Privacy Policy
Foresight Growth Partners Pty Ltd
Effective Date: 22 March 2026
1. Introduction
This Privacy Policy explains how Foresight Growth Partners Pty Ltd (“we,” “us,” or “our”), a company registered in South Africa, collects, uses, stores, and discloses personal information in connection with our marketing and lead generation services for eye laser clinics.
We operate in compliance with the Protection of Personal Information Act, 2013 (POPIA) of South Africa and applicable United States federal and state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), where applicable.
By engaging our services, visiting our websites or landing pages, or submitting your personal information to us, you acknowledge that you have read and understood this Privacy Policy.
2. Responsible Party
For purposes of POPIA, the responsible party is:
Foresight Growth Partners Pty Ltd
Cape Town, South Africa
Email: janovin@foresightgrowthpartners.com
Where we process personal information on behalf of our clients (eye laser clinics), those clients are the responsible party and we act as an operator (processor) under a written agreement.
3. Categories of Personal Information We Collect
We may collect the following categories of personal information, depending on your interaction with us:
3.1 Prospective Patients (Leads)
Full name
Email address
Phone number
Location or region
Responses to qualifying questions (e.g., prescription strength, age, contact lens use)
Appointment and consultation booking details
Interaction data from landing pages, forms, and advertisements (e.g., IP address, browser type, pages visited)
Meta advertising identifiers and pixel data
3.2 Clients (Eye Laser Clinics)
Business and contact representative names
Email addresses and phone numbers
Billing and payment information
Business registration details
3.3 Website Visitors
IP address and device information
Cookies and tracking technologies (see Section 9)
Browsing behaviour on our websites and landing pages
4. Purpose of Processing and Legal Basis
We process personal information for the following purposes:
To deliver our contracted services: running Meta advertising campaigns, operating landing pages, nurturing and converting leads, and booking consultations on behalf of our clients.
To communicate with leads via email, SMS, WhatsApp, or phone for appointment booking and follow-up.
To administer client accounts, process invoicing, and manage billing.
To analyse campaign performance, optimise advertising, and generate reports for our clients.
To comply with legal obligations under South African and, where applicable, US law.
Under POPIA, our lawful bases for processing include: consent (Section 11(1)(a)), contractual necessity (Section 11(1)(b)), legal obligation (Section 11(1)(c)), and legitimate interest (Section 11(1)(f)).
Under the CCPA/CPRA, we process personal information as a “service provider” on behalf of our clients (the “businesses”) and for our own operational purposes as described above.
5. How We Collect Personal Information
Directly from you: when you complete a form on one of our landing pages, book a consultation, or contact us.
From our clients: when a clinic provides us with contact lists or patient enquiry data for campaign purposes.
Automatically: through cookies, Meta Pixel, server logs, and similar tracking technologies when you interact with our digital properties.
6. Sharing and Disclosure of Personal Information
We may share personal information with:
Our clients (eye laser clinics): lead and consultation data generated through our campaigns is shared with the relevant clinic as part of our service delivery.
Service providers and sub-processors: including Meta (Facebook/Instagram) for advertising, email and SMS platforms for lead nurturing, CRM and calendar booking systems, and hosting providers. All sub-processors are bound by written data processing agreements.
Legal and regulatory authorities: where required by South African law, US law, or a valid court order.
We do not sell personal information. For purposes of the CCPA/CPRA, we do not “sell” or “share” (as those terms are defined under California law) the personal information of California residents for cross-context behavioural advertising on our own behalf. Where Meta Pixel or similar tools transmit data to advertising platforms, this is done solely as an operator acting under our client’s instructions.
7. Cross-Border Transfers
Our services involve the transfer of personal information across international borders, including between South Africa and the United States. We may also transfer data to servers or sub-processors located in other jurisdictions.
Under POPIA (Section 72), we ensure that cross-border transfers are made only to jurisdictions with adequate data protection laws, or subject to binding agreements that provide an adequate level of protection, or with the data subject’s consent.
8. Retention of Personal Information
We retain personal information only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law.
Lead data is retained for the duration of our engagement with the relevant client, plus a reasonable wind-down period not exceeding 12 months after termination.
Client data is retained for 5 years after the end of the contractual relationship to comply with South African tax and business record-keeping requirements.
Anonymised or aggregated data used for campaign analytics may be retained indefinitely.
9. Cookies and Tracking Technologies
Our websites and landing pages use cookies and similar technologies, including the Meta Pixel, to measure advertising effectiveness, build retargeting audiences, and optimise campaign performance.
You can manage cookie preferences through your browser settings. Disabling cookies may affect the functionality of our landing pages.
10. Your Rights
10.1 Under POPIA (South African Residents)
You have the right to:
Request access to your personal information held by us.
Request correction or deletion of inaccurate or outdated personal information.
Object to the processing of your personal information on reasonable grounds.
Withdraw your consent at any time (where consent is the basis of processing).
Lodge a complaint with the Information Regulator (South Africa).
10.2 Under CCPA/CPRA (California Residents)
If you are a California resident, you have the right to:
Know what personal information we collect, use, and disclose about you.
Request deletion of your personal information.
Request correction of inaccurate personal information.
Opt out of the sale or sharing of your personal information (note: we do not sell personal information).
Not be discriminated against for exercising your privacy rights.
10.3 How to Exercise Your Rights
To exercise any of the above rights, contact us at [INSERT EMAIL ADDRESS]. We will respond within 30 days (POPIA) or 45 days (CCPA/CPRA) of receiving a verifiable request.
11. Security Measures
We take reasonable technical and organisational measures to protect personal information against unauthorised access, loss, destruction, or damage. These measures include encrypted data transmission, access controls, secure hosting environments, and regular review of our security practices.
No method of electronic storage or transmission is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.
12. Children’s Privacy
Our services are not directed at individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without appropriate parental consent, we will take steps to delete it.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Material changes will be communicated by updating the effective date at the top of this document and, where practicable, by notifying affected parties directly.
14. Contact Us
If you have questions about this Privacy Policy, wish to exercise your rights, or have a complaint, please contact:
Foresight Growth Partners Pty Ltd
Cape Town, South Africa
Email: janovin@foresightgrowthpartners.com
For complaints regarding POPIA compliance, you may also contact:
The Information Regulator (South Africa)
Email: janovin@foresightgrowthpartners.com
Website: www.foresightgrowthparteners.com