UPDATED PRIVACY POLICY (AS AT 14 MARCH 2026)

1. Introduction

1.1. This Privacy Policy forms part of our standard Terms & Conditions of Service and applies to all registered or non-registered Users of our Services (as defined in our standard Terms & Conditions of Service) including visitors to our website (User, you or your). All references herein to us, our or we are to MComm Technologies (Pty) Ltd (Registration Number: 2013/102691/07).

1.2. Your privacy is important to us. The purpose of this Privacy Policy is to help you understand how we collect, use, store and share personal data about you. Personal data means any information about an individual from which that person can be identified and does not include anonymous data.

1.3. If you do not agree with this Policy, then you may not use this website or our Services and are required to cease doing so immediately.

1.4. PLEASE NOTE that where you use our Services to communicate messages to third parties such as your customers (message recipients), we are the data processor and you are the data controller. This means that you determine the purpose and means of the processing of information about message recipients. It is your responsibility to ensure that message recipients’ data that is uploaded to our platform, along with the content of the messages, is compliant with all applicable local and international data protection laws and regulations, including but not limited to the General Data Protection Regulation Directive (GDPR) and South Africa’s Protection of Personal Information Act (POPIA). Please refer to our Standard Terms of Service for further details.

2. The personal data we collect about you and where we get it from

2.1. We collect relevant and minimal personal data about you for the purpose of managing your affairs with us.

2.2. We collect information about you when you register for an account, create or modify your profile on our website, purchase Services from us, raise a query with our support team, contact us over the phone, by email or via live chat, sign up to any of our mailing lists, request marketing to be sent to you, take part in any surveys or give us some feedback.

2.3. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• 2.3.1. Contact details – your name, title, billing address, delivery address, email address and telephone numbers;
• 2.3.2. Payment information* – your bank account and branch number;
• 2.3.3. Purchase history – this includes details about the Services you have purchased from us;
• 2.3.4. Marketing preferences – this includes your preferences in receiving marketing from us and your communication preferences;
• 2.3.5. Browser information – this includes information from your browser, computer, or mobile device, which provide us with technical information when you access or use our website or Services, including device and network information, cookies and analytics information;
• 2.3.6. Customer service history – this includes interactions with us over the phone, via the website or live chat **.
• * Note that all credit card and electronic funds transfer payment processes are re-directed to and managed directly by a third party payment service provider. We do not hold your credit card details.
• ** While on live chat, our support team can see your public internet protocol (IP) address and location.

3. How we process your personal data

3.1. We will only process your personal data in a manner that is adequate, relevant and not excessive in the context of the purpose for which it is processed. That purpose will be compatible with that for which it was collected, unless you have consented to an alternative purpose in writing or we are permitted by POPI or in terms of national legislation of general application.

3.2. Most commonly, we will use your personal data in the following circumstances:

• 3.2.1. to provide you with access to this website;
• 3.2.2 to present certain material set out on the website to you;
• 3.2.3. where we need to perform the contract we are about to enter into or have entered into with you, including to process transactions with you, authenticate you when you log in, provide customer support, to operate and maintain the Services and to protect the safety and security of the Services;
• 3.2.4. to protect our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• 3.2.5. where we need to comply with a legal or regulatory obligation; and
• 3.2.6. where you have given us your consent to do so for a specific purpose.

Please refer to Appendix 1 to this Privacy Policy for more detail about what we do with your personal data and why.

4. Cookies

4.1. We may utilise temporary or session cookies. We utilize first and third-party cookies to improve users’ experience, store preferences, and track aggregate usage behavior.

4.2. You can opt out of a third party website’s use of cookies by visiting the Network Advertising Initiative opt-out page.

5. Keeping your personal data secure

5.1. In addition to our local environment, we use data centre service providers in the United Kingdom to host the information we collect.

5.2. We have put in place appropriate reasonable technical, organisational and security measures to secure your personal data. In addition, we limit access to your personal data to those employees, agents, service providers and other third parties who have a business need to know.

6. How we share the personal data we hold about you

6.1. We do not sell any of your personal data to any third party. We will not disclose any personal data relating to you to any third party unless your prior written agreement is obtained, or we are required to do so by law.

6.2. We share and/or store your information with our third party hosting, backup, storage and/or virtual infrastructure service provider(s) who help us run our business. Some of these third parties may be situated outside of your country and you consent to your personal data being transferred cross-border so that we can provide the Services to you.

7. How long do we keep your personal data?

7.1. Generally, we will only retain your personal data for as long as necessary to fulfil the purpose for which we collected it. We will destroy or delete any personal data that is no longer needed by it for the purpose it was initially collected, or subsequently processed.

8. Accessing and controlling your personal data

8.1. You have the right to request access, request correction, request erasure, object to processing, request restriction of processing, request the transfer (portability), and withdraw consent at any time. To exercise these rights, please contact our Information Officer as detailed in Section 13.

9. Transfer of Personal Data

9.1. Our website is operated from the Republic of South Africa (“RSA”). If you are not located here, and choose to use the website, or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in the RSA.

10. Children

10.1. Our website is not intended for children under the age of 18 and we don’t knowingly process any personal data relating to a person under the age of 18 years unless we have obtained consent from that person’s parent or legal guardian.

11. Consent

11.1. You hereby consent to the processing of your personal data in terms of the provisions of this Privacy Policy.

12. Changes to this Privacy Policy

12.1. We may change this Privacy Policy from time to time. Continued use of the website or our Services subsequent to any amendments having been made constitutes your acceptance of the Privacy Policy as amended.

13. Contact Us & Information Officer Details

Questions and comments regarding this Privacy Policy are always welcomed. If you have questions or concerns about how your information is handled, would like to exercise any of your legal rights, or wish to lodge a complaint, please contact our Information Officer:

Name	Mel Mlindi Mtintsilana
Position	Managing Director
Email	admin@mcommtech.co.za
Telephone	010 140 1490
Regulator Registration Number	2026-003718
Physical Address	1 Leo Road, Sunward Park, Boksburg 1459

Company Details

• MComm Technologies (Pty) Ltd
• Registration Number: 2013/102691/07
• VAT Number: 421 026 7532
• Website: www.mcommtech.co.za

Lodging a Complaint

If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you have the right to lodge a complaint with the Information Regulator of South Africa:

• Website: www.inforegulator.org.za
• Email: inforeg@justice.gov.za
• Telephone: 010 023 5207
• Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

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APPENDIX 1 – HOW WE USE YOUR PERSONAL DATA

How?	What?	Why?
To register you as a new customer and manage your account	Name and contact details Profile information	To perform our contract with you. We can’t set up an account for you if we don’t know who you are or what your username and password is.
To enable you to log into our website simply and to allow you to interact with our customer service team	Name and contact details	We have a legitimate interest - to make it easier for you to use our website and to get in touch with us if you have need help with a query.
To sell you Services	Name and contact detail Purchase history	To perform our contract with you. We can’t sell you services if we don’t know who you are.
To take payments and give refunds	Payment information *	To perform our contract with you.
To send you service messages	Name and contact details	To perform our contract with you.
To provide customer service and support	Purchase history Customer service history	To perform our contract with you.
To provide training to our staff	Customer service history	We have a legitimate interest – so that we can make sure you get great customer service.
To send you information about our new services	Name and contact details Marketing preferences	We have a legitimate interest – to develop our services and grow our business. Not an existing customer? we first need your permission.
To ask you to leave a review or take a survey	Name and contact details Profile information Marketing preferences Survey responses	We have a legitimate interest - to study how customers use our services to ensure we’re giving you what you want.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Name and contact details Payment information	We have a legitimate interest - for running our business, network security, to prevent and protect fraud and in the context of a business reorganisation or group restructuring exercise. We’ve also got a legal obligation.
To use data analytics to improve our website, services, marketing, customer relationships and experiences	Name and contact details Purchase history Profile information	We have a legitimate interest - to better understand our customers’ needs and to optimise our service and experience.