LEGAL 01 Privacy and Information Protection
Privacy and POPIA Policy

Personal information handled with purpose and accountability.

This policy explains how 51% Capital may collect, use, store, share and protect personal information when you use this website or communicate with us.

Effective date 24 August 2026
Jurisdiction South Africa
Policy reference 51C-PRIV-01
Important

This website policy is intended to provide a clear summary of our personal-information practices. It does not replace any additional privacy notice or contractual provision applicable to a particular engagement.

01

Introduction

51% Capital respects the privacy of website visitors, prospective clients, partners, suppliers and other people who communicate with us.

We aim to process personal information lawfully, reasonably and in a manner that does not unjustifiably infringe your privacy, in accordance with applicable South African data-protection law.

By using this website or submitting information through our enquiry form, you acknowledge the practices described in this policy. Where consent is required by law, we will request it separately.

02

Responsible Party

For personal information processed through this website, 51% Capital acts as the responsible party by determining the purpose and means of processing.

Requests relating to personal information can be submitted through our Contact page:

Submit a Privacy Enquiry
Before public launch

Add the verified registered entity name, registration number, physical address and Information Officer details when these are formally confirmed.

03

Personal Information We May Collect

Depending on how you interact with us, we may collect:

  • Your name and surname
  • Business or organisation name
  • Email address and telephone number
  • Job title or professional role
  • Sector and enquiry category
  • Information included in correspondence or forms
  • Meeting, proposal and engagement information
  • Website usage and technical information
  • IP address, device, browser and approximate location
  • Records required for legal or regulatory purposes

Please do not submit unnecessary confidential, financial, medical or other sensitive information through the general website enquiry form.

04

How We Collect Information

Information may be collected:

  • Directly from you through website forms
  • When you contact us by email, telephone or in person
  • During meetings, proposals and business engagements
  • From organisations you represent
  • From publicly available and lawful business sources
  • Automatically through website and server technologies
  • From service providers acting on our instructions
05

Why We Process Personal Information

We may process personal information to:

  • Respond to enquiries and consultation requests
  • Assess advisory, investment or partnership opportunities
  • Prepare proposals and administer engagements
  • Communicate with clients, partners and suppliers
  • Manage contractual and commercial relationships
  • Meet governance, accounting and legal obligations
  • Protect our website, systems and legitimate interests
  • Improve website functionality and user experience
  • Maintain business and correspondence records
  • Send communications where legally permitted

We will not use personal information for an incompatible purpose unless permitted by law or supported by appropriate consent.

06

Lawful Processing

The basis for processing will depend on the circumstances and may include:

Consent

You have agreed to a specific form of processing.

Contract

Processing is required to perform or prepare for an agreement.

Legal obligation

Processing is required by applicable law.

Legitimate interest

Processing supports a lawful business interest without unjustifiably infringing your rights.

Public-law duty

Processing is required for a lawful public function, where applicable.

Protection of interests

Processing is necessary to protect a legitimate interest of a person.

07

Sharing Personal Information

We do not sell personal information. We may share information when reasonably necessary with:

  • Companies within the LuxGroup ecosystem
  • Professional advisers and authorised consultants
  • Website, hosting, email and technology providers
  • Administrative and document-management providers
  • Regulators, law-enforcement bodies or public authorities
  • Parties involved in a lawful corporate transaction

Service providers processing information on our behalf should be subject to appropriate confidentiality, security and data-protection obligations.

08

Cross-Border Processing

Some service providers or technology systems may process or store information outside South Africa.

Where personal information is transferred across borders, we will seek to use a legally permitted transfer mechanism and appropriate safeguards, considering the requirements of POPIA.

09

Information Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, subject to legal, regulatory, contractual and legitimate record-keeping requirements.

When information is no longer required, it may be securely deleted, destroyed or de-identified.

10

Information Security

We use reasonable technical and organisational safeguards appropriate to the nature of the information and the risks associated with its processing.

Measures may include:

  • Access restrictions and authentication controls
  • Secure hosting and system-maintenance practices
  • Data backups and recovery procedures
  • Confidentiality obligations
  • Service-provider assessments and agreements
  • Incident identification and response procedures

No internet transmission or electronic storage system can be guaranteed to be completely secure.

11

Cookies and Website Technologies

This website may use cookies and similar technologies required for security, functionality, preferences and aggregate website analysis.

Where non-essential cookies are introduced, visitors should be provided with appropriate information and consent choices where required.

You may also restrict cookies through your browser settings, although doing so may affect some website functions.

12

Your Personal-Information Rights

Subject to applicable law and appropriate identity verification, you may request:

  • Confirmation that we hold your personal information
  • Access to a record of your personal information
  • Correction of inaccurate or incomplete information
  • Deletion or destruction where legally appropriate
  • Restriction or objection to certain processing
  • Withdrawal of consent where processing relies on consent
  • Information about relevant third-party recipients

Some requests may be limited by legal obligations, privilege, the rights of other people or valid record-retention requirements.

13

Children’s Personal Information

This website and our services are intended for business and professional audiences. We do not knowingly request personal information from children through the general enquiry form.

If you believe a child has submitted personal information without appropriate authorisation, please contact us so that the matter can be reviewed.

14

Security Compromises

Where there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, we will assess and address the incident in accordance with applicable legal obligations.

This may include notification to the Information Regulator and affected data subjects where required.

15

Changes to This Policy

We may update this policy to reflect changes in our practices, services, technology or legal obligations.

The revised version will be published on this page with an updated effective date. Material changes may also be communicated through an appropriate additional notice.

16

Contact and Complaints

To request access, correction, deletion or other assistance regarding personal information, submit a privacy enquiry through our Contact page.

Submit a Privacy Request

If you believe that your personal information has been processed contrary to POPIA, you may also submit a complaint to the Information Regulator of South Africa.

Visit the Information Regulator