Privacy Policy

We respect your privacy and are committed to protecting the personal information that you share with us. Generally, you can browse through our website without giving us any information about yourself. When we do need your personal information to provide services that you request or when you choose to provide us with your personal information, this policy describes how we collect and use that information.

Information collection

Personal information means any information that may be used to identify an individual, including, but not limited to, a first and last name, e-mail address, a home, postal or other physical address, other contact information, title, birth date, gender, occupation, industry, personal interests, and other information needed to provide a service you requested.

When you browse our website, you do so anonymously, unless you have previously indicated that you wish us to remember your login and password. We do not automatically collect personal information, including your e-mail address. We do log your IP address (the Internet address of your computer) to give us an idea of which part of our website you visit and how long you spend there. We do not, however, link your IP address to any personal information unless you have logged in to our website. Like many other commercial websites, the 3byTwo Financial Planning CC website may use a standard technology called a “cookie” to collect information about how you use the site. Please go to “Cookies and tracking technology” below for more information.

We collect personal information when you register with us for a 3byTwo Financial Planning CC membership account, when you use certain 3byTwo Financial Planning CC services, when you register to attend a seminar or participate in an online survey, when you ask to be included in an e-mail or other mailing list, or you submit an entry for a competition or other promotions, or when you submit your personal information to us for any other reason. From time to time, we receive personal information from business partners and vendors. We only uses such information if it has been collected in accordance with acceptable privacy practices consistent with this Policy and applicable laws.

Access to certain 3byTwo Financial Planning CC web pages requires a login and a password. The use of those web pages, and the information or programs downloadable from those sites, may be governed by a written agreement between your employer and 3byTwo Financial Planning CC. Unless you request deletion of your personal information as specified below, your personal information may be retained by 3byTwo Financial Planning CC to verify compliance with the agreement, log software licenses granted, to track software downloaded from those pages, or track usage of other applications available on those pages.


When personal information is collected, we will inform you of the purpose for the collection at the point of collection. We will not transfer your personal information to third parties without your consent, except under the limited conditions described under the discussion below entitled “Information sharing and disclosure”.

If you choose to provide us with your personal information, we may only transfer that information within 3byTwo Financial Planning CC or to 3byTwo Financial Planning CC’s third-party service providers with your permission. Upon receiving your permission, we may transfer your information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

We will always give you the opportunity to “opt out” of receiving direct marketing or market research information. This means we assume you have given us your consent to collect and use your information in accordance with this policy unless you take affirmative action to indicate that you do not consent, for instance by clicking or checking the appropriate option or box at the point of collection. In some cases, when applicable, we will provide you with the opportunity to “opt in.” This means we will require your affirmative action to indicate your consent before we use your information for purposes other than the purpose for which it was submitted.

Cookies and tracking technology

A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the site uses to track the pages you have visited, but the only personal information a cookie can contain is information you supply yourself. A cookie cannot read data off your hard disk or read cookie files created by other sites. Some parts of our website use cookies to track user traffic patterns. We do this in order to determine the usefulness of our website information to our users and to see how effective our navigational structure is in helping users reach that information.

If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you of its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of our website if you do so. In particular, you may be required to accept cookies in order to complete certain actions on our website. However, you do not need to have cookies turned on to use/navigate through many parts of our website, except where access to certain of our web pages may require a user login and password.

How we use information collected

We use information for several general purposes: to fulfill your requests for certain products and services, to personalise your experience on our website, to keep you up to date on the latest product announcements, updates, special offers or other information we think you would like to hear about either from us or from our business partners, and to better understand your needs and provide you with better services. We may also use your information to send you, or to have our business partners send you, direct marketing information or contact you for market research.

Information sharing and disclosure

Because we offer internationally based products, your personal information may be shared with other business partners or subsidiaries anywhere in the world. All such entities are governed by this privacy policy or are bound by the appropriate confidentiality and data transfer agreements.

Your personal information is never shared outside 3byTwo Financial Planning CC without your permission, except under conditions explained below. Inside 3byTwo Financial Planning CC, data is stored in controlled servers with limited access. Through rigorously designed business rules, only a few of our authorised personnel (e.g. system operators and business analysts) have access to this information, and then in predetermined circumstances. Your information may be stored and processed in South Africa or any other country where we, our subsidiaries, affiliates or agents are located.

We may send your personal information to other companies or people under any of the following circumstances: we have your consent to share the information; we need to share your information to provide the product or service you have requested; we need to send the information to companies who work on our behalf to provide a product or service to you (we will provide those companies only the information they need to deliver the service, and they are prohibited from using that information for any other purpose); or we want to keep you up to date on the latest announcements, updates, special offers or other information we think you would like to hear about either from us or from our business partners (unless you have opted out of these types of communications). We will also disclose your personal information if required to do so by law, to enforce our terms of use, or in urgent circumstances, to protect personal safety, the public or our websites.

Children and privacy

Our websites do not target and are not intended to attract children under the age of 18. We do not knowingly solicit personal information from children under the age of 18 or send them requests for personal information.

Third-party Sites

Our website may contain links to other sites. We do not share your personal information with those websites and are not responsible for their privacy practices nor do we have any control over their collection of personal data. We encourage you to find out about the privacy policies of those companies.

Some of these third-party sites may be co-branded with a 3byTwo Financial Planning CC logo, even though they are not operated or maintained by us. Although we choose our business partners carefully, we are not responsible for the privacy practices of websites operated by third parties that are linked to our site. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle information they collect from you.

Changes to this Privacy Policy

We will amend this policy from time to time. If we make any substantial changes in the way we use your personal information we will make that information available by posting a notice on this site.

Questions or suggestions

If you have questions or concerns about our collection, use, or disclosure of your personal information, please e-mail us at

Internal Policy on Conflict of Interest and Register of non-cash incentives

FSP: 3byTwo Financial Planning CC

FSB Licence No: 25331

Revised: 10 June 2010


In accordance with a financial services provider’s obligation to act in the best interest of his or her client, it is not permissible for a financial services provider to engage in conduct, whether by acting or failing to act, which would amount to a conflict of interest with that of the client.

The primary objectives of this policy are:

  • To provide guidance on the behaviours expected in accordance with the Code of Conduct.
  • To promote transparency and avoid conflicts of interest.
  • To ensure fairness in the interests of clients.
  • To document the process for the disclosure, which may amount to actual, potential or perceived conflicts of interest.

Process and Requirements

Whenever the FSP renders a financial service, it must disclose to clients the existence of any personal interest in the relevant service, or of any circumstance which gives rise to an actual or potential conflict of interest in relation to such service, and take all reasonable steps to ensure fair treatment of the client.

Whenever the FSP renders a financial service, it must disclose to clients the existence of any personal interest in the relevant service, or of any circumstance which gives rise to an actual or potential conflict of interest in relation to such service, and take all reasonable steps to ensure fair treatment of the client.

Non-cash incentives offered and/or other indirect consideration payable by another provider, a product supplier or any other person to the FSP, could be viewed as a potential conflict of interest.

Disclosure will take the form of a specific disclosure of any personal interest in a specific service, as well as a general disclosure regarding non-cash incentives in the FSP’s Contact Stage Disclosure letter, as well as the maintenance of a Register of Non-Cash Incentives.

The details of any non-cash incentives offered and / or other indirect consideration paid to the FSP by any other FSP, a product supplier or any other person will be recorded in the non-cash incentives register. The register will be available on the premises should a client wish to obtain further details.

Personal Interest includes:

  • Instances where the FSP sells the product of a smaller product provider company in which the FSP has a financial interest- for example, is a shareholder in the company.
  • Instances where the interest is other than a reasonable amount of commission,
  • Instances where the FSP partakes in some sort of profit share with the product provider company.

Non-cash incentives include:

  • offshore trips, seminars, holidays or other substantial gifts offered where there is an expectation to do, give or provide something in return for the product provider;
  • prizes or incentives offered to the FSP to reach a certain sales target for a specific product;
  • special commission rate given to the FSP if the FSP sell’s a certain product;
  • Small gifts such as lunches, golf days, rugby tickets, promotional will also be recorded in the register of non-cash incentives.

Fair Treatment of the Client:

At all times the FSP must be able to show that where there were similar products that may have been suitable with similar benefits, that the product recommended would have been recommended regardless of the incentive offered to the FSP.



The Allan Gray-Orbis Global Equity Feeder Fund remains fully invested in global equities. The objective of the Fund is to outperform the FTSE World Index at no greater-than average risk of loss in its sector.