Privacy Policy

Effective Date: 18 June 2026 Company: FNA Solutions (Pty) Ltd trading as Consilium 360

FNA Solutions (Pty) Ltd trading as Consilium 360 (“we”, “us”, or “our”) is committed to protecting your privacy. This policy outlines how we collect, process, and protect the personal information of our Subscribers (Financial Advisors, FSPs, and website visitors).

(Important Note: For information regarding how we handle the sensitive financial data of YOUR clients that you input into our CRM and FNA calculators, please refer to our POPIA Compliance & Data Processing Statement, where we act strictly as the “Operator”).

1. Information We Collect as a Responsible Party

When you register for Consilium 360, browse our marketing website, or contact our sales team, we act as the Responsible Party and collect the following:

  • Identity & Contact Data: First name, last name, email address, physical address, and telephone numbers.

  • Professional Data: FSP license numbers, practice names, job titles, and regulatory verification details.

  • Financial & Billing Data: Bank account details or credit card tokens processed securely through our payment gateway (Netcash). We do not store raw credit card numbers on our servers.

  • Technical & Usage Data: IP addresses, browser types, operating systems, login timestamps, session durations, feature usage analytics, and device identifiers.

2. Purpose of Processing Your Data

We process your personal information to:

  • Provision, operate, support, and maintain your access to the Consilium 360 SaaS platform.

  • Process monthly or annual subscription billing.

  • Verify your identity and regulatory standing to prevent fraud.

  • Communicate with you regarding system updates, security alerts, and legislative changes impacting the calculators.

  • Analyze platform usage telemetry to troubleshoot bugs and improve UI/UX.

3. Data Security Measures

We implement rigorous, enterprise-grade security protocols to protect your data against unauthorized access, alteration, or destruction.

  • Our infrastructure is hosted on Google Cloud’s secure serverless architecture.

  • All data is encrypted in transit using TLS 1.2+ and encrypted at rest (AES-256).

  • Access to user accounts is protected by mandatory Two-Factor Authentication (2FA).

4. Disclosure to Third Parties (Sub-Processors)

We do not sell, rent, or trade your personal information. We only share necessary data with trusted third-party service providers (Sub-Processors) required to run our business. These include:

  • Cloud Hosting: Google Cloud Platform (GCP).

  • Payment Gateways: Netcash (for subscription processing).

  • Integrations: DocuSign (if you utilize the e-signature feature).

  • AI Providers: OpenAI or equivalent secure LLM API providers (utilized strictly for the generative text formatting of ROAs. Note: We use enterprise APIs where data is explicitly NOT used to train public AI models). We ensure all third parties are bound by strict confidentiality and data protection agreements compliant with South African law.

5. Cookies and Tracking Technologies

Our website and platform use cookies (small text files stored on your device) to:

  • Maintain your authenticated session (Strictly Necessary Cookies).

  • Remember your platform preferences (Functional Cookies).

  • Understand how users navigate our site to improve marketing (Analytics Cookies). You can configure your browser to refuse non-essential cookies, but doing so may limit your ability to use the Consilium 360 platform effectively.

6. Data Retention

We retain your account profile and billing information for as long as your subscription is active, and for a period of up to 5 years thereafter as required by South African accounting and tax legislation (SARS).

7. Your Rights Under POPIA

As a Data Subject, you have the right to:

  • Request access to the personal information we hold about you.

  • Request correction of inaccurate or outdated information.

  • Request deletion of your data (subject to our legal retention obligations).

  • Object to the processing of your data for direct marketing purposes.

To exercise these rights, please email our Information Officer at legal@consilium360.co.za. If you are unsatisfied with our handling of your data, you have the right to lodge a complaint with the Information Regulator of South Africa (inforeg@justice.gov.za).