Privacy Policy

1. Introduction

1.1) This Privacy Policy outlines how the personal information of a Client is collected, used, stored, and protected by Comit Capital.

2. DEFINITIONS

2.1 The following definitions

2.1.1) “Authority” means the Financial Sector Conduct Authority of South Africa;
2.1.2) “Client” means a person who has entered into an agreement with Comit Capital;
2.1.3) ‘‘Consent’’ means any voluntary, specific and informed expression of will in terms of which permission is given for the processing of personal information;
2.1.4) “Personal Data” means, any information that identifies a person, such as name, contact details, identity number, financial details, and regulatory information;
2.1.5) “Processing” means any operation performed on personal information, including collection, storage, updating, sharing, or deletion;
2.1.6) “Responsible Party” or “We” means Comit Capital, which determines the purpose and means of processing personal information;
2.1.7) “Data” means any information relating to an identifiable, living person or juristic entity, including names, contact details, financial information;
2.1.8) “Data Subject” means any individual or entity whose personal information is collected, processed, or stored by Comit Capital;
2.1.9) “POPI Act” means the Protection of Personal Information Act, No. 4 of 2013, as amended;
2.1.10) “Regulator” means the Information Regulator of South Africa; and,
2.1.11) “Third Party” means any external entity with whom personal information is shared, such as regulatory authorities, service providers, or business partners.

3. SCOPE AND APPLICATION

3.1) This Privacy Policy applies to all clients, prospective clients, business partners, service providers, employees, and any other persons whose personal information we process in connection with our services.

4. COLLECTION OF PERSONAL INFORMATION

4.1) We obtain most of the data we collect about you directly from you in connection with your use of our services. This includes, in particular:

4.1.1) Data that you provide to us yourself, especially when you register on the website, enter information into your user account, order services, participate in our events and projects, or when you
communicate with us through customer support or social networks. These are identification and contact data, specifically the name, surname, telephone number, e mail address, postal address, date of birth, user name and password, and business identification number or tax registration number, if you are an entrepreneur; payment data, such as bank details; and other data, such as records of communication between you and our company or details of any warranty claims.

4.1.2) Data that we automatically collect when you use our services. These are data about your device (such as the IP address, device type, operating system, browser used, connection provider); website usage data (such as the date, time and duration of visit, a country from which you visit the website, website browsing history), and data on the use of services (such as the login and logout information, your account settings, the value of your fictitious capital, your account currency, business strategy).

4.1.3) Some data about you is provided to us by third parties, such as providers of trading platforms that you choose for use of our services, and social network operators if you decide to link your social networking accounts to an account on the website.

4.1.4) Data about the simulated transactions you have completed (such as the type of financial instrument, time of opening and closing the position, amount of investment, profit and loss) and data from social networks (username, profile picture, e-mail address associated with the account on the social network). For information on how your personal data are processed by trading platform providers and social network operators for their own purposes, please refer to the privacy policies of those parties.

5. HOW DO WE USE YOUR PERSONAL DATA

5.1) We use personal data for the following purposes:

5.1.1) Registration and user account: in order to use the services, you must register on the website and create your account, and for this purpose we process your personal data;
5.1.2) Marketing communication about our services and products or about events in which we take part: if you are our current or past customer, we may from time to time send you marketing communications that relate to our services. We may also send you commercial communications to the extent to which you give us your consent. Each of the e-mails sent will be marked as a business communication and each of them will contain a link with the help of which you can easily unsubscribe from the business communications;
5.1.3) Client support and communication: if you use our customer support services, we will process your personal data;
5.1.4) Improving services: if you use some of our services, we will process your personal data in order to develop, test and enhance the services and improve their security; and,
5.1.5) Analytics: to obtain information about how our website and our services are used, we analyse customer behaviour.

6. DATA SHARING AND TRANSFERS TO THIRD COUNTRIES

We make your data available or transfer them to persons that help us provide our services, in particular the following persons:

6.1.1) The trading platform provider, in order to enable you to perform the simulated trades; and,
6.1.2) Other third parties that help us run our website and provide our services (such as other companies in our group, hosting and cloud service providers, payment system operators and financial institutions, providers of customer support tools and services, IT companies and system administrators, marketing and communication agencies, consultants and postal service providers).

6.2) In addition, we may transfer your data to persons in respect of which you give your consent thereto, as well as in the cases where it is our obligation under the law or under a judicial or any other legally binding decision. Each such entity to whom personal data are transferred is contractually obligated to protect your personal data in accordance with legal provisions and to process the data exclusively according to our instructions.
6.3) Certain third parties collect personal data for their own purposes as controllers. In such a case, their own rules for the processing of personal data shall apply.

6.4) We may share your personal information with:

6.4.1) Regulatory authorities such as the Authority, the South African Revenue Service, and the Financial Intelligence Centre;
6.4.2) Third-party service providers who assist us with compliance, IT, data storage, and operational support;
6.4.3) Financial institutions and payment service providers for transaction processing;
6.4.4) Law enforcement or other parties when required by law; and,
6.4.5) Business partners in connection with contractual obligations.

7. DATA STORAGE AND SECURITY MEASURES

7.1) Comit Capital takes appropriate security measures to protect your personal information from loss, misuse, unauthorised access, disclosure, or alteration. These measures include:

7.1.1) Secure data encryption and storage mechanisms;
7.1.2) Access controls and authentication measures;
7.1.3) Regular security assessments and compliance audits; and,
7.1.4) Secure third-party service provider agreements.

8. ENFORCEMENT OF SECURITY MEASURES

8.1) We enforce security measures by conducting regular security audits, employee training, and ensuring
compliance with industry standards. Any breach of our security policies by employees or third parties is subject to disciplinary action or termination of contracts where applicable.

9. DATA BREACHES

9.1) In the event of a data breach that compromises personal information, we will notify affected individuals and relevant authorities as required by POPI ACT. Notifications will include details of the breach, potential risks, and any remedial actions taken.

10. CONSENT

10.1) We will obtain your explicit consent before using your personal information for marketing or sharing it with third parties for purposes other than those stated in this policy. You may opt out of marketing communications at any time by contacting us.

11. CROSS-BORDER TRANSFER OF INFORMATION

11.1) Where personal information is transferred outside of South Africa, we ensure that such transfers comply with POPI ACT by implementing appropriate safeguards, such as contractual clauses or regulatory approvals.

12. YOUR RIGHTS UNDER POPI ACT

12.1) Under the POPI ACT, you have the following rights, the:

12.1.1) Right to Access – Request a copy of your personal information;
12.1.2) Right to Correction – Request correction of inaccurate or outdated information;
12.1.3) Right to Deletion – Request deletion of personal information under certain conditions;
12.1.4) Right to Object – Object to the processing of your information on reasonable grounds;
12.1.5) Right to Restriction – Request that we limit how we process your information; and,
12.1.6) Right to Withdraw Consent – Withdraw consent where processing is based on consent.

13. RETENTION OF PERSONAL INFORMATION

13.1) We retain personal information only for as long as necessary to fulfil the purposes outlined in this policy, comply with legal obligations, or resolve disputes. Once no longer required, data will be securely disposed of.

14. CHANGES TO THIS PRIVACY POLICY

14.1) We may update this Privacy Policy from time to time to reflect changes in legal requirements, operational practices, or security measures. The latest version will be available on our website.

14.2) All changes and updates to this Privacy Policy are reflected below:
14.2.1) Version: 1.
14.2.2) Date implemented: 1 / 11 / 2025.

15. CONTACT INFORMATION

15.1) For any questions, requests, or complaints regarding this Privacy Policy or the processing of your personal information, please contact our Information Officer:

15.1.1) Physical address: Sasol Building
50 Katherine Street
Sandton
Johannesburg
2196
15.1.2) For the attention of: care@comitcapital.com

15.2) By engaging with Comit Capital, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy.