and, where applicable to international Clients or leads, the General Data Protection Regulation (“GDPR”). By engaging with SOT in any capacity, you consent to the collection and processing of your personal information as described in this Policy.

2. WHO THIS POLICY APPLIES TO

This Policy applies to all individuals who interact with SOT, including:

• visitors to the Website;
• leads and prospects who register via any SOT web form, landing page, or lead form;
• Clients who purchase SOT Products or Services;
• Members of the Smart Online Trader Community Hub.

3. PERSONAL INFORMATION WE COLLECT

3.1 Information You Provide Directly

• Identity information: full name, identity number or passport number, date of birth;
• Contact details: email address, telephone/WhatsApp number, physical and postal address;
• Financial information: bank account details, payment card information (processed securely through payment processors), payment and transaction history;
• Programme information: membership tier selected, course progress, assessment results, enrolment history;
• Communication records: email correspondence, support ticket content, complaint records;
• Marketing preferences: opt-in and opt-out records for marketing communications.

3.2 Information We Collect Automatically

• Technical data: IP address, browser type and version, device type, operating system;
• Usage data: pages visited, time spent, links clicked, session duration, referral source;
• Cookie data: as described in our Cookie Notice on the Website.

3.3 Information from Third Parties

• Preferred Broker data: relevant trading account status information shared by the Preferred Broker where necessary for your SOT programme;
• Credit bureau data: contact details obtained through a credit bureau trace, strictly limited to the circumstances described in the Terms and Conditions of Purchase;
• Social media data: if you interact with SOT’s social media accounts.

4. HOW WE USE YOUR PERSONAL INFORMATION

5. MARKETING COMMUNICATIONS AND CONSENT

5.1 Marketing Channels and Consent

By registering on any SOT web or lead form, or by completing a Purchase Agreement, you expressly consent to receive marketing and promotional communications from SOT via:

• Electronic mail (email);
• Short Message Service (SMS);
• WhatsApp messages (processed via Twilio, in compliance with Twilio’s messaging policy and applicable South African law);
• Telephone calls.

These communications may include promotional offers, new programme launches, educational webinars, community events, market updates, and company news. SOT does not sell your contact details to third-party advertisers.

5.2 Testimonials and Image Consent

By purchasing a SOT Product or Service, you consent to SOT using any image, photograph, video testimonial, written feedback, or trading-related content submitted by you or featuring you, for marketing purposes on SOT’s social media platforms, Website, and promotional materials. You retain the right to withdraw this consent at any time in writing, and SOT will cease using new content featuring you within a reasonable timeframe following receipt of a withdrawal request.

5.3 WhatsApp and SMS — Twilio

SOT uses Twilio as its third-party messaging platform for SMS and WhatsApp communications. All messages comply with applicable South African law, Twilio’s acceptable messaging policy, and applicable communications industry guidelines. You may revoke consent for WhatsApp and SMS messages at any time by following the opt-out instructions in any message received.

5.4 How to Opt Out of Marketing

You may withdraw your marketing consent at any time, free of charge and without penalty, by:

• emailing info@smartonlinetrader.com with the subject line “MARKETING OPT-OUT — [your full name]”;
• clicking the unsubscribe link in any SOT email;
• following the opt-out instructions in any WhatsApp or SMS message;
• registering on the national Opt-Out Register managed by the Direct Marketing Association of Southern Africa (DMASA) at www.dmasa.org.

Withdrawal of marketing consent does not affect the validity of, or your obligations under, any existing Purchase Agreement.

5.5 CRM — Hustlery

SOT uses Hustlery (www.hustlery.co.za) as its Customer Relationship Management (CRM) platform. Your contact details, purchase history, and interaction records may be stored and managed within Hustlery for the purpose of managing your client relationship with SOT and delivering relevant communications. Hustlery processes personal data in accordance with applicable data protection law under a data processing agreement with SOT.

6. SHARING OF PERSONAL INFORMATION

SOT will not sell, rent, or lease your personal information to any third party for their own marketing purposes. We may share personal information with the following trusted service providers, strictly as required to deliver our Products and Services:

All third-party service providers are contractually required to maintain the confidentiality and security of personal information and to process it only for the specific purpose for which it was shared, in accordance with POPIA.

Any transfer of personal information to recipients in foreign jurisdictions will be conducted in compliance with Section 72 of POPIA, ensuring either that the recipient jurisdiction provides an adequate level of protection, or that appropriate contractual safeguards are in place.

7. YOUR RIGHTS AS A DATA SUBJECT (POPIA / GDPR)

To exercise any of the above rights, submit a written request to info@smartonlinetrader.com. SOT will acknowledge your request within 5 Business Days and respond substantively within 30 days of receipt, as required by POPIA.

8. INFORMATION REGULATOR OF SOUTH AFRICA

If you are not satisfied with SOT’s response to any privacy concern, or if you believe SOT has not complied with its obligations under POPIA, you have the right to lodge a complaint with the Information Regulator:

9. SECURITY OF PERSONAL INFORMATION

SOT implements reasonable and appropriate technical and organisational security measures to protect your personal information against loss, theft, unauthorised access, disclosure, alteration, and destruction. These measures include:

• role-based access controls and strong authentication requirements;
• encrypted data storage and transmission using industry-standard SSL/TLS protocols;
• regular security assessments and vulnerability monitoring;
• staff training on data protection and information security obligations.

While SOT takes information security seriously, no system or method of electronic transmission or storage is 100% secure. In the event of a material data security breach that poses a risk to you, SOT will notify you and the Information Regulator as required by Section 22 of POPIA.

10. RETENTION OF PERSONAL INFORMATION

SOT retains personal information only for as long as necessary to fulfil the purposes for which it was collected and as required by applicable law. Indicative retention periods:

Upon expiry of the applicable retention period, personal information will be securely deleted, anonymised, or archived in accordance with SOT’s data retention policy.

11. CHILDREN

SOT’s Products and Services are intended for persons who are 18 years of age or older. SOT does not knowingly collect personal information from minors. If you believe that a person under 18 has provided personal information to SOT without appropriate parental or guardian consent, please contact us immediately at info@smartonlinetrader.com and we will take prompt steps to delete such information.

12. CHANGES TO THIS POLICY

SOT reserves the right to update this Privacy Policy at any time to reflect changes in its practices, applicable law, or regulatory guidance. Material changes will be communicated to registered Clients by email and via a prominent notice on the Website. The updated Policy will include a revised effective date. Continued use of SOT’s services after any amendments take effect constitutes acceptance of the revised Policy.

13. CONTACT US

Smart Online Trader® | Maximize Trading Success | smartonlinetrader.com

smartonlinetrader.com  |  info@smartonlinetrader.com  |  (+27) 010 753 2460