Privacy Statement

Cennergi Holdings (Pty) Ltd
(Hereinafter referred to as “Cennergi”)

1. Introduction and Scope

Cennergi is committed to protecting and respecting your privacy. We strive to ensure that our use of your personal information is lawful, reasonable, and relevant to our business activities.

This Privacy Statement applies when you provide or when Cennergi collects or uses any information that is defined by the Protection of Personal Information Act 4 of 2013 (“POPIA”) as “personal information”. This Privacy Statement is intended to inform you of Cennergi’s privacy practices and to explain how we collect, store, use, transfer and disclose your personal information.

In adopting this Privacy Statement Cennergi wishes to balance its legitimate business interests and rights of persons to their Constitutional right to privacy. Accordingly, Cennergi will take all reasonable steps to prevent unauthorised access to, or disclosure of Personal Information as required by the POPIA.

2. Personal Information we Collect and Why

Personal information can extend to any information where you can be identified directly or indirectly, in particular by reference to an identifier. Information that does not identify a particular person, such as statistical information, is not personal information and is not covered by this Privacy Statement.

Cennergi may collect different types of personal information from you in the context of its business activities, including but not limited to your name, gender, job title, photographic identification, email address, home address, details of your business and other interests, communications with you, an online identifier such as a unique device identification number, and other contact details.

We may collect personal information from you where it is necessary for our business requirements, or in order to comply with applicable laws. It will be made clear to you at the point of collection, the type of personal information we require and the reasons for collecting it. Where it is lawful and practicable for us to allow it, you have the right not to identify yourself when dealing with us. However, if you do not provide us with your personal information, it may impact on our ability to provide you with access to certain features on our website, eg registration as a potential supplier, without first collecting your name and address.

Special personal information is considered to be sensitive and therefore needs additional protection. This includes information about racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, trade union membership, health or medical conditions, genetic or biometric information, sexual orientation, or criminal convictions and offences. Cennergi will only collect, manage and use your special personal information where we have obtained your explicit consent or where we have other lawful grounds to do so under applicable law.

3. How we Collect your Personal Information

Cennergi may collect personal information about you in the following ways:

Information that you provide voluntarily
Cennergi may ask you to provide your contact details when you submit enquiries to us through our website or if you ask to receive information from us. We may also collect personal information during the course of our business interactions with you, including from any communications you send us. If you choose to register with our site, we will ask you to provide certain personal information, including your first and last names, your email address, language, country or location, telephone number and other contact information.

Information that we collect automatically
When you visit our website, or do business with us, Cennergi may collect your personal information, even if you do not create an account. Cennergi may collect information, such as your device type and unique device identification number, IP address, the name of the ISP (Internet Service Provider), the browser, the website from which you gained access to Cennergi’s website, the pages on the Cennergi website you visited and in what sequence, the date and length of visit, and other information concerning the computer’s operating system, language settings, and broad demographic information.

We use this information for our internal operations and analytics purposes and to improve the quality and functionality of our website. Some of this information may be collected using cookies and similar technology. A cookie is information stored on a user’s computer or smart phone by the web browser.

Please note that other third-party websites and social media platforms may be accessible via hyperlinks from the Cennergi website. These websites and platforms are owned and operated by third-parties and are not subject to this Privacy Statement. Cennergi has no control over the content of these websites and platforms and cannot be held liable for any damages, loss or liability of whatsoever nature arising from the use or inability to use third-party websites linked to its website. We encourage you to review the separate privacy policies for these websites before using them, to understand how such third-parties collect, manage and use your personal information.

Information that we obtain from third-party sources
In some cases, we may collect personal information about you from publicly available sources or from a third-party, such as through your representatives, or other third-parties who are entitled to share that information. In addition, where you have expressed an interest in career opportunities with Cennergi, we may obtain personal information provided to us by HR practitioners, hiring managers and recruitment advisors.

4. How we Use your Personal Information

Only personal information that is necessary for the purposes stated in this Privacy Statement will be collected and used by Cennergi. We may use your personal information for the following purposes:

• managing our relationship with you – this includes providing you with information or services, improving our products and services and communicating with you;
• business-related purposes – this includes but is not limited to negotiating, managing, and fulfilling our contracts with customers, suppliers and third-parties (including e-commerce transactions); managing business relationships; leases and licences; conducting clearance procedures; managing accounts and records; supporting corporate social responsibility activities; resource planning and workforce management; activities and operations; internal investigations.
• public relations purposes – this includes analysing the characteristics of visitors to our website; to prepare analytics and profiling for business intelligence purposes; to personalise your experience on our website; managing our newsletters and communications.
• recruitment-related purposes – this includes considering you for career opportunities (including internship positions) with Cennergi and inviting you to participate in recruitment activities and events;
• managing safety and security risks – this includes managing and monitoring access and use of our premises and sites, safety and security at our sites (including through the use of CCTV), and our IT environment (including monitoring electronic communications) and the health of those on our sites;
• website administration and internal operations – this includes troubleshooting, data analysis, testing, research, statistical and survey purposes;
• managing shareholder relationships – this includes for the purposes of undertaking share transactions, dividend payments and communications with shareholders; and
• legal obligations – this includes meeting obligations imposed under law; responding to lawful requests from governments and public authorities; and responding to potential or actual litigation.

5. Where and How we Retain your Personal Information

We are committed to keeping your personal information safe, confidential and secure. We may hold your personal information in electronic or hard copy form. We may keep this information at our own premises, or at sites managed by our service providers. We use physical, electronic and procedural safeguards to do this. We update these safeguards from time to time in order to address new and emerging security threats.

Cennergi retains the personal information we collect from you where we have an ongoing legitimate business need to do so, for example, to provide you with a product or service you have requested, or to comply with applicable legal, tax or accounting requirements. Cennergi’s aim is to keep your personal information for no longer than is necessary for the purpose for which it was collected, or for any other legitimate business requirement.

6. Data Subject Rights

You can request access to your personal information held by us, or request that it be updated, corrected or deleted at any time by contacting our Group Information Officer using the contact details provided under Contact Information. To protect the integrity and security of the information we hold, Cennergi has a defined access procedure, which includes the completion of a form to verify your identity when requesting access to your personal information in our possession.

7. Disclosure of Personal Information to Third-Parties

Your personal information may be disclosed between related entities within the Cennergi group, and may be used by those entities for the same purposes for which we are entitled to use it. In appropriate circumstances, we may also disclose your personal information to the following categories of third-parties:

• auditors, legal and other professional advisers and share registries;
• IT and other service providers;
• our other business partners and their agents;
• government and law enforcement authorities;
• financial and medical institutions;
• prospective buyer or seller of all or part of our business, assets or shares in one of our companies;
• other third-parties where disclosure is required by law; and
• to any other person with your consent to the disclosure.

Cennergi shall take reasonable steps to protect the confidentiality and security of your personal information when it is disclosed to a third-party. Cennergi has in place the necessary measures to ensure third-parties deal with your personal information in accordance with our instructions, applicable privacy laws, and only for the purpose for which it is disclosed.

8. Cross Border Transfer of Personal Information

Third-parties to whom Cennergi may disclose your personal information may be located outside of South Africa, including entities related to Cennergi. Cennergi may process or transfer your personal information to a country other than the country in which you are located. Cennergi will take appropriate safeguards to protect your personal information for all cross border transfers, and ensure that the third-party will handle the information in a manner consistent with this Privacy Statement and all applicable privacy laws.

9. Privacy Statement Review and Updates

Cennergi will review this Privacy Statement periodically and update it from time to time, or when relevant regulatory changes occur. Please visit our website to obtain a copy of the latest version of this Privacy Statement. Where we are required by applicable law, we will make you aware of any material changes.

10. Contact Information

If you have a question, concern or complaint regarding the way in which we handle your personal information, or if you believe that Cennergi has failed to comply with this Privacy Statement or breached any applicable laws in relation to the management of your personal information, you can make a complaint.

Please direct your requests and/ or complaints in writing to:

Itumeleng Lebepe
Group Information Officer
Information.Officer@exxaro.com

Cennergi will review and respond to your request and/ or complaint within the prescribed periods as defined by privacy laws.