Privacy Policy.

African Liberal Investments (Pty) Ltd ("Company", "we", "us" or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, process, store and disclose personal information when you interact with our Website, submit applications or engage with our services.

This Policy applies to all personal information collected by the Company through:

• Our Website at a-l-i.co.za and any associated subdomains.
• Online application forms, enquiry submissions and other digital interactions.
• Communications via email, telephone or other direct channels.
• Any other interaction where you provide personal information to us.

We process personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA) and other applicable South African data protection legislation. By using our Website and services, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal information as described herein.

If you do not agree with the terms of this Privacy Policy, please refrain from using our Website or providing us with your personal information.

We collect personal information that you voluntarily provide to us when you interact with our Website, submit applications or communicate with us. The types of personal information we may collect include:

• Identity Information: Full name, date of birth, identity number or passport number, nationality and country of residence.
• Contact Information: Email address, telephone numbers, physical address and postal address.
• Financial Information: Bank account details, income information, assets, liabilities, credit history and other financial data relevant to funding applications or investment participation.
• Employment Information: Employer details, occupation, employment status and professional background.
• Application Information: Details provided in funding applications, investment participation requests and related documentation.
• Technical Information: IP address, browser type, device information, operating system, referring URLs and browsing behaviour on our Website.
• Correspondence: Records of communications between you and the Company, including emails, letters and telephone recordings.

We collect information directly from you when you submit applications, complete forms or communicate with us. We may also collect information from third-party sources such as credit bureaus, identity verification services or public records, where permitted by law and with your consent, to verify the accuracy of information provided.

We use your personal information for the following purposes:

• Assessment and Evaluation: To assess your eligibility for funding or investment participation, evaluate applications and verify information provided.
• Service Delivery: To provide, manage and administer our services, including funding arrangements, investment structures and financial solutions.
• Communication: To respond to your enquiries, provide updates, send notifications and manage our relationship with you.
• Compliance: To comply with legal and regulatory obligations, including anti-money laundering (AML), counter-terrorism financing (CTF) and know-your-customer (KYC) requirements.
• Risk Management: To assess and manage financial, credit and operational risks associated with our services.
• Fraud Prevention: To detect, prevent and investigate fraud, impersonation and other unlawful activities.
• Improvement: To improve our Website, services and customer experience through analysis and feedback.
• Marketing: To send you information about our services, offers or updates, provided we have your consent or a lawful basis to do so. You may opt out at any time.

We will only process your personal information for purposes that are compatible with the purposes described in this Policy. If we intend to use your information for a new purpose, we will notify you and obtain your consent where required by law.

Under POPIA, we are required to process personal information lawfully and on a valid legal basis. The legal grounds we rely on include:

• Consent: You have given us explicit consent to process your personal information for specific purposes, such as marketing communications or processing special personal information.
• Contractual Necessity: Processing is necessary to enter into or perform a contract with you, including assessing applications, providing services and managing our relationship.
• Legal Obligation: Processing is required to comply with a legal or regulatory obligation, such as anti-money laundering, tax reporting or record-keeping requirements.
• Legitimate Interest: Processing is necessary for our legitimate business interests — such as fraud prevention, risk management, service improvement and operational efficiency — provided these interests do not override your fundamental rights and freedoms.

We may share your personal information with third parties in the following circumstances:

• Service Providers: Third-party vendors and service providers who assist us in delivering our services, including IT hosting, data storage, identity verification, credit assessment, payment processing and legal or professional advisory services. These providers are subject to strict confidentiality and data protection obligations.
• Regulatory Authorities: Government agencies, regulators, law enforcement bodies or other authorities where required by law, court order or regulatory directive.
• Financial Institutions: Banks, credit bureaus and other financial institutions involved in funding arrangements, investment structures or risk assessment processes, subject to applicable confidentiality and data protection requirements.
• Legal and Professional Advisors: External legal counsel, auditors, accountants and other professional advisors who assist us in managing our legal and compliance obligations.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of assets, your personal information may be transferred to the successor entity, subject to the continuation of this Privacy Policy.

We do not sell, rent or trade your personal information to third parties for marketing purposes. We only share information with third parties who demonstrate adequate levels of data protection and processing practices, and we ensure that appropriate data sharing agreements are in place.

We take the security of your personal information seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, disclosure, alteration, destruction or loss. Our security measures include:

• Encryption: Secure transmission of data using industry-standard encryption protocols (TLS/SSL) for all online interactions.
• Access Controls: Restricted access to personal information on a need-to-know basis, with role-based permissions and authentication requirements.
• Monitoring: Regular monitoring and auditing of systems for security vulnerabilities, intrusions and incidents.
• Training: Ongoing privacy and security awareness training for our employees and contractors.
• Policies: Comprehensive data protection policies, incident response plans and breach notification procedures.

In the event of a data breach that may affect your personal information, we will notify you and the relevant regulatory authorities in accordance with applicable laws and our breach notification procedures.

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting or reporting requirements.

Our retention periods are determined based on:

• The purpose for which we collected and processed the information.
• Any legal or regulatory obligations that require us to retain records for specific periods.
• The nature and sensitivity of the information.
• Potential risks of harm from unauthorised use or disclosure.
• Whether we need the information to resolve disputes, enforce agreements or defend legal claims.

Generally, we retain personal information for a period of five (5) years from the date of your last interaction with us, or for longer where required by law (such as financial records required under tax legislation).

When personal information is no longer needed, we securely delete or anonymise it to ensure it can no longer be associated with you.

The Protection of Personal Information Act 4 of 2013 grants you certain rights in relation to your personal information. We respect these rights and are committed to facilitating their exercise:

• Right of Access: You have the right to request access to the personal information we hold about you and to obtain a copy of that information.
• Right to Rectification: You have the right to request that we correct any inaccurate, incomplete or outdated personal information we hold about you.
• Right to Deletion: You have the right to request that we delete or destroy your personal information where there is no lawful basis for continued processing.
• Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes or where processing is based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time.
• Right to Complain: You have the right to lodge a complaint with the Information Regulator of South Africa if you believe your rights have been infringed.

There may be circumstances where we are unable to comply with your request due to legal, regulatory or other lawful obligations. In such cases, we will explain the reasons for our decision and your right to escalate the matter if you are not satisfied.

Our Website uses cookies and similar tracking technologies to enhance your browsing experience, analyse traffic and improve our services. Cookies are small text files placed on your device that help us remember your preferences and understand how you interact with our Website.

We use the following categories of cookies:

• Essential Cookies: Necessary for the Website to function properly, including security, navigation and session management. These do not require consent.
• Analytics Cookies: Help us understand how visitors use the Website, which pages are visited most frequently and how we can improve user experience. We use analytics tools that collect anonymised data.
• Preference Cookies: Remember your preferences and settings to personalise your experience, such as language or region preferences.

You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies, but please note that disabling essential cookies may affect the functionality of the Website.

We do not use cookies for advertising or marketing purposes without your explicit consent. You may opt out of non-essential cookies at any time using the cookie settings on our Website.

If you have any questions, concerns or requests regarding this Privacy Policy, our data processing practices or your personal information, please contact us using the details below.

Information Regulator of South Africa

If you are not satisfied with our response to your privacy request, you have the right to lodge a complaint with the Information Regulator:
www.inforegulator.org.za

Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements or regulatory guidance. The most current version will always be available on our Website, with the effective date indicated at the top of the Policy. We encourage you to review this Policy periodically and check for updates. Your continued use of our Website and services after any changes constitutes your acceptance of the revised Policy.