PRIVACY POLICY AND NOTICE

This is the privacy policy and notice of Tulisa Cables (Pty) Limited, (“Tulisa”), a South African company with Registration number 2004/032467/07 and with its principal place of business situated at 18 Tennyson Drive, Tulisa Park, Johannesburg, 2197.

In this policy, the words “we” or “us” refers to Tulisa and the words “you” or “your” refers to you as the Data Subject.

This Privacy Policy and Notice is in compliance with the provisions of the Protection of Personal Information Act 4 of 2013 (“POPIA”).

DEFINITIONS

1. In this Policy and for ease of reference, terms used shall bear the same meanings as provided in the clause below, unless a definition to the contrary appears herein.

1.1 “Confidential Information” means:-

1.1.1. any information or data relating to the Company (even if not marked as being confidential, restricted, secret, proprietary or any similar designation), in whatever format and whether recorded or not (and if recorded, whether recorded in writing, on any electronic medium or otherwise), which by its nature or content is identifiable as, or could reasonably be expected to be, confidential and/or proprietary to the Company;

1.1.2. information relating to the Company’s existing and future strategic objectives and existing and future business plans and corporate opportunities, trade secrets, technical information, techniques, know-how, operating methods and procedures;

1.1.3. details of costs, sources of materials and customer lists (whether actual or potential) and other information relating to the pricing, price lists and purchasing policies of existing and prospective customers and suppliers of the Company;

1.1.4. computer data, programs and source codes, whether relating to the client or a third party; and

1.1.5. intellectual property of the Company and/or in respect of which it has rights of use or possession.

1.2. “Consent” means any voluntary, specific and informed expression agreeing to the processing of personal information, which shall by your usage of our websites, be deemed to have been expressly given;

1.3. “Data” means any information relating to the Data Subject which was obtained as a result of a legal agreement between the Responsible Party and the Data Subject. The information may be held in hardcopy form (e.g. as written notes relating to a person or as part of a filing system, including card index or filing cabinets structured by name, address, or other identifier) or in a form capable of being processed electronically

1.4. “Data Subject” means the person to whom the personal information relates, including a third party or any natural person or legal company whose personal and/or business details were made known to the Responsible Party;

1.5. “Information” means any confidential information or personal information;

1.6. “Personal Information” means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to–

1.6.1. information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, wellbeing, disability, religion, conscience, belief, culture, language and birth of the person;

1.6.2. information relating to the education or the medical, financial, criminal or employment history of the person;

1.6.3. any identifying number, symbol, email address, physical address, telephone number, location information, online identifier or other particular assignment to the person;

1.6.4. the biometric information of the person;

1.6.5. the personal opinions, views or preferences of the person;

1.6.6. correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;

1.6.7. the views or opinions of another individual about the person; and

1.6.8. the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.

1.7. “Processing” means any operation or activity, or any set of operations whether or not by automatic means, including–

1.7.1. The collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;

1.7.2. Dissemination by means of transmission, distribution, or made available in any other form; or

1.7.3. Merging, linking, as well as restriction, degradation, erasure or destruction of information.

1.8. “Record” means any recorded information–

1.8.1. regardless of form or medium, including any–

1.8.1.1. writing on any material;

1.8.1.2. information produced, recorded or stored by means of any tape recorder, computer equipment, whether hardware or software or both, or other device, and any material subsequently derived from information so produced, recorded or stored;

1.8.1.3. label, marking or other writing that identifies or describes anything of which it forms part, or to which it is attached by any means;

1.8.1.4. book, map, plan, graph or drawing;

1.8.1.5. photograph, film, negative, tape or other device in which one or more visual images are embodied so as to be capable, with or without the aid of some other equipment, of being reproduced;

1.8.1.6. in the possession or under the control of a responsible party;

1.8.1.7. whether or not it was created by a responsible party; and

1.8.1.8. regardless of when it came into existence.

1.9. “Responsible Party” means a public or private body or any person which or who, alone or in conjunction with others, determines the purpose of and means of processing information;

1.10. “this Policy or the Policy” means this Privacy Policy and Notice.

DATA SUBJECTS

2. This Policy applies to any person/s who visits our website or downloads or extracts information or uses our application or a person who has requested products from us.

3. This Policy is informative as to your rights as a Data Subject and in regards to the Personal Information and Confidential Information that we collect as a result of your use of our website and/or our services.

4. We are committed to Processing and Recording your Personal Information in a manner required by a Responsible Party in terms of POPIA. If you think this Policy is not compliant with the provisions of POPIA and is in violation of your rights to confidentiality, please contact our Information Officer, Carlyn Rosenberg at carlynr@tulisacables.co.za

5. Save as set out in this Policy, we do not share, sell, or disclose to a third party, any personally identifiable information collected by us.

6. By accepting this Policy, you confirm that you have read, understood, accepted, and agreed to be bound by all of its terms and you consent to providing us with your Personal Information voluntarily.

RIGHTS OF DATA SUBJECTS

7. As a Data Subject, you have the right in terms of POPIA to have your Personal Information Processed in accordance with lawful processing and including:-

7.1. The right to be notified that Personal Information about you is being collected as provided for in terms of Section 18 of POPIA; and

7.2. The right to be notified if your Personal Information has been accessed by an unauthorised person, in terms of Section 22 of POPIA.

8. You are also entitled to object, on reasonable grounds relating to the Data Subject’s particular circumstances, to the Processing of your Personal Information as provided for in terms of Section 11(3)(a) of POPIA. This does not preclude you from objecting to direct marketing or objecting to the processing of your Personal Information in terms of Section 69(3)(c) of POPIA.

PERSONAL INFORMATION

9. Personal information includes:

9.1. Certain information that we collect automatically when you visit our website or use our application, includes but is not limited to your;

9.2. Name and surname;

9.3. E-mail address;

9.4. Contact details;

9.5. Company name;

9.6. Registration number;

9.7. VAT number; and

9.8. Postal and street address.

10. Where you order products from Tulisa, we collect your Personal Information from you including but not limited to your name, telephone number and physical address. This information is used to fulfil your order and this information is made available to our employees and agents to complete your order as is required in order for us to conduct our services.

11. Should you contact Tulisa requesting information on services or in order to purchase products, your Personal Information is stored on a secured server by us.

12. Your Personal Information is not used for marketing or advertising and will not be distributed to third parties without your prior consent.

13. Where you register to receive notifications and/or advertisements from us, we will collect your Personal Information, including your name, contact details and your e-mail address in order to fulfil this request. We will use this information to provide you with the information you enquired and requestedand provide any related information which we believe may be relevant to you.

14. This Personal Information is provided to our employees and third parties that may be involved in distributing the notifications and advertisements.

15. We will not disclose your Personal Information to any third party without your express consent and we will not sell or distribute your Personal Information obtained through your use of our website or services. Where we are required to use a third party to Process your Personal Information, you will be notified and given the option to opt-out.

16. We undertake to preserve the confidentiality of all of your Personal Information and of the terms of our relationship. The information collected by us is not used for any other purpose other than what is stated in this Policy in regards to the Personal Information we obtain from your usage of our website or from any enquiries on products or purchases made through our website.

17. We shall not under any circumstances, divulge your details to any person who is not an employee or agent or contractor of ours.

18. We will not be held liable for Personal Information processed whereby the disclosing party did not have the authority to disclose such Personal Information to us and it is the disclosing party’s responsibility to obtain consent from the Data Subject.

TERMS OF USE

19. We may use your Personal Information to fulfil our obligations to you. Such obligations include providing you with products (through sale), advising you of specials and current advertisements in respect of our products and delivering our products to you. We may send administrative messages and email updates to you about the website or our applications from time to time.

COOKIES

20. Cookies are small text files that are stored on the your device (computer, smartphone or tablet) when the user accesses our website. These Cookies are widely used to enhance your experience when making use of our website and in order to create a user specific experience. The Cookies that we collect typically relate to the user’s standard internet log information and behavioural data.

21. We may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages that you visit whilst you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser) or may remain on your computer until you delete them or until a defined period of time has passed.

22. We recommend that you allow the use of cookies to take advantage of the features of our website that rely on their use. If you prevent their use, you will not be able to use all the functionalities of our website. The manner in which we use Cookies is as follows:-

22.1. to allow essential parts of our website to operate for you;

22.2. to collect information about how visitors use our website; and

22.3. to store your personal information so that you do not have to provide it afresh when you visit the website next time.

COMPLAINTS

23. Any complaints in regard to the Processing and Record of your Personal Information must be directed to our appointed Information Officer and Deputy Information Officers being Carlyn Rosenberg as Information Officer and Samantha Dorman and Barend Jakobus Venter as Deputy Information Officers.

24. When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact another person, we may decide to give to that person some of the information contained in your complaint.

25. We may process your Personal Information to develop internal statistics and for analytical research purposes and your Personal Information and Confidential Information will not be disclosed to external parties in this manner.

SECURITY

26. We are bound to lawfully Process and Record your Personal information and Confidential Information as required by POPIA. All of your Personal Information will be safely and securely stored on site and under protected servers with encrypted password protection.

27. Our website further has a Secure Socket Layer (“SSL”) certificate in order to establish an encrypted link between our website and a website user.

DISCLOSURE TO GOVERNMENT AND THEIR AGENCIES

28. We may disclose personal information if require:-

28.1. by a subpoena or court order:-

28.1.1. to comply with any law;

28.1.2. to protect the safety of any individual or the general public; and

28.1.3. to prevent violation of our customer relationship terms.

NO SELLING

29. We will not sell your Personal Information. No personal information will be disclosed to anyone except as provided for in this Policy.

COMPLIANCE WITH THE LAW

30. This Policy has been incorporated in order to protect your rights as a Data Subject and our Processing of Personal Information will at all times be in compliance with the relevant laws of the Republic of South Africa and more specifically, within the requirements of POPIA.

REVIEW OR UPDATE PERSONALLY IDENTIFIABLE INFORMATION

31. At any time you may review or update the personally identifiable information that we hold about you by contacting us. To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your Personal Information.

HOW LONG DO WE KEEP YOUR INFORMATION

32. We only keep your information for as long as is necessary for the purpose for which we collected the data unless:

32.1. retention is required or authorised by law; and

32.2. you have consented to the retention of the information.

33. Personal information when destroyed, will be in accordance with applicable legislation including POPIA.

CHANGES

34. We may change the terms and conditions of this Policy at any time by updating our website or our applications and in order to at all times be compliant with legislation. If you continue using the website or the applications following our change of terms, the changed terms will apply to you and you will be deemed to have accepted the changed terms upon your continued usage. We will notify you of any changes by placing a notice on the website and on our applications.

35. If you have any question regarding the privacy policy, please contact us through our Information Officer, Carlyn Rosenberg at carlynr@tulisacables.co.za.