POPIA Compliance Policy

Business Manager360 — A Product of Intel360

Protection of Personal Information Act 4 of 2013

1. RESPONSIBLE PARTY AND INFORMATION OFFICER

This POPIA Compliance Policy ("Policy") applies to Intel360 ("we", "us", or "our"), the provider of the Business Manager360 software-as-a-service platform ("Platform"), and is issued in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA"). Responsible Party: Intel360 Product: Business Manager360 Email: info@intel360.co.za Postal Address: 323 Panorama Rd, The Reeds, Centurion, Gauteng, South Africa Intel360 acts as the Responsible Party in respect of personal information collected directly from users of the Platform, and may act as an Operator (data processor) on behalf of Client organisations who are themselves the Responsible Party for the personal information of their own clients, contacts, and staff entered into the Platform. Information Officer: The Information Officer for Intel360 may be contacted at info@intel360.co.za for any matters relating to the processing of personal information, data subject access requests, or complaints under POPIA.

2. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Business Manager360 is a business management platform. The following categories of personal information are collected and processed through the Platform: 2.1 User Account Information • Full name • Email address • User role (e.g. admin, user, editor, viewer) • Organisation membership and group assignments 2.2 Authentication and Session Data • Login credentials (managed securely by the platform auth backend) • Session identifiers • IP addresses • Device and browser information • Login timestamps and activity logs • Heartbeat/session validation data 2.3 Organisation and Billing Information • Owner/administrator email address • Billing contact name, email, phone, and address • Subscription and seat information • Payment records and transaction references 2.4 Client and Contact Information (entered by Clients) • Contact person names • Contact email addresses • Contact phone numbers • Physical/billing addresses • VAT registration numbers • Purchase order numbers • Company and trading names 2.5 Sales and Financial Records • Customer names, emails, phone numbers, and addresses on invoices and quotations • Transaction and payment history • Recurring billing configuration • Lead and pipeline contact data 2.6 Employee and Team Information • Member names and email addresses • Roles and permissions within organisations • Group memberships and access levels • Login activity and last-active timestamps 2.7 Automatically Collected Information • IP address and geolocation (country level) • Browser type and device characteristics • Operating system and language preferences • Usage logs and activity within the Platform Special Categories of Personal Information: Intel360 does not knowingly collect or process special personal information as defined in POPIA (e.g. religious beliefs, race, ethnic origin, health, biometrics, or criminal behaviour). Should any such data be entered inadvertently, it will be deleted upon discovery.

3. PURPOSE AND LAWFUL BASIS FOR PROCESSING

Intel360 processes personal information only where there is a lawful basis under POPIA. The purposes for which we process personal information include: 3.1 Providing the Platform Services • Account creation, authentication, and user management • Delivering the subscribed business management modules (CRM, invoicing, accounting, inventory, reporting) • Managing multi-company and multi-tenant access 3.2 Billing and Subscription Management • Processing subscription payments and recurring billing • Managing seat allocations and organisational licences • Issuing invoices and tracking payment status • Grace period and account status management 3.3 Security and Fraud Prevention • Session validation and single-session enforcement • Detecting and preventing unauthorised access • Maintaining audit trails and activity logs • Protecting user accounts and organisational data 3.4 Communication and Support • Responding to user enquiries and support requests • Sending service notifications and account alerts • Communicating billing and subscription matters 3.5 Legal Compliance • Complying with South African tax and financial record-keeping requirements • Retaining records as required by the South African Revenue Service (SARS) and applicable law • Responding to lawful requests from authorities Lawful Basis: Processing is carried out on the basis of (a) the data subject's consent at registration, (b) the conclusion or performance of a contract with the data subject, (c) compliance with a legal obligation, and (d) Intel360's legitimate interests in operating and securing the Platform.

4. DATA SUBJECTS AND RECIPIENTS

4.1 Data Subjects The personal information processed through the Platform relates to the following categories of data subjects: • Registered users and account holders • Organisation members and administrators • Clients, customers, and contacts entered by Clients into the Platform • Billing contacts and authorised representatives 4.2 Recipients and Sharing Personal information may be shared with or accessible to: • Authorised users within the same organisation (based on role-based access controls and row-level security) • Affiliates and subsidiaries of Intel360, bound by equivalent confidentiality obligations • Payment processors (e.g. Yoco) for the purpose of processing subscription payments — payment card data is handled and stored directly by Yoco in accordance with their own privacy and security standards • Sub-processors and service providers engaged to deliver the Platform (e.g. cloud hosting, email delivery, analytics), all bound by data protection obligations • Third parties in connection with a business transfer, merger, or acquisition, subject to confidentiality • Relevant authorities where required by law or court order Intel360 does not sell personal information to any third party.

5. CROSS-BORDER TRANSFERS

Personal information may be processed or stored on servers located outside of the Republic of South Africa (e.g. cloud infrastructure providers). Where personal information is transferred to a third party in a foreign country, Intel360 ensures that: (a) the recipient is subject to a law, binding corporate rules, or binding agreement which provides an adequate level of protection that does not undermine the safeguards for the protection of personal information; or (b) the data subject has consented to the transfer; or (c) the transfer is necessary for the performance of a contract with the data subject or in their interest. A list of sub-processors and their locations is available upon request from the Information Officer.

6. DATA RETENTION AND DELETION

Intel360 retains personal information only for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. 6.1 Active Account Data Personal information associated with an active subscription is retained for the duration of the subscription and any renewal period. 6.2 Post-Termination Upon termination of a subscription, Intel360 retains Client Data (including personal information) for a period of thirty (30) days, during which the Client may export their data. After this period, personal information may be permanently deleted or anonymised. 6.3 Legal Retention Certain records — including financial transactions, invoices, and tax-related data — may be retained for the period required by South African law (typically five (5) years for tax records under the Tax Administration Act), even after account termination. 6.4 Backup Data Personal information included in backup archives may be retained until the backup cycle completes, after which it is securely deleted or rendered irretrievable.

7. SECURITY MEASURES

Intel360 implements appropriate technical and organisational measures to safeguard personal information against loss, unauthorised access, alteration, or disclosure. These measures include: 7.1 Access Control • Role-based access control (RBAC) with organisation-scoped permissions • Row-level security (RLS) ensuring users only access data within their authorised companies and organisations • Single-session enforcement preventing concurrent logins from multiple devices 7.2 Technical Safeguards • Encrypted authentication tokens managed by the platform auth backend • Session heartbeat validation and automatic logout on invalid sessions • Secure handling of payment data through Yoco (PCI-DSS compliant) • Audit logging of user activity and administrative actions 7.3 Organisational Safeguards • Confidentiality obligations binding on all personnel and sub-processors • Restricted internal access to personal information on a need-to-know basis • Regular review of access permissions and group memberships Despite these safeguards, no system can be guaranteed to be 100% secure. Intel360 will notify affected data subjects and the Information Regulator of any security compromise in accordance with POPIA section 22, where required.

8. DIRECT MARKETING

Intel360 does not process personal information for direct marketing by means of unsolicited electronic communications, except where a data subject has given their explicit consent or where they are an existing client and the marketing relates to similar products or services. Data subjects may opt out of marketing communications at any time by contacting info@intel360.co.za or using the unsubscribe link provided in any communication.

9. DATA SUBJECT RIGHTS

In accordance with POPIA, data subjects have the following rights regarding their personal information: 9.1 Right of Access A data subject may request confirmation as to whether Intel360 processes their personal information, and a description of the personal information held, including the identity of third parties who have access to it. 9.2 Right to Correction A data subject may request the correction or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or unlawfully obtained. 9.3 Right to Deletion A data subject may request the deletion of their personal information, subject to legal retention obligations and the legitimate interests of Intel360. 9.4 Right to Object A data subject may object to the processing of their personal information on legitimate grounds, and Intel360 will cease processing unless there are compelling legitimate grounds that override the data subject's interests. 9.5 Withdrawal of Consent Where processing is based on consent, the data subject may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal. 9.6 How to Exercise Rights To exercise any of these rights, data subjects may submit a data subject access request to the Information Officer at info@intel360.co.za. Intel360 will respond to such requests within a reasonable time, and no later than the periods prescribed by POPIA.

10. AUTOMATED DECISION-MAKING

Intel360 does not make decisions based solely on automated processing that produces legal effects or significantly affects data subjects, except where authorised by law. The Platform does use automated session validation and security monitoring (e.g. single-session enforcement, grace-period triggers), which may result in account access being restricted for security reasons. These automated processes are limited to protecting the security and integrity of the Platform and user accounts.

11. CHILDREN'S INFORMATION

Intel360 does not knowingly collect personal information from children under the age of 18. The Platform is a business-to-business (B2B) service intended for use by registered organisations and their authorised users who are 18 years or older. If we become aware that personal information of a child under 18 has been collected, we will take reasonable steps to delete such information.

12. COMPLAINTS

If a data subject believes that Intel360 has processed their personal information in a manner that contravenes POPIA, they may: 12.1 First submit a complaint to Intel360's Information Officer at info@intel360.co.za. We will acknowledge receipt and investigate the complaint in accordance with our internal procedures. 12.2 If the data subject is not satisfied with Intel360's response, they may lodge a complaint with the Information Regulator (South Africa): The Information Regulator (South Africa) General enquiries: enquiries@inforegulator.org.za Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za Website: https://inforegulator.org.za/

13. RECORDS OF PROCESSING

Intel360 maintains records of processing activities in accordance with POPIA section 17, including: • The purpose of processing • The categories of data subjects and personal information • The recipients or categories of recipients • Cross-border transfers, if any • Retention periods and security safeguards These records are available for inspection by the Information Regulator upon request.

14. POLICY UPDATES

Intel360 may update this POPIA Compliance Policy from time to time to reflect changes in our data practices or applicable law. The updated version will be indicated by an updated "Last updated" date at the top of this Policy. Where material changes are made, we will notify data subjects by posting a prominent notice on the Platform or by direct communication. We encourage data subjects to review this Policy periodically.

15. CONTACT INFORMATION

For any questions, requests, or complaints relating to this POPIA Compliance Policy or the processing of personal information, please contact: Information Officer Intel360 — Business Manager360 Email: info@intel360.co.za Postal Address: 323 Panorama Rd, The Reeds, Centurion, Gauteng, South Africa This POPIA Compliance Policy was last updated on 21 July 2026 and applies to all processing of personal information through the Business Manager360 Platform.