Introduction

This document sets forth the Praesidium Capital Management Privacy Policy (the “Privacy Policy”) for this Web site, www.pcap.co.za (the “Site”). If you have objections to the Privacy Policy, you should not access or use this Site. This Privacy Policy does not govern privacy practices associated with offline activities or any other web sites. Praesidium Capital Management is a provider of financial services to the industry. Praesidium Capital Management utilises the web for both marketing and service delivery. Praesidium Capital Management supports ethical use of personal information and subscribes to the privacy policy herein.

Changes in Privacy Policy

All “personal information” (“personal information” is defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains) that we collect and maintain will be subject to the version of the Privacy Policy in effect at the time of such collection. Praesidium Capital Management reserves the right to change the Privacy Policy from time to time at its sole discretion, and will provide notice of material changes on the home page of the Site. If as the result of such changes, you want to alter the ways in which Praesidium Capital Management is allowed to use your personal information, you can do so by following the procedure described below in the section titled “Updating your personal information and privacy preferences.” You will be deemed to have been made aware of, and will be subject to, the changes to the Privacy Policy by your continued use of the Site after such notice has been posted for thirty (30) days. However, if Praesidium Capital Management sells assets to another entity, or is acquired by, or merged with, another entity, Praesidium Capital Management may provide to such entity customer information that is related to that part of our business that was sold to or merged with the other entity without your consent.

Collection of personal information

As a visitor to this Site, you can engage in many activities without providing any personal information. In connection with other activities, such as contacting Praesidium Capital Management, Praesidium Capital Management may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, Praesidium Capital Management may ask that you provide us personal information, such as your first and last name, e-mail address, website, reason for contacting Praesidium Capital Management and a brief message. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.

How your personal information is used

Praesidium Capital Management collects your information in order to record and support your participation in the activities you select. If, for example, you subscribe to a service, the information is used to register your subscription preferences and rights, if any, to support or other benefits that may be made available to registered subscribers. Your personal information is also used to keep you informed about Praesidium Capital Management products and services if you have so opted to receive such communications.

Praesidium Capital Management may collect information about the use of the Site, such as the types of services used and how many users we receive daily. This information is collected in aggregate form, without identifying any user individually. Praesidium Capital Management may use this aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes.

Your choices with respect to personal information

Praesidium Capital Management recognises and appreciates the importance of responsible use of information collected on this Site. Except in the particular circumstances described in this Privacy Policy, Praesidium Capital Management will not provide your name to other companies or organizations without your consent.

There are other instances in which Praesidium Capital Management may divulge your personal information. Praesidium Capital Management may provide your personal information if necessary, in Praesidium Capital Management’s good faith judgment, to comply with laws or regulations of a governmental or regulatory body or in response to a valid subpoena, warrant, or order or to protect the rights of Praesidium Capital Management or others.

Privacy-related inquiries and complaints

Praesidium Capital Management takes its users’ privacy concerns seriously. If you believe that Praesidium Capital Management has not complied with this Online Privacy Policy with respect to your personal information or you have other related inquiries or concerns, you may write to the Manager of Praesidium Capital Management at the address indicated.

In your letter, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that the Praesidium Capital Management Online Privacy Policy has not been complied with. We will investigate your inquiry or complaint promptly. Please note that Praesidium Capital Management is not responsible for the content or privacy practices of non-Praesidium Capital Management web sites to which this Site or any other Praesidium Capital Management Web site may link. You should review the privacy policy of such sites before using the sites.