DATA PRIVACY POLICY

We at the Ignition Group take your privacy seriously and are committed to protecting your

Personal Information. We place a high premium on the privacy of every person or organisation

with whom we interact and therefore acknowledge the need for Personal Information to be

handled with a reasonable standard of care.

This Data Protection and Privacy Policy (‘’Policy’’) relates to our Processing of your Personal

Information when you interact with us, access our Platforms and/ or use our Offerings. It explains

how we undertake to Process Personal Information in a manner which promotes the constitutional

right to privacy, while retaining accountability and managing Data Subject participation.

With our headquarters in Durban, South Africa, we are a global customer acquisition business,

operating in the telecommunications, home services and ﬁnancial services sectors.

We are committed to complying with the Applicable Laws in the multiple jurisdictions in which we,

and you, operate. We have therefore drafted this Policy in accordance with the provisions of

POPIA, which governs Data protection in South Africa, and in consideration of the following

international Applicable Laws:

1. General Data Protection Regulation (European Union) 2016/679, which governs Data

protection in respect of the European Union;

2. Federal Data Protection Act, updated as of 1 September 2023, which governs Data protection

in respect of Switzerland;

3. Data Protection Act 2018 which governs Data protection in respect of the United Kingdom;

and

4. California Consumer Privacy Act of 2018, as amended and expanded by the California Privacy

Rights Act of 2020, which may be employed for Data protection within the United States of

America.

5. Consumer Data Protection Act, effective 1 January 2023, which governs data protection and

privacy in respect of Virginia within the United States of America.

(collectively referred to as “International Data Protection Laws”).

By engaging with us, electronically or physically, you Consent to the Processing and transfer of

your Personal Information as set out in this Policy.

If you have any questions or concerns about our Processing of your Personal Information, please

1.1.

1.2.

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1.4.

DEFINITIONS

“Afﬁliate/s” means any entity which is associated with the Ignition Group through

common ownership, as per Annexure A2 below;

"Anonymisation" means the process of turning Personal Information into anonymous

information so that a Data Subject is not (or is no longer) identiﬁable;

“Annexure/s” means any annexure attached to this Policy, as amended from time to time;

“Applicable Law/s" means any laws applicable to the protection and Processing of

Personal Information, with particular emphasis on POPIA and the International Data