DATA PROTECTION POLICY : Maven Solutions

1. Preamble

1.1. The purpose of this Data Protection Policy is to provide Maven Solutions Clients with information on how it processes, handles and stores their personal information, as a data Controller and as a data processor. Maven Solutions values its Client’s privacy and security and is committed to protecting it. Maven Solutions undertakes to comply with the legal standards governing its Clients, namely the General Data Protection Regulation of the (EU) 2016/679 (“the GDPR”) and the Protection of Personal Information Act 4 of 2013 (“POPIA”).

1.2. This Policy seeks to ensure that Maven Solutions (i) complies with international legal standards and best practice for the receipt, importing, processing, handling and storing of personal data of individuals, both as received from its Clients, and as held in respect of its employees;(ii) protects the rights of its employees, as well as that of its Clients and third parties in respect of individuals’ data; (iii) transparently communicates how it processes, handles and stores individuals’ data; and protects itself from the risks of a personal data breach.

1.3. In adopting this Policy, Maven Solutions wishes to balance its legitimate business interests and its Clients’ reasonable expectation of privacy. Accordingly, Maven Solutions will take appropriate and reasonable technical and organisational steps to prevent unauthorised access to, or disclosure of your Personal Information.

1.4.The rules and standards set out in this Policy apply regardless of whether personal data relates to a Client or an Employee of Maven Solutions, and/or is stored electronically, digitally, on paper, or other materials, or through other methods.

2. Interpretation and Definitions

In this Policy-

2.1 the headings are for convenience and shall be disregarded in construing this Policy

2.2 unless the context indicates a contrary intention, the singular shall include plural and vice versa;

2.3 a natural person includes a juristic person and vice versa;

2.4 where any term is defined within a particular clause other than this clause 2, the term so defined shall bear the meaning ascribed to it in that clause wherever it is used in this Policy, unless it is clear from the clause in question that such a defined term has limited application to the relevant clause;

2.5 any reference to any statute, regulation or other legislation shall be a reference to that statute, regulation or other legislation as amended or substituted from time to time; and

2.5.1 Unless the context clearly indicates a contrary intention, the following expressions shall bear the meanings set opposite them below and cognate expressions shall bear corresponding meanings:

2.5.2 “Client” means any natural or legal person to whom Maven Solutions provides a service or benefit and includes any Prospective Client;

2.5.3 “Consent” means a Client’s voluntary, specific and informed indication of its wishes by a statement or an affirmative action, which signifies its agreement to the processing of its Personal Information, as defined in Section 1 of the POPIA and Article 4 of the GDPR, whichever is applicable under the circumstances;

2.5.4 “Data Subject” means the person to whom the Personal Information relates, as defined in Section 1 of the POPIA and Article 4 of the GDPR, whichever is applicable under the circumstances;

2.5.5 “DPO” means a (i) Data Protection Officer as defined in Articles 37 to 39 of the GDPR; (ii) an Information Officer, as defined in section 1 of the POPIA, whichever is applicable under the circumstances;

2.5.6 “Maven Solutions” means Knoesen Consulting (Proprietary) Limited trading as Maven Solutions a private company registered in accordance with the laws of South Africa under registration number: 2016/478376/07;

“Personal Data/Information” means information which relates to an identified or identifiable natural person, and where applicable, an identifiable, existing juristic person, in particular by reference to an identifier factor such as a name, identification number, location data, online identifiers or other specific factors such as physical, physiological, genetic, mental, economic, cultural or social identity of a natural person, as defined in Section 1 of the POPIA and Article 4 of the GDPR, whichever is applicable under the circumstances;

2.5.8 “Policy” means this data protection policy and addendums thereto;

2.5.9 “Processing” means any operation or set of operations performed on Personal Information or sets of Personal Information, as defined in Article 4 of the GDPR and Section 1 of the POPIA, whichever is applicable under the circumstances;

2.5.10 “Prospective Client” means any natural or legal person to which Maven Solutions has provided or from which Maven received a proposal, bid or written inquiry regarding the possible performance of services by the company;

2.5.11 “Recipient” means a natural or legal person, public authority, agency or another body, to which the Personal Information is disclosed, whether a third party or not; and

2.5.12 “Regulatory Authority” means the Information Regulator established in terms of section 39 of POPIA.

3. Personal Information collected and processed

3.1 The types of Personal Information that we may collect and process includes information necessary for Maven Solutions legitimate business interests and the categories of Personal Information defined in POPIA and GDPR. This may include (amongst other things):

3.1.1 information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the Data Subject;

3.1.2 information relating to the education or the medical, financial, criminal or employment history of the Data Subject;

4. Processing the Personal Information