Privacy Policy
How Wealth Pathway collects, uses, discloses and protects personal information in accordance with the Protection of Personal Information Act, 2013 (POPIA).
Last updated: 1 March 2026
This Privacy Policy describes how Wealth Pathway Consulting (Pty) Ltd ("Wealth Pathway", "we", "us" or "our") collects, uses, stores, discloses and protects personal information in the course of operating our website at lembrio.pro and delivering financial advisory services. We process personal information in accordance with the Protection of Personal Information Act, 2013 (POPIA) and other applicable South African law.
Responsible party
The responsible party for the processing of personal information described in this policy is:
| Legal name | Wealth Pathway Consulting (Pty) Ltd |
|---|---|
| Registration number | 2016/384927/07 |
| VAT number | 4720193856 |
| Registered address | 48 Kloof Street, 8005, Cape Town, South Africa |
| Phone | +27 21 418 3762 |
| info@lembrio.pro |
Information Officer
In accordance with POPIA, we have appointed an Information Officer responsible for compliance with the Act. Enquiries, complaints, or requests relating to the processing of your personal information may be directed to our Information Officer at info@lembrio.pro or by post to 48 Kloof Street, 8005, Cape Town, South Africa.
What personal information we collect
We collect personal information that you provide directly to us, as well as information collected automatically when you use our website:
- Contact and enquiry data: name, email address, phone number, company name, and any message content submitted through our contact forms or in correspondence with our advisory team.
- Client and engagement data: where you engage us for advisory, risk or compliance services, we may collect financial, corporate and identity information necessary to deliver those services, in line with our engagement terms and applicable FICA/FAIS obligations.
- Technical and usage data: IP address, browser type, device information, pages visited, referring URLs, and timestamps, collected via cookies and similar technologies (see our Cookie Policy).
- Communications: records of correspondence, call notes, and meeting records arising from our relationship with you.
How we use your information
We process personal information for the following purposes, each grounded in a lawful basis under POPIA (consent, contractual necessity, legal obligation, or legitimate interest):
- Responding to enquiries submitted via our contact forms and correspondence;
- Providing, administering and improving our advisory, risk and compliance services;
- Meeting our legal, regulatory and tax obligations, including under FICA and FAIS;
- Operating, securing and analysing the performance of our website;
- Sending service-related communications and, where you have consented, marketing communications;
- Preventing fraud and protecting the rights, property and safety of Wealth Pathway, our clients and third parties.
Contact form data
When you submit a contact form on our website, we collect the information you provide (such as name, email, phone number and message) in order to respond to your enquiry. This data is retained only for as long as necessary to address your request and to maintain a reasonable business record of the correspondence, after which it is securely deleted or anonymised.
Cookies and tracking technologies
Our website uses cookies and similar technologies to operate correctly, understand visitor behaviour, and — where you consent — deliver relevant content. Cookies fall into three categories: essential, analytics and marketing. Full details of the cookies we use, their purpose and how to manage your preferences are set out in our Cookie Policy.
Hosting and third-party processors
Our website and associated infrastructure are hosted and supported by reputable third-party service providers who process data on our behalf and under contractual confidentiality and security obligations. We may also share personal information with:
- IT and hosting providers who store and secure our website and associated data;
- Professional advisers (auditors, legal counsel, regulators) where necessary to comply with our legal obligations;
- Analytics providers who help us understand website usage in aggregated, privacy-conscious form;
- Regulatory or governmental bodies where required by law.
We do not sell personal information. Where any processor is located outside South Africa, we take reasonable steps to ensure that the recipient is subject to a law, binding corporate rules, or contractual terms that provide an adequate level of protection substantially similar to POPIA.
Data retention
We retain personal information only for as long as necessary to fulfil the purposes described in this policy, including satisfying any legal, accounting, or regulatory requirements. Client engagement records may be retained for periods required under FICA, FAIS and tax legislation, typically five years from the end of the relevant engagement or transaction.
Security measures
We implement appropriate technical and organisational measures to safeguard personal information against loss, unauthorised access, alteration or disclosure, including access controls, encryption in transit, and restricted staff access on a need-to-know basis. No system is completely secure, and we continually review our safeguards in line with industry practice.
Your rights under POPIA
Subject to applicable limitations, you have the right to:
- Be notified that your personal information is being collected;
- Access the personal information we hold about you;
- Request correction or deletion of inaccurate, irrelevant, excessive or unlawfully obtained personal information;
- Object to the processing of your personal information for direct marketing purposes;
- Withdraw consent, where processing is based on consent, at any time;
- Lodge a complaint with the Information Regulator of South Africa.
To exercise any of these rights, please contact our Information Officer at info@lembrio.pro. We will respond to legitimate requests within a reasonable timeframe and in accordance with POPIA.
Complaints to the Information Regulator
If you believe we have not adequately addressed a concern regarding the processing of your personal information, you have the right to lodge a complaint with the Information Regulator of South Africa:
Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Email: [email protected]
Children's information
Our services are directed at businesses and professionals. We do not knowingly collect personal information from children, and any such information identified will be deleted promptly.
Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "Last updated" date at the top of this page indicates when the policy was last revised. We encourage you to review this page periodically.
Contact us
For any questions regarding this Privacy Policy or our processing of personal information, please contact us:
Wealth Pathway Consulting (Pty) Ltd
48 Kloof Street, 8005, Cape Town, South Africa
Phone: +27 21 418 3762
Email: info@lembrio.pro