Privacy and POPIA Notice.

1. Responsible party

Gain Africa Investments (Pty) Ltd, registration number 2012/049682/07, is the responsible party for personal information processed through this website and its general corporate enquiry channel.

Address: Infinity Business Park, Block B, 4 Pieter Wenning Road, Witkoppen Ext, Fourways, Sandton, South Africa, 2191.
Privacy and POPIA contact: [email protected].

2. Scope

This Notice applies to personal information collected when a person visits the Gain Africa website, submits an enquiry, communicates with Gain Africa about an investment opportunity or corporate matter, or otherwise interacts with the website.

Portfolio companies may be responsible parties for information collected through their own websites and business processes. Their privacy notices apply to those interactions.

3. Personal information we may collect

Depending on the interaction, Gain Africa may collect:

• name, email address, organisation, position and country;
• enquiry category, project name, commodity, project stage and general project location;
• the content of messages and subsequent correspondence;
• information about a submitting party's authority, ownership or professional role;
• technical information ordinarily generated by web servers, such as IP address, browser type, date, time, requested pages and security events; and
• additional information voluntarily supplied during a subsequent, controlled due-diligence process.

The public form is not intended for identity documents, precise mine coordinates, passwords, bank details, special personal information or confidential technical records.

4. Why we process personal information

Gain Africa may process personal information to:

• receive, assess, route and respond to enquiries;
• screen potential mining, partnership and portfolio-company opportunities;
• conduct authorised due diligence and transaction discussions;
• manage business relationships and communications;
• protect the website, prevent spam, fraud and unauthorised use;
• maintain legal, corporate, risk and governance records;
• comply with applicable law, lawful requests and regulatory obligations; and
• establish, exercise or defend legal rights.

Processing is based on the circumstances and may be necessary to take steps requested by the person, perform or manage an agreement, comply with law, protect legitimate interests, or occur with consent where consent is appropriate.

5. Sharing and recipients

Gain Africa does not sell personal information. Information may be shared, where necessary and proportionate, with:

• authorised Gain Africa directors, employees and advisers;
• BEMC, CIM Supplies or another controlled entity where the enquiry relates to that business;
• technical, hosting, email, security and professional-service providers subject to appropriate duties;
• potential transaction partners under suitable confidentiality and due-diligence arrangements;
• regulators, courts, law-enforcement bodies or other persons where required or permitted by law; and
• a successor or transaction counterparty in a lawful corporate reorganisation, subject to appropriate safeguards.

6. Cross-border processing

Gain Africa and its portfolio companies operate across more than one country and may use service providers whose systems are located outside South Africa. Where personal information is transferred across borders, Gain Africa will seek to apply safeguards appropriate to the information, purpose, recipient and applicable law.

7. Retention

Personal information is retained only for as long as reasonably necessary for the purpose for which it was collected, related business and governance requirements, legal obligations, dispute management and the establishment, exercise or defence of rights. Information that is no longer required will be deleted, destroyed or de-identified where reasonably practicable.

8. Security

Gain Africa applies reasonable technical and organisational measures appropriate to the nature of the information and foreseeable risks. Measures may include encrypted transmission, access controls, secure hosting, confidentiality obligations, rate limiting, bot protection, backups, vendor controls and incident-response procedures.

No internet transmission or information system is completely secure. Visitors should avoid submitting highly sensitive information through the public form.

9. Cookies and analytics

The initial Gain Africa website is designed without advertising trackers or non-essential analytics cookies. Essential technical mechanisms may be used for security, form processing and reliable website operation. If non-essential analytics or marketing technologies are introduced, this Notice and any required consent mechanism will be updated.

10. Your rights

Subject to POPIA and other applicable law, a person may request confirmation of whether Gain Africa holds personal information about them and may request access, correction or deletion; object to certain processing; withdraw consent where processing depends on consent; or complain about the handling of personal information.

Requests should be sent to [email protected]. Gain Africa may need to verify identity and authority before acting on a request.

11. Direct marketing

Submitting a corporate or investment enquiry does not automatically subscribe a person to marketing. Where Gain Africa wishes to send electronic direct marketing, it will apply the consent, existing-customer and opt-out requirements applicable to the communication.

12. Contact and complaints

Gain Africa privacy contact: [email protected].

A person may also lodge a complaint with the Information Regulator (South Africa). Current contact and complaint channels are available on the Information Regulator's official website.