Privacy Policy

1. Introduction

FGL Solutions ("FGL Solutions", "we", "us" or "our") respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, store, process, share and protect personal information when you visit our website, contact us, engage with our services or otherwise interact with FGL Solutions.

We process personal information in accordance with applicable South African data protection legislation, including the Protection of Personal Information Act 4 of 2013 ("POPIA").

Where appropriate, we also apply recognised principles of responsible data handling when using artificial intelligence, automation and third-party technology platforms.

By using our website or providing information to us, you acknowledge the practices described in this Privacy Policy.

2. Who We Are

FGL Solutions provides business strategy, systems, digital, website, artificial intelligence, automation and related consulting and implementation services.

For purposes of POPIA, FGL Solutions may act as a "responsible party" when we determine why and how personal information is processed.

In certain circumstances, particularly when providing services to clients, we may process personal information on behalf of a client. In those circumstances, our client may be the responsible party and FGL Solutions may act as an operator.

3. Personal Information We May Collect

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

• Your name and surname
• Business or company name
• Email address
• Telephone or mobile number
• Job title or professional information
• Information submitted through website forms
• Information contained in emails, messages or other communications with us
• Information provided during consultations or project engagements
• Billing, transactional or business information where applicable
• IP address and general device or browser information
• Website usage and interaction information
• Referral information and pages visited
• Cookie and analytics information
• Information you voluntarily provide to us in connection with our services

When providing consulting, AI, automation, website or systems-related services, we may also process information supplied by our clients where reasonably necessary to perform the agreed services.

We endeavour to collect only information that is reasonably necessary for the relevant purpose.

4. How We Collect Personal Information

We may collect personal information:

• Directly from you
• When you complete a website form
• When you email, telephone or message us
• When you request a consultation, quotation or proposal
• When you become a client
• During the provision of our services
• Through website analytics and similar technologies
• From publicly available business sources where lawful and appropriate
• Through service providers and platforms used to operate our business

5. Why We Process Personal Information

We may process personal information for purposes including:

• Responding to enquiries
• Providing quotations and proposals
• Communicating with prospective and existing clients
• Delivering contracted services
• Managing client relationships
• Developing websites, systems, automations and digital solutions
• Providing business and strategic consulting
• Providing artificial intelligence and automation services
• Improving our website and services
• Analysing website performance and usage
• Maintaining security and preventing abuse
• Managing billing, administration and record keeping
• Complying with legal and regulatory obligations
• Establishing, exercising or defending legal rights
• Sending relevant business or marketing communications where permitted by law

We will not intentionally process personal information for purposes incompatible with the purpose for which it was originally collected unless permitted by law or authorised by you.

6. Artificial Intelligence and Automated Technologies

FGL Solutions uses artificial intelligence ("AI"), automation and other advanced technologies as part of its business operations and services.

AI tools may assist us with activities such as:

• Research and information analysis
• Content development and refinement
• Business analysis
• Data organisation
• Workflow automation
• Website and software development
• Coding and technical assistance
• Document analysis
• Marketing and communication support
• Business process optimisation
• Customer and client support
• Development of AI-powered solutions for clients

Depending on the service being provided, information submitted to FGL Solutions may be processed using third-party AI or technology platforms.

We take reasonable steps to avoid submitting unnecessary personal, confidential or sensitive information to AI systems and seek to limit information provided to such systems to what is reasonably necessary for the relevant purpose.

Where practical and appropriate, information may be minimised, anonymised, de-identified or otherwise limited before being processed using AI tools.

### Human Oversight

AI-generated information is used as an assistance tool and does not automatically replace human judgement.

Where an AI-assisted process could materially affect a client or individual, we endeavour to maintain appropriate human oversight and review.

FGL Solutions does not intend to make decisions producing significant legal or similarly substantial consequences for individuals solely through automated processing unless such processing is lawful and appropriate safeguards are in place.

### Accuracy of AI Outputs

Artificial intelligence systems can occasionally produce inaccurate, incomplete or inappropriate results. We therefore apply appropriate human verification and review before material AI-generated outputs are relied upon.

Our use of AI does not remove our responsibility to handle personal information appropriately.

7. Client Information Used in AI Projects

Where FGL Solutions develops or implements an AI or automation solution for a client, the treatment of information may depend on the particular project, platform and services involved.

Clients remain responsible for ensuring that they have appropriate authority to provide personal information to FGL Solutions for processing where they are the responsible party.

Where reasonably required, additional contractual provisions, confidentiality agreements, data processing arrangements or project-specific privacy requirements may apply.

We encourage clients not to provide unnecessary sensitive personal information, passwords, authentication credentials, financial account information or other highly confidential information unless specifically required and appropriate safeguards have been agreed.

8. Third-Party Service Providers

We may use reputable third-party service providers to operate and deliver our website and services.

These may include providers of:

• Website hosting
• Email and communications
• Website forms
• Analytics
• Cloud storage
• Artificial intelligence services
• Automation platforms
• Customer relationship management systems
• Accounting and administrative systems
• Security services
• Website development and technical infrastructure

These providers may process information on our behalf or, depending on the service, under their own applicable privacy terms.

We seek to use providers that maintain appropriate privacy and security practices.

FGL Solutions does not sell personal information to third parties.

9. International Processing and Cross-Border Transfers

Some of the technology, cloud, analytics, communications and artificial intelligence providers used by FGL Solutions may operate infrastructure or process information outside South Africa.

As a result, personal information may in certain circumstances be transferred to or processed in another country.

Where cross-border processing occurs, we take reasonable steps to ensure that the transfer and processing are permitted under applicable South African law and that appropriate safeguards are in place.

10. Cookies and Website Analytics

Our website may use cookies and similar technologies to operate correctly, understand website usage, improve performance and enhance the visitor experience.

Cookies may collect information such as:

• IP address
• Browser type
• Device information
• Pages visited
• Time spent on pages
• General interaction information
• Referring websites or sources

Where required, visitors may be provided with options to manage non-essential cookies.

You may also control or delete cookies through your browser settings, although disabling certain cookies may affect website functionality.

11. Analytics

We may use website analytics and performance-monitoring services to understand how visitors interact with our website.

Information collected through these services may include technical and usage information and may be processed by third-party service providers.

We use this information primarily to understand website performance, identify problems and improve our services and user experience.

12. Contact Forms and Communications

When you contact FGL Solutions through our website, email, telephone, social media or another communication channel, we may retain the information you provide so that we can:

• Respond to your enquiry
• Prepare proposals or quotations
• Provide requested services
• Maintain appropriate business records
• Follow up on legitimate business enquiries

Submitting an enquiry does not automatically subscribe you to ongoing marketing communications.

13. Direct Marketing

Where permitted by law, we may communicate with existing or prospective clients regarding FGL Solutions services that we believe may be relevant to them.

Where consent is legally required, we will seek the appropriate consent.

You may request that we stop sending marketing communications at any time.

An unsubscribe request will not prevent us from sending communications that are reasonably necessary in connection with an existing client relationship, contract, transaction or legal obligation.

14. How We Protect Personal Information

We take reasonable technical and organisational measures designed to protect personal information against:

• Loss
• Misuse
• Unauthorised access
• Unauthorised disclosure
• Alteration
• Destruction
• Unlawful processing

Measures may include access controls, password protection, secure hosting, reputable technology providers, software updates, restricted access and appropriate internal procedures.

No internet transmission, electronic storage system or technology platform can, however, be guaranteed to be completely secure.

15. Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, or for a period required or permitted by applicable law.

Retention periods may depend on:

• The nature of the information
• The purpose for which it was collected
• Contractual requirements
• Tax and accounting requirements
• Legal and regulatory requirements
• Potential disputes or legal claims
• Legitimate business record-keeping requirements

When information is no longer required, we may securely delete, destroy, anonymise or de-identify it where appropriate.

16. Your Rights

Subject to applicable law, you may have the right to:

• Ask whether we hold personal information about you
• Request access to personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion or destruction of information where legally appropriate
• Object to certain processing of your personal information
• Withdraw consent where processing is based on consent
• Object to direct marketing
• Submit a complaint regarding the processing of your personal information

Some rights may be subject to legal limitations or record-retention obligations.

17. Access, Correction and Deletion Requests

If you would like to request access to, correction of or deletion of personal information held by FGL Solutions, you may contact us using the details provided below.

We may need to verify your identity before acting on a request in order to protect personal information against unauthorised disclosure.

Certain access requests may also be dealt with in accordance with the Promotion of Access to Information Act 2 of 2000 ("PAIA"), where applicable.

18. Information Relating to Other People

If you provide FGL Solutions with personal information relating to another person, you are responsible for ensuring that you are lawfully entitled to provide that information to us.

You should not provide another person's personal information without appropriate authority or a lawful basis for doing so.

19. Children's Personal Information

Our website and services are primarily intended for businesses and adults.

We do not knowingly seek to collect children's personal information through our website unless there is a lawful and legitimate reason to do so and the appropriate consent or authority has been obtained where required.

20. Confidential Client Information

In addition to personal information protected under privacy law, FGL Solutions recognises that clients may provide confidential commercial, strategic, technical or operational information during an engagement.

We take reasonable steps to maintain the confidentiality of such information and use it for the purposes of providing the relevant services.

Where required, additional confidentiality obligations may be recorded in contracts or non-disclosure agreements.

21. External Websites and Services

Our website may contain links to third-party websites, platforms or services.

FGL Solutions does not control the privacy practices of independent third parties and is not responsible for their privacy policies or handling of information.

We encourage users to review the privacy policies of external services before providing personal information to them.

22. Data Breaches and Security Incidents

If we become aware of a security compromise involving personal information, we will assess the incident and take reasonable steps to contain and address it.

Where notification is required under applicable law, we will notify the Information Regulator and affected data subjects as required.

23. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

• Our services
• Our technology
• Our use of artificial intelligence
• Our service providers
• Our business operations
• Applicable laws or regulatory requirements

The latest version will be published on this website together with an updated effective date.

24. Contact Us

For questions about this Privacy Policy or the way FGL Solutions handles personal information, or to exercise your privacy rights, please contact:

FGL Solutions
Website: fglsolutions.co.za
Email: info@fglsolutions.co.za

Information Officer: To be designated — contactable via the email address above in the interim.

25. Information Regulator

If you believe your personal information has been processed in a manner that contravenes POPIA, you may have the right to lodge a complaint with the Information Regulator of South Africa.

Information about POPIA, PAIA, data-subject rights and complaint procedures is available directly from the Information Regulator.

26. Governing Law

This Privacy Policy is governed by the laws of the Republic of South Africa.

Any dispute relating to this Privacy Policy or the processing of personal information by FGL Solutions will be dealt with in accordance with applicable South African law.