PRIVACY STATEMENT

1. Security and safeguards

2. Submission and collection of personal information

3. Withdrawal of consent and requests for information records

4. Third-party access to personal information

5. Applicable laws and jurisdictions

C. USER AGREEMENT

1. Acceptance and consent

2. Changes to this user agreement

D. REGULATORY DISCLOSURE

DIGITAL PLATFORMS

Terms of use and privacy statement

PRIVACY STATEMENT

1. Security and safeguards

1.1. Redefine is committed to securing the integrity and confidentiality of users’ personal information in its possession or under its control by

a. taking appropriate, reasonable technical and organisational measures to prevent loss of, damage to, or unauthorised destruction of personal information, and unlawful access to, or processing of personal information; and

b. ensuring that any operator or anyone processing personal information on behalf of Redefine will process such information only with the knowledge or authorisation of Redefine and treat personal information that comes to their knowledge as confidential and not disclose it, unless required by law or in the course of the proper performance of their duties.

2. Submission and collection of personal information

2.1. The user acknowledges and agrees that

a. by using this site, personal information may have to be submitted and that all the personal information possessed by Redefine is collected through the user’s access to this site;

b. Redefine may collect information and data through the use of cookies (“cookies” are small text files a website can use to recognise repeat users, facilitate the users’ on-going access to and use of the website, and allow a website to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising); and

c. disabling cookies or similar features may adversely affect the user’s use of and access to the site and that the user will not hold Redefine liable for any loss arising therefrom;

d. Redefine has implemented certain Google Analytics features for the primary purpose of attempting to ascertain the success of our online marketing endeavours via the Google AdWords platform;

e. Redefine shall under no circumstances be utilising any personally identifiable information as obtained through the use of cookies or Google AdWords for remarketing campaigns in any other related marketing endeavours than the purpose stated in this agreement – online or otherwise;

f. Redefine will not sell, rent or provide personal information to unauthorised third parties for their independent use, without written consent from the user;

g. Redefine may transfer the user’s personal information outside the borders of South Africa in the following instances:

a) User email addresses that are hosted outside South Africa;

b) To administer certain services, for example, cloud services;

c) The user grants Redefine the right to use or process any information, data, materials, or other content the user provides via the site in accordance with applicable laws; and

d) Information submitted by the user via the site will affect the quality of personal information obtained, as well as the security in and integrity of personal information retained and managed by Redefine in accordance with the Redefine data governance standards.

2.2. Redefine may collect the following personal information from the user:

a. Correspondence through the site (which may include the user’s name, surname, address, email address and contact information);

b. Website connection information, statistics on page views, traffic to and from the website, IP address and standard web log information;

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c. Preferences based on browsing and general website usage; and

d. Preferences based on voluntary provision of information by the user.

2.3. It remains possible for the user to make use of the site without submitting any information. Submission of this information is dependent on the use of the site by the user and is entirely voluntary.

2.4. Redefine collects, retains and processes such personal information for the following purposes:

a. To allow use of the site as an administrative and operational imperative;

b. To monitor and identify potential fraudulent activity;

c. To process the user’s instructions and requests;

d. To provide personalised content and information and enhance user experiences;

e. To analyse site usage and to improve the site;

f. For online marketing strategies;

g. For market research, project planning, troubleshooting problems, detecting and protecting against errors, fraud or other criminal activity; and

h. For general historical, statistical and research activity.

2.5. Redefine shall retain records of personal information only for as long as necessary to achieve the purpose for which it was collected or processed, unless

a. retention of the record is required or authorised by law;

b. Redefine reasonably requires the information for lawful purposes related to its functions or activities;

c. retention of the record is required by a contract between the user and Redefine; or

d. the user consented to the retention of the record.

3. Withdrawal of consents and requests for information records

3.1. The user is entitled to withdraw any consent to process his/her personal information.

3.2. If the user withdraws consent to process personal information, the user should cease use of the site forthwith. Any further use will result in a renewed consent due to the binding nature of these terms and conditions.

3.3. The user is entitled to request:

a. on proof of identity, confirmation as to whether Redefine possesses any personal information pertaining to the user;

b. on proof of identity, a record or a description of the personal information about the user, including information about the identity of all third parties who currently have or have had access to the personal information; and

c. generally, any record Redefine may hold and is required to disclose to the user in terms of the Promotion of Access to Information Act 2 of 2000. See Redefine PAIA manual https://www.redefine.co.za/paia

3.4. The user may request Redefine to

a. correct or delete information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully; and

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b. destroy or delete a record of personal information about the user that Redefine is no longer authorised to retain in terms of applicable laws.

4. Third-party access to personal information

4.1. Redefine is not responsible for any representations or information or warranties or content on any third-party site (including third-party websites linked to this website, sites facilitated by us or websites that serve as social networks, like Facebook or Twitter), Redefine does not exercise control over the privacy policies of these third parties, and users should refer to the privacy policy of these third parties.

4.2. Redefine may enter into arrangements with its partners and other third-party suppliers in order for them to provide services. Those arrangements may require the disclosure of personal information, whether in person or by electronic transmission.

4.3. Request for information by third parties will only be granted under the following circumstances:

a. The user has provided consent in writing for the disclosure of this information to that third party; or

b. Redefine has a legal or contractual duty to transmit and disclose information to that third party.

4.4. No personal information will be made available to a third party unless that third party has agreed to abide by the strict confidentiality protocols that we require.

4.5. In the event of a proposed or actual merger, acquisition, or any form of sale of any assets, Redefine reserves the right to share personal information with the third parties in connection with the transaction. In the case of a merger, acquisition or sale, the new entity will have access to all personal information records held by Redefine. The terms of the privacy statement will continue to apply.

5. Applicable laws and jurisdictions

5.1. This privacy statement is governed by the laws of the Republic of South Africa, and the user consents to the jurisdiction of the South African courts in respect of any dispute which may arise out of or in connection with the formation, interpretation, substance or application of this privacy statement.

C. USER AGREEMENT

1. Acceptance and consent

1.1. By using the site, the user expressly agrees to the terms and conditions of this user agreement. If the user does not agree to all of the terms and conditions, the user should not continue to use the site.

1.2. When the user installs or downloads Redefine apps, the user may be required to accept the terms and conditions or the end user licence agreement (collectively, an “EULA") of a third-party supplier or vendor. While the EULA is independent from these terms and conditions and establishes a separate legal relationship which the user is bound by, the user agrees that the EULA is part of this agreement and will apply to the use of the Redefine apps.

1.3. The user agrees that this user agreement applies to any information accessed via the site, and to all sections of the site.

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1.4. The user agrees that Redefine may collect, process and store the user’s personal information for all purposes that relate to the site and the products, services, facilities, tools or utilities offered on the site.

1.5. The terms and conditions, together with the privacy statement, contain the entire agreement and understanding between the user and Redefine relating to all Redefine digital platforms and its content and use, and supersede any and all prior agreements, arrangements, statements and understandings, except for any fraud or fraudulent representation by either party.

2. Changes to this user agreement

2.1. Redefine reserves the right to change the terms and conditions of this user agreement and privacy statement at any time. Therefore, it is recommended that the user familiarises himself/herself with this user agreement regularly.

2.2. The most updated version of this user agreement will apply each time the user accesses and uses the site.

D. REGULATORY DISCLOSURE

Access to the site is classified as a form of “electronic transaction” in terms of the Electronic Communications and Transactions Act 25 of 2002 (ECT Act) and, as such, the user is entitled to the below-mentioned disclosures in terms of Chapter 7 of the ECT Act:

Site owner: Redefine Properties Limited (registration number 1999/018591/06)

Contact details: investorenquiries@redefine.co.za

Website address: http://www.redefine.co.za

Postal address: Postnet Suite 264, Private Bag X31, Saxonwold, 2132

Street address: 155 West, 4th floor, 155 West Street, Sandown, Sandton, 2196

Telephone number: +27 11 283 0000

Governing terms of use: These terms, including the Redefine privacy policy

Manual in terms of the Promotion of Access to Information Act 2 of 2000: https://www.redefine.co.za/paia

Management: The executive committee of Redefine Properties (Pty) Limited as determined from time to time

Costs associated with the access to and use of the service: No cost associated with accessing the service

Complaints and queries

• Any queries and complaints in relation to the operation and content of the site must be submitted to the following email address: investorenquiries@redefine.co.za

• All requests for reports and records must be submitted to Redefine’s head office at the following email address: investorenquiries@redefine.co.za