MORACAPITAL PARTNERS

Privacy Notice

Protection of Personal Information Act, 4 of 2013 (POPIA)

1. Introduction

Mora Capital Partners (Pty) Ltd (registration number 2026/217033/07) is a capital advisory and transaction structuring firm committed to protecting the privacy and personal information of our clients, prospective clients, and any individual whose personal information we process. This Privacy Notice explains how we collect, use, store, share, and protect personal information in accordance with POPIA.

2. Information Officer

Tiego Morallane

Email: tiego@moracapitalpartners.com

Telephone: +27 68 818 2163

Address: 18 Big Charles Avenue, Mooikloof, Pretoria, Gauteng, 0081

3. Personal Information We Collect

3.1 Client and Counterparty Information

  • Company name, registration number, registered address, and contact details
  • Names, identity numbers, residential addresses, contact details, and roles of directors, shareholders, sureties, and authorised representatives
  • Tax identification numbers, VAT registration details, and BEE certification information
  • Beneficial ownership and control information required under FICA

3.2 Financial and Transaction Information

  • Annual financial statements, management accounts, and financial models
  • Bank statements and transactional banking records
  • Personal assets and liabilities statements of directors, shareholders, and sureties
  • Credit information, tax clearance certificates, and credit bureau records
  • Contracts, purchase orders, tenders, service-level agreements, and supporting transaction documentation

3.3 Communication and Engagement Records

  • Email correspondence, telephonic communications, and meeting notes
  • Mandate agreements, suretyship documents, and engagement records
  • Records of introductions to capital providers and related correspondence

4. How We Collect Personal Information

We collect personal information directly from clients and prospective clients through:

  • Email submissions to deals@moracapitalpartners.com
  • Documentation provided during preliminary review and formal engagement
  • Meetings, telephonic discussions, and direct interactions
  • Publicly available sources, credit bureaus, regulatory registers, and third-party verification services

5. Purpose of Processing

  • Conducting preliminary review of prospective transactions
  • Performing capital advisory, transaction structuring, and funding introduction services
  • Preparing credit memoranda, financial models, and information memoranda for submission to capital providers
  • Introducing clients to banks, institutional lenders, DFIs, private credit providers, and other capital providers
  • Complying with legal and regulatory obligations including FICA, anti-money laundering, and counter-terrorism financing requirements
  • Maintaining records of introductions and engagements
  • Enforcing our rights and obligations under signed mandate agreements

6. Lawful Basis for Processing

  • Consent: where the data subject has given express consent
  • Contractual necessity: where processing is necessary for the performance of a contract
  • Legal obligation: where processing is required to comply with an obligation imposed by law
  • Legitimate interest: where processing is necessary to pursue our legitimate interests as an advisory firm

7. Disclosure of Personal Information

We may disclose personal information to:

  • Banks, institutional lenders, DFIs, private credit providers, and investors to whom transactions are submitted
  • Professional advisors including legal counsel, auditors, and tax advisors
  • Regulatory authorities, law enforcement, and courts where required by law
  • Service providers supporting our operations, subject to appropriate data processing arrangements

We do not sell personal information to any third party.

8. Cross-Border Transfers

Where personal information is transferred outside South Africa, we will only do so where the recipient is subject to laws or binding agreements providing adequate protection substantially similar to POPIA, or where another lawful basis under section 72 of POPIA applies.

9. Retention of Personal Information

  • Engagement and transaction records: minimum five years following conclusion of engagement, in accordance with FICA
  • Introduction records: retained for the duration of the Tail Period under the relevant mandate, plus any further period required for fee enforcement
  • Declined engagement information: retained for a reasonable period to enable us to demonstrate the basis for the decision

10. Security Safeguards

In accordance with section 19 of POPIA, we implement:

  • Secure email and document storage with access controls
  • Encryption of sensitive information in transit and at rest
  • Confidentiality obligations on all personnel and third-party service providers
  • Regular review of security practices and incident response procedures

11. Your Rights as a Data Subject

  • The right to be notified that personal information is being collected or accessed without authorisation
  • The right to request confirmation and access to information we hold about you
  • The right to request correction, deletion, or destruction of inaccurate or unlawfully obtained information
  • The right to object to processing on reasonable grounds
  • The right to withdraw consent where processing is based on consent
  • The right to lodge a complaint with the Information Regulator

Requests should be directed to our Information Officer at tiego@moracapitalpartners.com.

12. Information Regulator

Information Regulator (South Africa)

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

Email: complaints.IR@justice.gov.za

Website: www.justice.gov.za/inforeg

13. Updates to This Notice

We may update this Privacy Notice from time to time. The current version is available at www.moracapitalpartners.com/privacy-notice.

14. Contact Us

Mora Capital Partners (Pty) Ltd

Attention: Information Officer

Email: tiego@moracapitalpartners.com

Telephone: +27 68 818 2163

Address: 18 Big Charles Avenue, Mooikloof, Pretoria, Gauteng, 0081