Privacy Policy – Processing of Personal Information

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We are committed to protecting your personal information and ensuring that it is processed in a lawful, fair, and secure manner.

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1. Collection of Personal Information

We collect personal information from investors, as well as from their representatives and authorised signatories, in order to:

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• Provide our services effectively

• Comply with legal and regulatory requirements

• Maintain accurate records of your investment account

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Providing personal information is mandatory unless otherwise indicated. Failure to provide complete and accurate information may result in:

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• Inability to process your investment

• Suspension or closure of your account

• Inability to process transactions or additional contributions

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2. How We Use Your Information

Your personal information may be collected, used, stored, verified, and disclosed for the following purposes:

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• To administer, service, and maintain your investment account

• To communicate with you and your authorised representatives

• To provide reports, respond to queries, and share relevant information

• To fulfil our obligations to you as an investor

• To ensure you meet requirements for specific investment products

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3. Sharing of Personal Information

We may share your personal information with:

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• Entities within our group of companies for administration and servicing

• Third-party service providers who assist with:

  • Identity verification

  • Compliance and regulatory obligations

  • Operational support (e.g. research, surveys, customer experience improvements)

• Regulatory authorities, law enforcement, or government bodies where required by law

• Other parties where necessary to provide services or enforce agreements

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All third parties are required to have appropriate measures in place to protect your information.

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4. Cross-Border Transfers

Your personal information may be transferred outside of Namibia where:

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• The receiving party is subject to similar data protection laws, or

• Adequate safeguards are in place to protect your information

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5. Legal and Regulatory Compliance

We may process and disclose your personal information in order to:

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• Comply with applicable laws and regulations

• Meet obligations under financial intelligence and anti-money laundering legislation

• Support enforcement of agreements and policies

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6. Data for Research and Improvement

Your information may be used to:

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• Improve our products and services

• Conduct research and analysis

• Send surveys or request feedback

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Where appropriate, information will be de-identified so that it cannot be linked back to you.

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7. Your Responsibility

By engaging with our services, you acknowledge that:

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• Your personal information will be processed as outlined above

• You have provided accurate and complete information

• You will update us where your information changes

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