Statutory Data Governance · POPIA Compliant

Privacy Policy & Data Protection Notice

This Policy sets out how TWVS (Pty) Ltd processes and protects personal information in accordance with the Protection of Personal Information Act (POPIA, Act 4 of 2013) and the Promotion of Access to Information Act (PAIA, Act 2 of 2000).

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· Last Reviewed: October 2026 · Responsible Party: TWVS

1. Responsible Party Details

This Privacy Policy is issued on behalf of TWVS (Pty) Ltd (“TWVS”, “we”, “us”, or “our”), operating specialized practice divisions comprising TV Consulting (Financial Market Infrastructure & Straight-Through Processing) and WV Consulting (Hospitality & Restaurant Operations).

Registered Entity: TWVS (Pty) Ltd · TWVS Holdings
Jurisdiction: Republic of South Africa
Headquarters: Sandton, Johannesburg, Gauteng, 2196

2. Scope & Application

This Policy applies to all personal information processed through our public web portal (https://twvs.co.za), consultation booking workflows, advisory engagement scoping discussions, and client communication channels.

We process personal information in strict compliance with the 8 Conditions for the Lawful Processing of Personal Information as established under Chapter 3 of the Protection of Personal Information Act 4 of 2013 (“POPIA”).

3. Categories of Personal Information Collected

We collect only the minimum necessary information required to facilitate specialized professional advisory consultations:

A. Consultation & Inquiry Information

Full name, corporate entity name, job title, institutional email address, direct telephone number, preferred consultation date/time, and operational problem descriptions submitted via our consultation request engine.

B. Operational Architecture & Scoping Data

High-level platform parameters (e.g. SWIFT messaging versions, reconciliation engine volumes, POS systems, kitchen throughput metrics) provided voluntarily to enable preliminary feasibility reviews.

C. Technical & Security Telemetry

IP address, browser type, device operating system, request timestamps, and referrer headers collected automatically via Cloudflare edge infrastructure for network security, DDoS prevention, and rate-limiting.

4. Purpose of Processing

TWVS processes personal information solely for legitimate business purposes, including:

  • Evaluating, scheduling, and conducting confidential advisory consultations;
  • Preparing preliminary Statements of Work (SOW) and Master Services Agreements (MSA);
  • Conducting operational reviews across SWIFT ISO 20022 migration, post-trade reconciliations, and hospitality workflows;
  • Executing mutual Non-Disclosure Agreements (NDAs);
  • Fulfilling legal, statutory, and accounting obligations under South African law.

5. Institutional Confidentiality & NDAs

Given our active practice in capital markets infrastructure, Central Securities Depositories (CSD), banking interfaces, and proprietary hospitality operational formulas, we treat all client inquiries under strict commercial confidentiality.

Mutual NDA Guarantee: Before evaluating non-public technical architecture, proprietary trade matching logic, or sensitive food/labour cost data, TWVS executes a bilateral Non-Disclosure Agreement safeguarding all institutional assets.

6. Third-Party Disclosures & Sub-Processors

We never sell, rent, trade, or monetize personal information. Information is disclosed strictly on a need-to-know basis to trusted infrastructure partners:

  • Cloudflare Inc.: Edge CDN, WAF, and secure DNS routing infrastructure;
  • Enterprise Platform Vendors: Inquiries regarding Omnea, SmartStream, Tegra Solutions, Axway, Cato Networks, or Salt Security are shared with the respective vendor only upon your explicit prior instruction;
  • Regulatory Authorities: Disclosed only where strictly mandated by statutory subpoena, court order, or applicable South African legislation.

7. Technical Security & Data Storage

TWVS maintains robust technical and organisational security measures conforming to Section 19 of POPIA:

In-Transit Encryption

All data transmitted between your browser and our servers is secured using TLS 1.3 encryption with strict HSTS enforcement.

Access Governance

Administrative access to consultation lead records is strictly restricted to designated practice partners via Multi-Factor Authentication.

8. Your Data Subject Rights Under POPIA

As a data subject under South African law, you hold the following statutory rights:

Right of Access (Section 23): Request confirmation of whether we hold personal information about you, and receive a copy of that record.
Right to Correction or Deletion (Section 24): Request the correction, amendment, or destruction of inaccurate, irrelevant, excessive, or unlawfully retained records.
Right to Object (Section 11(3)): Object on reasonable grounds to the processing of your personal information.
Right to Withdraw Consent: Withdraw your consent at any time where processing was originally based upon consent.

9. Cookies, Local Storage & Telemetry

We operate a privacy-first web environment:

  • Essential UI Cache: We use lightweight browser local storage (localStorage) strictly to cache the site navbar and footer components to deliver instantaneous page loads with zero layout shift;
  • No Invasive Ad Trackers: We do not deploy third-party advertising retargeting pixels or cross-site tracking cookies;
  • Anonymized Telemetry: Aggregated, anonymized request counts are measured for server health and capacity planning.

10. Information Officer Contact

For questions regarding this Policy, to exercise statutory data subject rights, or to submit a formal PAIA request, contact our registered Information Officer:

Tertius Vermeulen
Information Officer · TWVS (Pty) Ltd
Email: [email protected]
Sandton, Johannesburg, Gauteng, South Africa

11. Lodging a Complaint with the Information Regulator

If you are dissatisfied with our handling of your personal information, you have the right under Section 74 of POPIA to lodge a complaint directly with the South African Information Regulator:

The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O. Box 31533, Braamfontein, Johannesburg, 2017
General Enquiries: [email protected]
POPIA Complaints: [email protected]