POPI Compliance

PROTECTION OF PERSONAL INFORMATION AND THE RETENTION OF DOCUMENTS

A: PROTECTION OF PERSONAL INFORMATION IN TERMS OF THE PROTECTION OF PERSONAL INFORMATION ACT 4 OF 2013

1. PROTECTION OF PERSONAL INFORMATION ACT, 4 OF 2013 — POPI POLICY 2020

1.1 INTRODUCTION

CARBON COVER INSURANCE CONSULTANTS functioning within the SHORT TERM insurance is obligated to comply with The Protection of Personal Information Act 4 of 2013. POPI requires CARBON COVER INSURANCE CONSULTANTS to inform their clients as to the manner in which their personal information is used, disclosed and destroyed.

CARBON COVER INSURANCE CONSULTANTS guarantees its commitment to protecting its client's privacy and ensuring that their personal information is used appropriately, transparently, securely and in accordance with applicable laws.

The Policy sets out the manner in which CARBON COVER INSURANCE CONSULTANTS deals with their client's personal information as well as and stipulates the purpose for which said information is used. The Policy is made available on CARBON COVER INSURANCE CONSULTANTS website www.carboncover.co.za and by request from CARBON COVER INSURANCE CONSULTANTS office.

The Policy is drafted in conjunction with the Financial Intermediary Association's ("FIA") Protection of Personal Information Notice.

1.2 PERSONAL INFORMATION COLLECTED

Section 9 of POPI states that "Personal Information may only be processed if, given the purpose for which it is processed, it is adequate, relevant and not excessive." CARBON COVER INSURANCE CONSULTANTS collects and processes client's personal information pertaining to the client's financial needs. The type of information will depend on the need for which it is collected and will be processed for that purpose only.

Examples of personal information we collect include, but is not limited to:

• The Client's Identity number, name, surname, address, postal code, marital status, and number of dependants
• Description of the client's residence, business, assets; financial information, banking details, etc.
• Any other information required by CARBON COVER INSURANCE CONSULTANTS, suppliers and Insurers in order to provide clients with an accurate analysis of their Insurance needs

1.3 THE USAGE OF PERSONAL INFORMATION

The client's Personal Information will only be used for the purpose for which it was collected and as agreed. This may include:

• Providing products or services to clients and to carry out the transactions requested
• For underwriting purposes
• Assessing and processing claims
• Conducting credit reference searches or verification
• Confirming, verifying and updating client details
• For purposes of claims history
• For the detection and prevention of fraud, crime, money laundering or other malpractices
• Conducting market or customer satisfaction research
• For audit and record keeping purposes
• In connection with legal proceedings

1.4 DISCLOSURE OF PERSONAL INFORMATION

CARBON COVER INSURANCE CONSULTANTS may disclose a client's personal information to any of CARBON COVER INSURANCE CONSULTANTS or subsidiaries, joint venture companies and or approved product or third party service providers whose services or products clients elect to use.

1.5 SAFEGUARDING CLIENT INFORMATION

It is a requirement of POPI to adequately protect personal information. CARBON COVER INSURANCE CONSULTANTS will continuously review its security controls and processes to ensure that personal information is secure.

1.6 ACCESS AND CORRECTION OF PERSONAL INFORMATION

Clients have the right to access the personal information CARBON COVER INSURANCE CONSULTANTS holds about them. Clients also have the right to ask CARBON COVER INSURANCE CONSULTANTS to update, correct or delete their personal information on reasonable grounds.

OFFICE DETAILS

Telephone Number: 083 603 7611
Postal Address: P.O. Box 11344, Wierda Park South, 0057
Physical Address: Unit 1B, Swallow Street, Centurion, 0057
E-mail Address: terry@carboncover.co.za
Website: www.carboncover.co.za

B: POLICY ON THE RETENTION & CONFIDENTIALITY OF DOCUMENTS, INFORMATION AND ELECTRONIC TRANSACTIONS

1. PURPOSE

To exercise effective control over the retention of documents and electronic transactions as prescribed by legislation and as dictated by business practice. Documents need to be retained in order to prove the existence of facts and to exercise rights the Company may have.

2. SCOPE & DEFINITIONS

All documents and electronic transactions generated within and/or received by the Company. Clients includes, but are not limited to, shareholders, debtors, creditors as well as the affected personnel and/or departments related to a service division of the Company.

4. ACCESS TO DOCUMENTS

All Company and client information must be dealt with in the strictest confidence and may only be disclosed, without fear of redress, in the following circumstances: where disclosure is under compulsion of law; where there is a duty to the public to disclose; where the interests of the Company require disclosure; and where disclosure is made with the express or implied consent of the client.

5. STORAGE OF DOCUMENTS

Documents are stored in archive in head office. The Companies Act, No 71 of 2008 requires that hardcopies of documents be retained for 7 years. The Financial Advisory and Intermediary Services Act, No 37 of 2002 requires a retention period of 5 years. Various other legislation prescribes retention periods for specific record types.

6. DESTRUCTION OF DOCUMENTS

Documents may be destroyed after the termination of the retention period specified in this policy. Each department is responsible for attending to the destruction of its documents, which must be done on a regular basis. Documents are shredded before disposal to ensure confidentiality of information.