POPIA AND PAIA NOTICE

Protecting Your Personal Information

ZMS respects your privacy and is committed to protecting personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA) and providing access to records in accordance with the Promotion of Access to Information Act 2 of 2000 (PAIA).

For purposes of this notice, references to “ZMS”, “we”, “us” or “our” refer to Zak Steel Proprietary Limited in relation to the operation of the ZMS website and its mining-support activities.

RESPONSIBLE PARTY

Company: Zak Steel Proprietary Limited

Registration number: 2003/015241/07

Registered address: 4 Boniface Road, Selection Park Industrial Sites, Springs, Gauteng, 1559

Postal address: PO Box 747, Springs, Gauteng, 1560

Telephone: +27 11 815 5043

Website: www.zakminingsupport.co.za

INFORMATION OFFICER

Designated Information Officer: Michael Van Loggerenberg

Email: mj@clydeind.co.za

Physical address: 4 Boniface Road, Selection Park Industrial Sites, Springs, Gauteng, 1559

WHAT PERSONAL INFORMATION WE COLLECT

The personal information we collect depends on how you interact with ZMS. It may include:

• Your name and surname
• Company name
• Physical or postal address
• Email address
• Telephone or cellphone number
• Identification or registration information where legally or operationally required
• Product, project and quotation requirements
• Information included in enquiries or messages submitted to us
• Technical website information such as browser type, device information, pages visited and general location information

We aim to collect only the information that is reasonably necessary for the purpose for which it is required.

HOW WE COLLECT INFORMATION

We may collect personal information when you:

• Submit a contact or quotation-request form
• Contact us by telephone or email
• Request information about a product or service
• Enter into a contractual or commercial relationship with us
• Supply products or services to ZMS
• Interact with our website

Where reasonably possible, we will indicate which information is required and which information is optional.

HOW WE USE YOUR INFORMATION

We may use personal information to:

• Respond to enquiries and quotation requests
• Provide information about our products and services
• Prepare quotations and process orders
• Communicate regarding projects, products, deliveries and services
• Fulfil contractual and pre-contractual obligations
• Manage relationships with customers, suppliers and business partners
• Improve our products, services and website
• Maintain appropriate business and financial records
• Protect our systems, operations and legal rights
• Comply with applicable laws, regulations and industry requirements

We will not use personal information for purposes that are materially different from those for which it was collected unless permitted by law or agreed with the data subject.

QUOTE AND CONTACT FORMS

When you submit a quotation request or contact form, the information you provide will be used to review and respond to your enquiry, identify suitable products and prepare any requested quotation.

Submitting a form does not automatically subscribe you to marketing communications. Where marketing consent is requested, it will be presented separately and may be withdrawn at any time.

COOKIES, WEBSITE ANALYTICS AND EMBEDDED CONTENT

The ZMS website may use cookies and similar technologies to provide essential website functionality, remember preferences, understand how visitors use the website and improve the user experience.

We may use Google Analytics to collect aggregated information about website visits, such as pages viewed, visit duration, browser type, device type and general geographic location.

The website may also contain embedded content, such as videos, that is supplied by third-party platforms. These providers may place or read cookies when their content is loaded.

Where required, visitors will be given the opportunity to accept, reject or manage non-essential cookies through the website’s cookie banner. Cookies can also be restricted or deleted through browser settings, although disabling certain cookies may affect some website functionality.

SHARING OF PERSONAL INFORMATION

We may share personal information with trusted service providers or business partners where this is necessary to:

• Respond to an enquiry
• Deliver products or services
• Operate and secure our website
• Provide email, hosting, analytics or technical services
• Fulfil contractual obligations
• Comply with a legal obligation or lawful request

Where third parties process personal information on our behalf, we take reasonable steps to ensure that appropriate confidentiality, privacy and security obligations are in place.

We may also disclose information when required by law, court order, regulatory obligation or when reasonably necessary to protect our rights.

CROSS-BORDER PROCESSING

Certain website, hosting, analytics or technology providers may process or store information outside South Africa.

Where personal information is transferred across borders, reasonable steps will be taken to ensure that the information receives an appropriate level of protection in accordance with POPIA.

INFORMATION SECURITY

ZMS takes reasonable technical and organisational measures to protect personal information against loss, unauthorised access, interference, misuse, alteration, disclosure or destruction.

Although reasonable safeguards are maintained, no internet transmission or electronic storage system can be guaranteed to be completely secure.

INFORMATION RETENTION

Personal information will be retained only for as long as reasonably necessary to fulfil the purpose for which it was collected, meet contractual obligations, resolve disputes and comply with legal or regulatory retention requirements.

When information is no longer required, it will be securely deleted, destroyed or de-identified, subject to applicable legal obligations.

YOUR RIGHTS

Subject to POPIA, PAIA and other applicable legislation, you may have the right to:

• Ask whether we hold personal information about you
• Request access to your personal information
• Ask for inaccurate or incomplete information to be corrected
• Request the deletion or destruction of information where legally permitted
• Object to certain forms of processing
• Withdraw consent where processing is based on consent
• Object to direct marketing
• Submit a complaint concerning the processing of your information

Requests may be sent to the Information Officer using the contact details above. We may require proof of identity before providing access to or changing personal information.

ACCESS TO RECORDS UNDER PAIA

PAIA provides a procedure through which a person may request access to records held by a private body where access is required for the exercise or protection of a right.

A request must be made using the prescribed Form 2 and submitted to the Information Officer. The request should:

• Identify the record being requested
• Provide sufficient information to locate the record
• Explain the right that the requester wishes to exercise or protect
• Explain why the requested record is required
• Specify the preferred form of access
• Include the requester’s contact information
• Include proof of authority when a request is submitted on behalf of another person

Access to a record is subject to the requirements, grounds for refusal and prescribed fees contained in PAIA. ZMS may refuse access where permitted or required by law, including where disclosure would unjustifiably affect another person’s privacy, reveal confidential commercial information, breach legal privilege or prejudice safety and security.

CATEGORIES OF RECORDS

Records held by Zak Steel Proprietary Limited may include:

• Company and statutory records
• Customer and supplier information
• Product and service information
• Quotations, contracts and commercial records
• Financial, accounting and taxation records
• Employment and personnel records
• Operational and manufacturing records
• Policies, procedures and compliance records
• Website, marketing and communication records
• Legal and regulatory records

Certain records, such as publicly available company information, product brochures, technical information, news and website content, may be available without a formal PAIA request.

COMPLAINTS

If you believe your personal information has been processed unlawfully, or if you are dissatisfied with the handling of a PAIA request, you may first contact the ZMS Information Officer.

You may also contact or lodge a complaint with the Information Regulator of South Africa.

Information Regulator

Telephone: 010 023 5200

General enquiries: enquiries@inforegulator.org.za

POPIA complaints: POPIAComplaints@inforegulator.org.za

PAIA complaints: PAIAComplaints@inforegulator.org.za

Website: https://inforegulator.org.za

Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191