1. Definitions

1.1 ‘Personal Information’ means data from which a person can be identified, including name, contact details, ID number, tax reference, financial information, and banking details.

1.2 ‘Processing’ means collection, receipt, recording, storage, updating, retrieval, use, dissemination, and destruction of Personal Information.

2. What Personal Information We Collect

2.1 We may collect: identification information (name, ID number, entity registration); contact information (address, telephone, e-mail); tax information (tax registration number); financial information (banking details, proof of funds, investment history); Website interaction data (IP address, pages visited, cookies); and correspondence.

3. Why We Process Your Personal Information

3.1 We process your Personal Information to: establish and administer investor accounts; comply with FICA anti-money laundering legislation; communicate regarding investments and investor relations; comply with I-Ex and STRATE requirements; maintain statutory registers; manage and improve the Website; and comply with applicable law.

4. Legal Basis for Processing

4.1 We process your Personal Information where necessary to perform a contract with you, required by law, or for our legitimate interests in operating iGroup Fund.

4.2 Where we rely on consent, you may withdraw it by contacting the Information Officer. Withdrawal does not affect prior processing or processing required for legal compliance.

5. Who We Share Your Personal Information With

5.1 We do not sell your Personal Information. We share it only with: service providers (auditors, fund administrators, legal advisers) under data processing agreements; I-Ex and STRATE for listing and settlement; regulatory authorities (FIC, SARS) where required by law; and other parties with your written consent.

6. Retention

6.1 We retain your Personal Information for as long as necessary to fulfil its purpose or as required by law. Records are retained for a minimum of five years under FICA and as required under the Companies Act and tax legislation. On expiry, Personal Information is destroyed or de-identified.

7. Your Rights as a Data Subject

7.1 You have the right to: access and obtain a copy of your Personal Information; request correction or deletion of inaccurate information; object to processing; request restriction of processing; and lodge a complaint with the Information Regulator.

7.2 To exercise these rights, contact our Information Officer at [DETAILS] or the Information Regulator (inforeg@justice.gov.za / 012 406 4818).

8. Cross-Border Transfers

8.1 We may transfer Personal Information outside South Africa where the recipient has adequate protection (law, binding rules, or binding agreement) equivalent to POPIA.

9. PAIA Manual

9.1 iGroup Fund has compiled a manual under the Promotion of Access to Information Act 2 of 2000 (POPIA). The manual is available on request from the Information Officer.

10. Updates

10.1 iGroup Fund may update this Privacy Notice to reflect changes in law or processing practices. The current version will be published on the Website. Continued use constitutes acceptance.