PRIVACY NOTICE

1. POPI Act

You can access the Protection of Personal Information Act (the POPI Act by accessing the Act in website form at https://popia.co.za/

2. Introduction

AQUACHROME (PTY) LTD (”, we”, “us”) understand the critical importance of safeguarding your personal information. We adhere to the principles set out in the Protection of Personal Information (“POPI”) Act. Your privacy and personal information are of utmost importance to us, and we are dedicated to collecting and using this information in a manner that is appropriate, lawful, and transparent. Our privacy notice, alongside the Promotion of Access to Information Act (“PAIA”) and our POPIA manual, aims to inform you about our policies regarding the use of the data and personal information we collect, as well as your rights as a data subject.

This Privacy Notice details the following aspects:

• How we collect personal information.
• The types of personal information we collect and maintain.
• The purposes for which we utilize this personal information.
• The entities with whom we share your personal information, as needed.
• Your rights regarding the personal information we hold.

3. About US

AQUACHROME is a reputable company within the chrome mining sector. Our information is as follows:

4. About Personal Information

According to the POPI Act ‘‘personal information’’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. Please refer to POPIA for a detailed definition and various types or categories of personal information.

Personal information encompasses:

• Information automatically collected when you visit our website.
• Information gathered during registration.
• Information collected through our business activities. ● Optional information that you voluntarily provide.

but excludes:

• Anonymous information that cannot identify a specific individual (juristic or natural).
• Permanently de-identified data that neither relates to nor can be traced back to you.
• Non-personal statistical data that we compile.

5. How We Collect Personal Information

We collect information about you directly from you, including additional information on a voluntary basis (optional information), as well as from third parties when permitted and consented to, and from publicly accessible sources, including:

From our website

AQUACHROME uses traffic log cookies to create sessions per user, identifying the pages visited and session duration. This helps us analyze web traffic data to improve the website and tailor it to customer needs. This information is used solely for statistical analysis and does not track any personal information without consent. Additionally, we collect information directly from you when you submit a contact form on our website, enabling us to engage with your enquiry. This includes your name, email address, and any other personal information you voluntarily provide through uploaded documents.

How We Collect Information about Clients

1. Direct Interactions

We gather information directly from our clients through various interactions, such as:

• Consultation Meetings: During initial consultations and ongoing meetings, clients provide us with personal and business information necessary for our services.
• Contact Forms: Clients fill out contact forms on our website or in person, providing details like their name, email address, phone number, and specific inquiries.
• Surveys and Feedback: Through surveys and feedback forms, clients share their experiences and preferences, helping us improve our services.

2. Online Interactions

Our digital platforms facilitate the collection of client information through:

Website Visits: We use cookies and other tracking technologies to collect data on website usage, including pages visited, session durations, and interactions, to enhance user experience.

Online Accounts: Clients who create accounts on our website provide information such as login credentials, profile details, and transaction history.

Social Media: Engagements on our social media pages, including comments, messages, and shared content, help us gather insights into client preferences and interactions.

3. Business Transactions

Information is collected during business transactions, including:

Service Agreements: Details exchanged during the drafting and signing of service contracts, including client contact information, service requirements, and financial details.

Invoicing and Payments: Processing invoices and payments involves collecting billing information, payment methods, and transaction records.

4. Third-Party Sources

We may also obtain client information from third-party sources, such as:

Business Partners: Information shared by our business partners about mutual clients, ensuring a seamless service delivery.

Public Databases: Information from publicly accessible databases and directories to verify and update client records.

Referrals: Data received through client referrals, including contact details and background information.

From job candidates and employees

We collect data from you when you provide personal information during the employer-employee relationship. This also includes data from our business partners and individuals employed to provide services for us, such as background verification, security, debt collection, communications, and data hosting, processing, and management services.

From suppliers and service providers

We collect and process information about you or your employees, provided directly to register as a supplier or collected during service delivery. This includes names, contact details, billing information, account details, identity numbers, and places of business and residence. Information may also come from our business partners and employees providing services such as background verification and authentication.

From other third parties

We may collect and process information from public registers, credit bureaus, money laundering, fraud prevention, and law enforcement agencies to protect both us and our data subjects. This includes information from legally entitled entities and entities you consent to providing us with information about you.

6. Purpose For Processing Personal Information

We may use or process any personal or optional information you provide for the purposes indicated when you agreed to share it with us. Processing includes gathering, disclosing, and combining your personal information with other data.

We generally collect and process your personal information for various purposes, including:

• General Correspondence and Enquiries: Handling communication and responding to inquiries.
• Recruiting and Staff Administration: Managing recruitment, employee, contractor, and general staff administration.
• Contract Administration: Administering contracts and agreements.
• Record Keeping: Maintaining accounts, registers, and records.
• Procurement: Sourcing, utilizing, and paying for goods and service providers.
• Customer Services: Providing products and services to customers.
• Health and Safety: Complying with health and safety obligations, such as controlling access to premises, conducting consultation processes, health monitoring, security and safety monitoring, investigating incidents, and fulfilling legal appointments.
• Environmental Obligations: Ensuring compliance with environmental impact assessments and handling environmental concerns.
• We may also use the information we hold about you for purposes required by or permitted under applicable law, such as:
• Fraud Prevention: Preventing, investigating, and prosecuting fraud, money laundering, terrorism, abuse of our services, and other unlawful activities.
• Legal and Regulatory Compliance: Complying with legal and regulatory requirements, conducting audits, and participating in legal proceedings, including identifying and verifying clients, service providers, suppliers, etc., as part of our due diligence checks.
• Consent-Based Purposes: For other purposes you may consent to or as otherwise lawfully permitted, including protecting our legitimate interests and those of our suppliers and clients.

7. Consent

You may only provide us with your own personal information or the information of another data subject if you have their permission. Where necessary, we will obtain your consent to collect personal information:

1. Inaccordance with applicable laws.
2. When you provide us with any registration information or optional details.

8. Sharing information

Ensuring the security of your personal information is one of our top priorities. We will not disclose your personal information unless legally permitted to do so. Except as outlined below, we will not transfer your personal information to third parties without your consent unless required by law.

Notably, we do not sell lists or databases containing personal information of our data subjects and will not provide your personal information to entities outside our group for marketing purposes.

We may share your personal information with third parties, including:

• Employees and affiliated company staff who need your information to perform their duties, including our directors, employees, contractors, agents, auditors, legal and other professional advisors.
• Governmental, judicial, regulatory, and law enforcement bodies and agencies, such as the South African Revenue Service.
• Entities or organizations engaged by us, including fraud prevention agencies, to detect and prevent potentially illegal activities and policy violations.
• Goods or services providers under contract who assist in business operations, such as client and account verification, electronic or cash payment services, income collection, marketing, and technology services. Our contracts stipulate that these providers only use your information in connection with the services they provide to us.
• Persons to whom we subcontract, cede, delegate, transfer, or assign any of our rights or obligations relating to the services provided to you or contracts concluded with you.
• Individuals acting as your legal guardian, executor of your estate, curator, or in a similar capacity.
• Any other persons as permitted by applicable law or to whom you may consent.
• This ensures we protect your personal information while fulfilling our obligations and providing necessary services.

9. Legal Disclosure

We may disclose your personal information when required by law or during a governmental audit. Additionally, we may disclose personal information if necessary:

• By a subpoena or court order.
• To comply with any law.
• To protect the safety of any individual or the public.
• To prevent violations of our contractual terms.

10. Information Security

We are legally obligated to provide adequate protection for the personal information we hold and to prevent unauthorized access and use. We continually review our security controls and related processes to ensure that your personal information remains secure.

Our security policies and procedures encompass physical security, computer and network security, access to personal information, secure communications, information retention and disposal, acceptable usage of personal information, governance and regulatory issues, monitoring access and usage, and investigating and responding to security incidents.

When contracting with third parties, we impose appropriate security, privacy, and confidentiality obligations to ensure that personal information remains secure. We ensure that anyone who receives your personal information agrees to provide the same level of protection as we are obliged to.

11. Transfer of Personal Information

We may send personal information outside South Africa to various countries. However, we will only transfer data to countries with similar privacy laws to South Africa’s that provide adequate protection, or to recipients who can guarantee the protection of personal information to the same standard we must uphold.

12. Accurate & Up-To-Date Information

We strive to keep the personal information we collect accurate, current, complete, confidential, and reliable for the purposes defined in this statement. We may occasionally request you to update your personal information. If any of your information changes, please contact us to correct it.

13. Personal Information Retention

We may retain your personal information in physical or electronic records at our discretion but will only do so as long as necessary to fulfill the purposes explicitly stated, unless retention is required or authorized by law, or you have consented to it. We maintain a Record Retention and Disposal Schedule to ensure records are retained only as long as necessary and are destroyed as soon as practical after the retention period expires.

During the retention period, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.

14. Your Rights & Our Obligations

If we require your consent to obtain and use your data, you may withdraw your consent at any time by notifying us in writing. We will maintain your data on our records for as long as we have your consent.

For lawful bases other than consent, you have the right to object to processing at any time by following the instructions in our PAIA and POPIA manual. You also have the right to request us to update, correct, or delete your information, or to request a copy of the personal information we hold about you at any time by following the instructions in our PAIA and POPIA manual.

Please note that such access requests may be subject to a legally allowable fee. Refer to our PAIA and POPIA manual for more details.

15. Contact Us

If you have any concerns about the processing of your personal information or wish to exercise any rights outlined in clause 13 of this document, please notify us via email sam@aquachrome.co.za. We will inform you of the steps taken in response to your request. Note that we are not obliged to provide information or agree to requests to the extent that doing so is prohibited by applicable law, would unreasonably prejudice our legitimate interests or those of a third party, or if we have a legal basis for denying the request. Please allow a reasonable period for us to comply with your request.

16. Complaints

You have the right to complain about our processing of your information by contacting us at sam@aquachrome.co.za. If we do not respond to your full satisfaction, you can escalate the complaint to the Regulator’s Office using the contact details provided in our PAIA and POPIA manual.