Privacy Policy

1. Introduction and responsible party

ConnectionHut Pty Ltd ("we", "us", "our") is the responsible party (as defined in the Protection of Personal Information Act 4 of 2013 ("POPIA")) for the personal information we process. We are committed to protecting your privacy and to processing personal information in accordance with POPIA, the regulations issued under POPIA (including the Regulations relating to the Protection of Personal Information as amended from time to time, such as the 2025 Amendment Regulations), and other applicable South African data protection law. The consolidated text of POPIA can be consulted at the Southern African Legal Information Institute (SAFLII): www.saflii.org. This Privacy Policy explains how we collect, use, store and disclose your personal information when you use our lead submission and related services.

2. Your obligation: permission and consent to share information

You may only submit information to ConnectionHut Pty Ltd if you have the right and all necessary permissions to do so. By submitting a lead, you represent and warrant that:

• You have obtained any consent, authority or permission required from the data subjects whose personal information you are providing (including the lead contact and any other individuals whose details you submit), so that you are lawfully entitled to pass that information to us and for us to process it in accordance with this policy.
• You have informed those data subjects (where required by law) that their information may be shared with ConnectionHut Pty Ltd and potentially with service providers or other parties for the purpose of fulfilling the lead.
• You will not submit any personal information in respect of which you do not have the right to disclose to us or for us to use as described in this policy.

If you do not have the necessary permission or consent to pass the information, you must not submit it. ConnectionHut Pty Ltd relies on your representations above. We are not responsible for any claim, loss or liability arising from your submission of information without proper consent or authority from the relevant data subjects.

3. Fulfilling the lead: service providers and third parties

To verify, progress and fulfil the lead, ConnectionHut Pty Ltd may engage one or more service providers, partners, contractors or other third parties (including to identify and engage a party capable of fulfilling the lead, providing the relevant product or service, or closing the deal). By submitting a lead and the associated personal information, you expressly consent to:

• Our use of the information you provide for the purpose of verifying the lead and fulfilling it, including by sharing such information with selected service providers or other parties where necessary for that purpose.
• Our disclosing the lead details and related personal information to such service providers or third parties to the extent reasonably required to fulfil the lead, communicate with the lead contact, or complete the transaction.

This processing is necessary for our legitimate business purpose and, where you have obtained the consent of the data subjects as set out in section 2 above, is carried out on that basis. We require service providers and third parties to handle personal information in accordance with applicable law and appropriate confidentiality and security obligations.

4. Information we collect

When you submit a lead, we collect (in line with purpose specification and processing limitation under POPIA):

• Your name, email address, phone number and (if provided) company name
• Lead/opportunity details: lead company name, contact name, email, phone, industry, description and any estimated value
• Your confirmation that you have consent to share the information you are providing
• Your electronic signatures on our declarations
• Technical data such as IP address and time of submission, where relevant for security or compliance

5. How we use your information

We use the information you provide only for the following purposes (and will not use it for incompatible further processing without a lawful basis):

• To verify the lead and your details
• To process and follow up on the opportunity, including by engaging service providers or other parties to fulfil the lead as set out in section 3
• To communicate with you and with the lead contact about the submission and any payout
• To comply with legal and regulatory requirements (including under POPIA)
• To improve our services and security in a way that is consistent with the original purpose of collection

6. Disclosure

We may disclose your and the lead's information to trusted service providers and third parties who assist us in operating our business and fulfilling leads (as described in section 3), including for hosting, verification, and engaging parties to fulfil the lead. We do not sell your personal information. We may also disclose information where required by law (including to regulators), or to protect our or others' rights, property or safety. We take reasonable steps to ensure that any recipient of personal information is bound by appropriate safeguards.

7. POPIA and lawful processing

We process personal information in accordance with POPIA and the regulations made under it (as updated from time to time). This includes compliance with the eight conditions for lawful processing in POPIA Chapter 3: accountability; processing limitation; purpose specification; further processing limitation; information quality; openness; security safeguards; and data subject participation. Where we process personal information across borders, we do so in accordance with POPIA Chapter 9 and ensure appropriate safeguards where required. We do not use the information you submit for direct marketing by means of unsolicited electronic communications; were we to do so, we would obtain your prior written or equivalent consent as required by POPIA and the amended regulations.

8. Storage and security

We store your data securely and retain it only for as long as necessary to fulfil the purposes in this policy and to meet legal obligations (including under POPIA). We implement appropriate technical and organisational measures to protect the integrity and confidentiality of personal information. In the event of a security compromise (unauthorised access to or acquisition of personal information), we will take steps to notify the Information Regulator and affected data subjects where required by POPIA section 22 and any applicable regulations (including any mandatory reporting procedures). No method of transmission or storage is completely secure; you provide information at your own risk subject to your obligations in section 2.

9. Your rights (data subject participation)

Under POPIA and the regulations made under it (including the 2025 Amendment Regulations), you have the right to: be notified when your personal information is collected; establish whether we hold your personal information and request access to it; request the correction, destruction or deletion of your personal information (where we are no longer authorised to retain it, such requests will be dealt with at no charge); and object to the processing of your personal information on reasonable grounds, or to processing for purposes of direct marketing, at no charge and through accessible channels (e.g. email or the contact details on our Contact Us page). We will respond to requests for access, correction, destruction or deletion and will notify you in writing of the outcome within 30 days where required by South African law. You may also lodge a complaint with the Information Regulator (South Africa); the Regulator will process complaints in accordance with applicable procedures (including acknowledgment of receipt within the period prescribed by regulation). To exercise any of these rights or ask questions about this policy, contact ConnectionHut Pty Ltd using the details in the Contact section below.

10. Limitation and indemnity

To the fullest extent permitted by law, ConnectionHut Pty Ltd shall not be liable for any claim, loss or damage arising from: (a) your submission of personal information without the consent or authority of the relevant data subjects; (b) our processing or disclosure of information in accordance with this policy and the consent you have given; or (c) the acts or omissions of any service provider or third party engaged to fulfil the lead. You indemnify ConnectionHut Pty Ltd against any claim by a data subject or third party arising from your failure to obtain the necessary permission or consent before submitting their information.

11. Contact and Information Officer

For privacy-related enquiries, to exercise your rights under POPIA, or to contact our Information Officer, please use the details on our Contact Us page. ConnectionHut Pty Ltd is the responsible party for the purposes of POPIA.