Privacy Policy

1. About this Privacy Statement

Developify (Pty) Ltd., trading as Developify ("Developify", "we", "us" or "our"), is committed to protecting your personal information. This Privacy Statement explains how we collect, use, store and share personal information when you use the Developify website, platform or services. We process personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") and other applicable South African laws.

2. Information We Collect

Depending on how you use Developify, we may collect:

• identification and contact information;
• identity and verification documents;
• bank and payment information;
• investment and transaction information;
• source of funds or source of wealth information where required;
• beneficial ownership and regulatory information;
• information required for sanctions, PEP/PIP, fraud and financial crime screening;
• communications with us; and
• technical information such as your IP address, device information and Platform activity.

3. How We Collect Information

We collect information directly from you when you register, invest, transact or communicate with us. We may also obtain information from lawful third-party sources such as banks, payment providers, identity-verification services, regulatory databases, public records and compliance or screening providers.

4. Why We Use Your Information

We may process personal information to:

• create and administer your account;
• verify your identity;
• complete regulatory and customer due diligence;
• facilitate investments, payments, distributions and transfers;
• maintain investor and transaction records;
• prevent fraud and financial crime;
• provide customer support;
• communicate with you;
• operate and secure the Platform;
• comply with legal and regulatory obligations; and
• establish, exercise or defend legal rights.

We process information only where we have a lawful basis to do so, including contractual necessity, legal obligations, legitimate interests or your consent where required.

5. FICA, Compliance and Screening

Developify and/or a relevant regulated entity may be required to obtain and verify information for FICA, FAIS and other regulatory purposes. This may include sanctions, PEP/PIP, beneficial ownership, fraud and financial crime screening. Where required information is not provided or cannot be satisfactorily verified, we may be unable to open or maintain an account, accept an investment, process a transaction or provide a service.

6. Sharing Your Information

We do not sell your personal information.

Where reasonably necessary or legally required, information may be shared with:

• relevant investment SPVs;
• authorised financial services providers;
• banks and payment providers;
• identity verification and compliance providers;
• accountants, auditors and legal advisers;
• property managers and other service providers;
• technology and cloud providers; and
• regulators, courts or law-enforcement authorities.

Third parties processing information on our behalf must process it appropriately and in accordance with applicable law.

7. Cross-Border Processing

Some service providers or technology infrastructure may be located outside South Africa. Where personal information is transferred internationally, we will take appropriate steps to ensure that the transfer complies with POPIA.

8. Security and Retention

We implement reasonable technical and organisational safeguards designed to protect personal information against loss, misuse, unauthorised access or disclosure. Personal information is retained only for as long as reasonably necessary or as required by law, including applicable FICA, FAIS, Companies Act, tax, contractual and regulatory record-keeping requirements. Where a personal information breach occurs, we will manage and report it in accordance with applicable legal requirements.

9. Your Rights

Subject to applicable law, you may request:

• access to personal information we hold about you;
• correction of inaccurate information;
• deletion or destruction where legally permitted;
• objection to certain processing; or
• withdrawal of consent where processing relies on consent.

You may also object to direct marketing and lodge a complaint with the Information Regulator (South Africa). Certain information cannot be deleted where Developify is legally required to retain it.

10. Cookies and Marketing

Developify may use cookies and similar technologies for Platform functionality, security, analytics and user experience. We may send marketing communications where permitted by law. You may opt out of electronic direct marketing at any time. Operational, investment, security and regulatory communications may still be sent where necessary.

11. Changes to this Statement

We may update this Privacy Statement where our services, technology, legal obligations or business operations change. The latest version will be available through the Developify Platform.

12. Contact Us

For questions about your personal information or to exercise your rights, contact:

Information Officer

Developify (Pty) Ltd. t/a Developify

Email: help@developify.co.za

Address: Soshanguve, 0152, South Africa

You may also lodge a complaint with the Information Regulator (South Africa).