POPIA PRIVACY POLICY & NOTICE

Effective Date: 1 September 2026 | Last Updated: September 2026

1. Introduction & Purpose

D-Portfolio Investments (Pty) Ltd ("the Company", "The Portfolio", "we", "us", or "our"), Registration Number 2024/004292/07, is committed to safeguarding the privacy of all visitors, clients, counterparties, and stakeholders in full compliance with the Protection of Personal Information Act, No. 4 of 2013 (POPIA) and applicable international data protection standards.

This Privacy Notice explains how we collect, use, disclose, retain, and protect personal and commercial information collected through our website (theportfolio.co.za) and direct communication channels.

2. Legal Entity & Information Officer

3. Categories of Information We Collect

We collect personal and business information necessary to deliver boutique strategic advisory, corporate real estate planning, and transaction facilitation services. This includes:

• Contact Information: Full name, corporate email address, telephone/WhatsApp number, designation, and company name.
• Commercial & Transaction Data: Project parameters, funding requirements, property portfolio specifications, commodity specifications, transaction scale, and counterparty mandates.
• Due Diligence & Verification Information: Corporate registration details, representative authority/mandates, KYC documentation, and proof of capability where required for transaction qualification.
• Technical Data: IP address, browser type, device information, operating system, and website usage statistics collected via cookies.

4. Lawful Basis and Purpose of Processing

We process personal and commercial data strictly for legitimate business purposes under the following lawful grounds:

• Client Consent: When you voluntarily submit consultation requests, inquiries, or opportunity briefs.
• Contractual Performance: To prepare, structure, negotiate, and execute advisory mandates and facilitation agreements.
• Compliance & Legal Obligations: To perform counterparty identification, sanctions screening, and fraud prevention in commercial transactions.
• Legitimate Interests: To maintain website security, optimize user experience, and communicate relevant market intelligence.

5. Data Sharing & Third Parties

We treat all commercial information with the highest degree of confidentiality under appropriate non-disclosure standards. We do not sell, rent, or trade your personal information. Information is only shared with:

• Qualified institutional counterparties, funders, or corporate partners strictly with your prior knowledge and consent.
• Vetted technical service providers (e.g., secure hosting, email infrastructure, CRM) under strict confidentiality agreements.
• Regulatory or law enforcement bodies where required by applicable South African or international law.

6. Cross-Border Data Transfers

Where commercial transactions or cloud infrastructure involve cross-border transmission of data across African corridors or international jurisdictions, we ensure recipient parties adhere to data protection standards substantially equivalent to POPIA.

7. Data Security & Storage

We employ industry-standard technical and organizational security measures—including SSL encryption, secure access controls, firewall protections, and restricted data access—to prevent unauthorized access, loss, alteration, or disclosure of your information.

8. Your Data Subject Rights under POPIA

Under POPIA, you hold the following rights regarding your personal information:

• Right of Access: Request confirmation of whether we hold your personal data and obtain a copy thereof.
• Right to Rectification: Request correction or updating of inaccurate, incomplete, or outdated data.
• Right to Deletion: Request the deletion or destruction of personal information no longer required for authorized purposes.
• Right to Object: Object to processing on reasonable grounds or withdraw consent at any time.
• Right to Complain: Lodge a complaint with the Information Regulator of South Africa (inforegulator.org.za) via email at complaints.IR@justice.gov.za.

9. Updates to this Policy

We reserve the right to modify this Policy periodically to reflect evolving legal, regulatory, or operational requirements. Updated versions will be published on this page with an updated effective date.