Privacy Policy

Last updated: 12 October 2026

1. Who we are

Arctern Advisory (Pty) Ltd ("Arctern," "we," "us," or "our") is a company registered in the Republic of South Africa (registration number 2026/595753/07).

Arctern refers individuals and families to accredited, independently licensed merit-based immigration programs in Portugal, Malta, Luxembourg, the Caribbean, South America, and Vanuatu, and facilitates referral relationships with wealth managers and financial advisors. This Privacy Policy explains how we collect, use, share, and protect personal information in connection with our website and services, in accordance with the Protection of Personal Information Act, 4 of 2013 ("POPIA").

2. Information Officer

Our appointed Information Officer is: Cameron van Rensburg, contactable at cameron@arcternadvisory.com. If our Information Officer registration with the Information Regulator is still pending at the time you are reading this, please contact us using the details in Section 13 below and we will direct your query appropriately.

3. What personal information we collect

We collect personal information you provide directly to us, including:

• Contact details — name, email address, phone number;
• Enquiry details — your relocation goals, timeline, family situation, and any other information you choose to share with us through our enquiry forms or in correspondence;
• Partner details — if you are a wealth manager, financial advisor, or other professional partner, your firm name, role, and professional contact details;
• Referred client information — where a partner refers a prospective client to us, limited contact and enquiry information about that individual, shared with us by the referring partner; and
• Technical information — such as browser type and general usage data collected through cookies or similar technologies (see Section 7).

4. How we use personal information

We use personal information to:

• Respond to and manage your enquiry;
• Assess which merit-based immigration programs may be relevant to your circumstances;
• Introduce you to accredited, independently licensed program administrators and professionals in Portugal, Malta, Luxembourg, the Caribbean, South America, or Vanuatu, where you have consented to such an introduction;
• Manage our referral partner relationships, including tracking referrals and calculating referral fees;
• Communicate with you about your enquiry or our services; and
• Meet our legal, regulatory, and contractual obligations.

We do not use personal information for automated decision-making that produces legal or similarly significant effects concerning you.

5. Lawful basis for processing

We process personal information on the basis of your consent (for example, when you submit an enquiry form), to take steps at your request prior to entering into a referral arrangement, and, where relevant, to comply with our legal obligations.

6. Cross-border transfer of information

Because Arctern refers clients to program administrators and licensed professionals located in Portugal, Malta, Luxembourg, the Caribbean, South America, and Vanuatu, your personal information may be transferred outside South Africa as part of making that introduction. We only make such a transfer with your consent, and we take reasonable steps to ensure that the recipient is subject to a law, binding corporate rules, or a binding agreement that provides an adequate level of protection substantially similar to POPIA's conditions for lawful processing.

If you have questions about a specific cross-border transfer relevant to your enquiry, contact us using the details in Section 13.

7. Cookies and similar technologies

Our website may use cookies or similar technologies to support basic site functionality and, where enabled, to understand how visitors use our site. You can control cookies through your browser settings.

8. Sharing your information

We share personal information with:

• Accredited, independently licensed program administrators and professionals in Portugal, Malta, Luxembourg, the Caribbean, South America, or Vanuatu, where you have consented to an introduction;
• Referral partners (such as your wealth manager or financial advisor), where relevant to your enquiry;
• Service providers who support our operations (for example, our website form and email providers), under appropriate confidentiality terms; and
• Regulators or authorities, where required by law.

We do not sell personal information.

9. Your rights

Subject to POPIA, you have the right to: request access to the personal information we hold about you; request that we correct or update it; request that we delete it, subject to any legal retention requirements; object to our processing of it on reasonable grounds; and withdraw consent you previously gave, without affecting processing carried out before that withdrawal.

To exercise any of these rights, contact us at cameron@arcternadvisory.com. You also have the right to lodge a complaint with South Africa's Information Regulator.

10. Data retention

We retain personal information only for as long as necessary to fulfil the purposes described in this policy, or as required by law, after which it is securely deleted or anonymised.

11. Security

We take reasonable technical and organisational measures to protect personal information against loss, unauthorised access, alteration, or disclosure.

12. Changes to this policy

We may update this Privacy Policy from time to time. The "last updated" date at the top of this page reflects the most recent revision.

13. Contact us

For any questions about this Privacy Policy or how we handle your personal information, contact us at cameron@arcternadvisory.com.