1. Introduction

Vocifer Fund I GP Proprietary Limited (Registration Number: 2026/071263/07) (“Vocifer”, “we”, “us”, or “our”) is committed to protecting the privacy and personal information of all persons who visit or interact with our website at [WEBSITE URL] (the “Website”).

This Privacy Policy (“Policy”) describes how we collect, use, store, share, and protect personal information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and, where applicable, and other applicable data protection legislation.

By using the Website, you acknowledge that you have read and understood this Policy and consent to the processing of your personal information as described herein. If you do not agree with this Policy, please do not use the Website.

2. Definitions

“Personal Information” means information relating to an identifiable, living, natural person (or, where applicable, an existing juristic person), including but not limited to name, email address, telephone number, IP address, and any other information that may directly or indirectly identify a person, as defined in POPIA.

“Processing” means any operation or activity in relation to personal information, including collection, recording, organisation, storage, updating, retrieval, use, dissemination, or destruction.

“Responsible Party” means Vocifer Fund I GP Proprietary Limited, as the entity that determines the purpose and means of processing personal information.

“Data Subject” means you, the individual whose personal information is being processed.

3. Personal information we collect

3.1 Information you provide directly

We may collect personal information that you voluntarily provide to us, including when you:

• complete a contact form or enquiry form on the Website;
• subscribe to updates, a newsletter, or any mailing list;
• download documents or request information from the Website;
• correspond with us by email or other means.

This may include your name, email address, telephone number, company name, and the content of your communications with us.

3.2 Information collected automatically

When you visit the Website, we may automatically collect certain technical and usage information, including:

• your IP address and approximate geographic location;
• browser type and version;
• device type and operating system;
• pages visited, time spent on pages, and referring URLs;
• cookies and similar tracking data (see clause 6 below).

This information is collected using cookies and analytics tools (such as Google Analytics or similar services) to help us understand how the Website is used and to improve our services.

3.3 Information we do not collect

The Website is informational in nature. We do not process payment card information, conduct financial transactions, or collect sensitive personal information (such as identity numbers, biometric data, or health information) through the Website. If we need to collect any sensitive information in future, we will do so only with your explicit consent and in compliance with POPIA.

4. How we use your personal information

We process personal information only for lawful, specific, explicitly defined, and legitimate purposes. We may use your personal information to:

• respond to your enquiries or requests submitted through the Website;
• send you information about Vocifer’s activities, investments, or updates that you have requested or consented to receive;
• administer, improve, and personalise your experience on the Website;
• conduct analytics and monitor Website performance and security;
• comply with our legal and regulatory obligations;
• enforce our Terms and Conditions and protect our rights.

We will not use your personal information for purposes that are incompatible with those for which it was collected, without your prior consent.

5. Lawful basis for processing

Under POPIA and, where applicable, the GDPR, we process personal information on the following lawful bases:

• Consent: where you have given us your explicit consent to process your information for a specific purpose (e.g. subscribing to updates);
• Legitimate interests: where processing is necessary for our legitimate business interests (e.g. improving the Website, responding to enquiries), provided these are not overridden by your rights;
• Legal obligation: where processing is required to comply with a legal or regulatory obligation;
• Contract: where processing is necessary to perform a contract with you, or to take steps at your request prior to entering into a contract.

6. Cookies and tracking technologies

6.1 What are cookies

Cookies are small text files placed on your device when you visit a website. They are widely used to make websites work more efficiently and to provide information to website operators.

6.2 Cookies we use

We may use the following categories of cookies:

• Strictly necessary cookies: essential for the Website to function properly. These cannot be disabled.
• Analytics cookies: used to understand how visitors interact with the Website (e.g. Google Analytics). These cookies collect information in an anonymised or pseudonymised form.
• Preference/functional cookies: used to remember your preferences and settings to improve your experience.

6.3 Managing cookies

You may control or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website. Further information about managing cookies is available at https://www.aboutcookies.org. Where required by applicable law, we will obtain your consent before placing non-essential cookies on your device.

7. Sharing of personal information

We will not sell, rent, or trade your personal information to third parties. We may share your personal information in the following circumstances:

• Service providers: we may share personal information with trusted third-party service providers who assist us in operating the Website or providing services (such as IT support, analytics providers, or email platforms). These parties are contractually bound to process personal information only on our instructions and in accordance with applicable data protection law.
• Legal requirements: we may disclose personal information if required to do so by law, court order, or regulatory authority, or where we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud.
• Business transfers: in the event of a merger, acquisition, or sale of all or part of Vocifer’s business, personal information may be transferred as part of that transaction. We will notify affected data subjects in such circumstances.

8. International transfers of personal information

Where personal information is transferred to third parties or service providers located outside South Africa, we will ensure that an adequate level of protection is in place as required by POPIA (section 72) and, where applicable, the GDPR. This may include relying on adequacy decisions, standard contractual clauses, or other appropriate safeguards. We will not transfer personal information to a foreign country without implementing appropriate protections.

9. Retention of personal information

We will retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law or regulation. When personal information is no longer required, it will be securely deleted or anonymised. Our standard retention periods are as follows:

• Contact form submissions: retained for up to 3 years from the date of submission, unless a longer period is required by law;
• Analytics data: retained in accordance with the settings of the relevant analytics platform (typically up to 26 months);
• Legal and compliance records: retained for the period required by applicable law.

10. Security of personal information

We implement reasonable and appropriate technical and organisational measures to protect personal information against unauthorised access, loss, destruction, disclosure, or alteration. These measures include encryption of data in transit (SSL/TLS), access controls, and regular security assessments. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

In the event of a personal information breach that poses a risk to data subjects, we will notify the Information Regulator and affected data subjects as required by POPIA.

11. Your rights as a data subject

Subject to applicable law, you have the following rights in respect of your personal information:

• Right of access: the right to request confirmation of whether we hold personal information about you and to obtain a copy of that information.
• Right to correction: the right to request that inaccurate, incomplete, or outdated personal information be corrected or updated.
• Right to erasure/deletion: the right to request the deletion of your personal information in certain circumstances (e.g. where it is no longer necessary for the purpose for which it was collected).
• Right to object: the right to object to the processing of your personal information for direct marketing purposes or where processing is based on our legitimate interests.
• Right to withdraw consent: where processing is based on your consent, the right to withdraw that consent at any time, without affecting the lawfulness of processing prior to withdrawal.
• Right to lodge a complaint: the right to lodge a complaint with the Information Regulator of South Africa (details below) if you believe your personal information rights have been violated.

To exercise any of the above rights, please contact our Information Officer using the details in clause 14. We will respond to your request within a reasonable period, and in any event within the timeframes prescribed by POPIA.

12. Information regulator (South Africa)

If you believe we have handled your personal information unlawfully or in violation of POPIA, you have the right to lodge a complaint with the Information Regulator of South Africa:

The Information Regulator (South Africa)

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

Email: inforeg@justice.gov.za

Website: https://www.inforegulator.org.za

13. Children’s privacy

The Website is not directed at children under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete it promptly.

14. Amendments to this policy

We may update this Policy from time to time to reflect changes in our practices or applicable law. Any amendments will be posted on the Website with an updated effective date. Your continued use of the Website after such updates constitutes acceptance of the revised Policy.

15. Contact and information officer

For any queries, concerns, or requests relating to this Policy or the processing of your personal information, please contact our Information Officer:

Information Officer

Vocifer Fund I GP Proprietary Limited

2nd Floor, 8 Melville Road, Illovo, Johannesburg, Gauteng, 2196

Email: vocifer@vocifer.africa

Tel: +27 72 113 9050