Working Capital Wealth Management (Pty) Ltd • Reg. No. 2012/140706/07

1) Company & Contact Details

Registered Name: Working Capital Wealth Management (Pty) Ltd

Registration Number: 2012/140706/07

Physical Address: 22 Carnarvon Place, Durban North, 4051, South Africa

Postal Address: 22 Carnarvon Place, Durban North, 4051, South Africa

Information Officer: Dean Savopoulos

Deputy Information Officer: N/A

Telephone: +27 82 440 2291

Email: dean@wcwm.co.za

Website: https://www.wcwm.co.za

2) Purpose of this Manual

This Manual is prepared in terms of section 51 of the Promotion of Access to Information Act, 2000 (PAIA) and the Protection of Personal Information Act, 2013 (POPIA). It explains how to request access to records held by Working Capital Wealth Management (Pty) Ltd, what records we hold, and how we process personal information.

3) Guide to PAIA

The Information Regulator publishes a guide explaining the PAIA request process (Section 10). It is available from the Information Regulator’s website and office. Contact details are available on the Regulator’s official site.

4) Records Held by the Company

Records are held in the following categories (whether in electronic or physical format). Availability is indicated as: Public (available without a PAIA request), On Request (available in terms of PAIA), or Confidential (restricted or subject to lawful grounds for refusal):

5) Requesting Access to Records (PAIA)

To request access to a record, please submit a completed Form 2 (Request for Access to Record) to the Information Officer at dean@wcwm.co.za. Your request must:

• Identify the record with sufficient detail to enable us to locate it;
• Provide your contact details and preferred form of access;
• State the right you are seeking to exercise or protect, and explain why the requested record is required to exercise or protect that right;
• Include proof of identity (and authority, if requesting on behalf of someone else);
• Be accompanied by the prescribed request fee (if applicable).

Access will be granted in accordance with PAIA, subject to the grounds of refusal (e.g., protection of personal privacy, commercial confidentiality, privilege, and safety). If a request is refused, written reasons will be provided and you may lodge a complaint with the Information Regulator or approach a court.

6) Fees

PAIA prescribes certain fees for records of private bodies. Where applicable, we will notify you of the request fee and any reproduction or access fees before processing your request.

7) PAIA: Personal Information Processing

7.1 Categories of Data Subjects

• Prospective, current and past clients
• Beneficial owners and related parties
• Employees, directors, contractors
• Suppliers and service providers
• Website visitors and marketing contacts

7.2 Categories of Personal Information

• Identifiers (names, ID/passport, registration numbers)
• Contact details (addresses, emails, phone numbers)
• KYC/FICA information (proof of address, source of funds)
• Financial information (banking details, income, assets, transactions)
• Advice & suitability information (risk profiles, objectives)
• Employment information (for HR and onboarding)
• Technical data (IP addresses, device data, cookies – see Cookies Notice)

7.3 Purpose of Processing

• Providing financial services and fulfilling mandates
• FSCA/FAIS/FICA and other legal/regulatory compliance
• Client onboarding, KYC, risk management, and reporting
• Billing, payments, accounting and tax
• Recruitment, HR, and administration
• IT security, fraud prevention and incident management
• Marketing and communications (where lawful and with appropriate opt‑out)

7.4 Lawful Bases

We process personal information on one or more of the following grounds: consent; performance of a contract; compliance with legal obligations; protection of legitimate interests; or pursuit of legitimate interests balanced against privacy rights.

7.5 Sharing & Transborder Flows

We may share personal information with authorised third parties (e.g., product providers, administrators, compliance officers, IT vendors, service providers) subject to confidentiality and security safeguards. Where information is transferred cross‑border, we ensure appropriate protections as required by POPIA.

7.6 Security Safeguards

• Access controls, encryption-in-transit, and least‑privilege principles
• Vendor due diligence and confidentiality undertakings
• Backups, incident response, and business continuity measures
• Employee training and acceptable‑use policies

7.7 Data Retention

Records are retained only as long as necessary for the purpose collected and to meet statutory requirements (e.g., FAIS, FICA, tax), after which they are securely destroyed or anonymised.

7.8 Data Subject Rights

You may request access, correction, deletion (where applicable), objection to processing, or restriction of processing, and you may withdraw consent where processing relies on consent. To exercise your rights, contact the Information Officer at dean@wcwm.co.za.

8) How to Lodge a Complaint

You may lodge a complaint with the Information Regulator using the prescribed forms. Details and forms are available on the Regulator’s official website.

9) Availability of this Manual

This Manual is available free of charge on our website, and a copy can be requested from the Information Officer. Reasonable reproduction charges may apply for printed copies.