Privacy and Cookie Notice

1. MCH Advisory (Pty) Ltd is responsible for your personal information. Our Information Officer can be contacted at contact@mchadvisoryservices.com.
2. We collect what we need to run your account and subscription, deliver and improve the research service, keep it secure and meet our legal obligations.
3. We do not sell your personal information and we do not use advertising or tracking cookies.
4. We send marketing only if you opt in, and you can unsubscribe at any time.
5. Our service providers (for example, hosting, e-mail and Paystack) may process your information outside South Africa under appropriate safeguards.
6. You may ask to access, correct or delete your information, object to processing, and complain to the Information Regulator or your local privacy regulator.

1.1 MCH Advisory (Pty) Ltd (registration number 2022/804419/07), trading as MCH Analysis (“MCH”, “we”), is the responsible party (controller) for the personal information described in this Notice. Our address is 109 Wildebees Street, Waterkloof Ridge, Pretoria, 0181, Gauteng, South Africa.

1.2 Our Information Officer is Marinus Heymann (Managing Director), who can be contacted at contact@mchadvisoryservices.com for any privacy question, request or complaint.

1.3 This Notice explains how we process personal information in connection with the MCH Analysis platform and website (the “Service”). It is a notice, not a contract, and is read together with the MCH Analysis Subscriber Agreement.

2.1 Do not send us information about your personal finances, holdings or investment objectives. We do not need it, and we do not use it to tailor research to you.

3.1 We do not use any personal information to adapt the content of our research to you. Research is the same for all subscribers on a Plan.

3.2 We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

3.3 An internal marketing lead score may be derived from your country and, for Desk enquiries, your organisation type. It is not a determination of your legal investor status and never changes the research you see.

4.1 We send electronic marketing only if you have given consent on our separate marketing consent form (which we present to you once, and on which neither option is pre-selected), or if you are an existing subscriber and the message concerns our similar products or services. Accepting the Subscriber Agreement is not consent to marketing.

4.2 Every marketing message identifies MCH and contains an unsubscribe link. You may also opt out by e-mailing contact@mchadvisoryservices.com. Opting out does not stop operational messages such as receipts, renewal and price-change notices, security alerts and changes to our terms.

5.1 We share personal information only with operators (processors) that help us provide the Service, under written agreements requiring them to keep it secure and use it only on our instructions: hosting and infrastructure providers (including Vercel), our payment provider (Paystack), our e-mail delivery provider (Brevo), and our professional advisers.

5.2 We may also disclose information where the law requires it, to protect our rights or the security of the Service, or to a purchaser of our business on the same terms as this Notice. We do not sell personal information or share it for cross-context behavioural advertising.

6.1 Some of our operators store or process information outside South Africa, including in the United States and the European Union. We transfer personal information only where the recipient is subject to a law, binding corporate rules or a binding agreement that provides an adequate level of protection, where the transfer is necessary to perform our contract with you, or where you consent, as required by section 72 of the Protection of Personal Information Act 4 of 2013 (“POPIA”). For subscribers in the United Kingdom or the European Union, transfers are made under the safeguards required by the applicable data-protection law, such as standard contractual clauses.

8.1 We use appropriate technical and organisational measures to protect personal information, including encryption in transit, access controls, hashed passwords and processor agreements. If a security compromise affects your personal information, we will notify you and the Information Regulator as required by law.

9.1 Subject to the law that applies to you, you may:

• 9.1.1 ask whether we hold your personal information and for a copy of it;
• 9.1.2 ask us to correct or delete it;
• 9.1.3 object to processing based on legitimate interests or for direct marketing;
• 9.1.4 withdraw consent at any time (without affecting earlier processing); and, where applicable,
• 9.1.5 ask for your information in a portable format or for processing to be restricted.

9.2 To make a request, e-mail contact@mchadvisoryservices.com. We may need to verify your identity. We will respond within the period the law requires and will not treat you less favourably for exercising your rights. You may authorise an agent to make a request for you.

9.3 If you are not satisfied with our response, you may complain to the Information Regulator (South Africa) or to the data-protection authority where you live.

10.1 United States. In the last 12 months we have collected the categories of information in clause 2 (identifiers, commercial information, internet activity, approximate geolocation and, if you provide it, professional information) from the sources and for the purposes described in clauses 2 and 3, and disclosed them to the service providers described above. We do not sell or share personal information, and we do not use or disclose sensitive personal information. Residents of California and other states with comprehensive privacy laws have the rights described in clause 9, including the right to know, correct and delete, and to non-discrimination. Requests may be made by e-mail to contact@mchadvisoryservices.com.

10.2 United Kingdom and European Union. Our lawful bases are set out in clause 3. You have the rights set out in clause 9 and may complain to your supervisory authority.

11.1 The Service is not intended for anyone under 18, and we do not knowingly collect personal information from children.

12.1 Cookies are small files placed on your device when you visit a website. Similar technologies include local storage and pixels.

13.1 Because we use only strictly necessary cookies, we do not display a cookie-consent banner. If we introduce any non-essential cookies, we will ask for your consent before setting them and update this Notice.

13.2 Our payment provider, Paystack, may set its own cookies on its checkout pages, governed by its own policy.

14.1 You can block or delete cookies in your browser settings. Blocking strictly necessary cookies will prevent you from signing in.

15.1 We may update this Notice. We will notify subscribers of material changes by e-mail or on the Service. The version and effective date appear at the top.