Last updated: January 2026
1.1 This privacy policy (“Privacy Policy“) governs the collection, use, disclosure, retention, transfer, and protection of Personal Information by Lionhead Capital Proprietary Limited, a private company incorporated in the Republic of South Africa, together with its affiliates and related entities (“Lionhead“, “we“, “us“, or “our“), through its websites, online applications, and digital interfaces (collectively the “Website“). Lionhead acts as the responsible party under the Protection of Personal Information Act, Act 4 of 2013 (“POPIA“) and as the data controller for purposes of the EU General Data Protection Regulation (“GDPR“). We recognise the importance of responsible data handling and are committed to protecting the privacy rights of individuals in accordance with applicable data protection laws. “Personal Information” means any information relating to an identified or identifiable natural person, but excludes information that has been (i) made anonymous so that it does not identify a specific person, (ii) permanently de-identified information that does not relate or cannot be traced back to you specifically, (iii) non-personal statistical information collected and compiled by us, and (iv) information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute Personal Information subject to protection under this Privacy Policy).
1.2 We collect Personal Information when you voluntarily provide it through enquiries, applications, submissions, subscriptions, correspondence, meetings, or other interactions via the Website. The categories of Personal Information collected may include names, contact details, business or professional information, identification information, nationality, investment-related information, correspondence records, and any other information necessary to establish, manage, or assess a business or investment relationship, comply with legal and regulatory obligations, or respond to legitimate requests.
1.3 Personal Information is processed for specific and lawful purposes, including assessing and managing potential and existing investor or business relationships, performing contractual or pre-contractual obligations, complying with applicable legal, regulatory, fiduciary, anti-money laundering, counter-terrorist financing, and know-your-customer requirements, responding to enquiries and communications, maintaining internal records, protecting legitimate business interests, improving the Website and our services, and, where permitted by law, sending communications relating to Lionhead’s activities. Processing is carried out only where a lawful basis exists, including where processing is necessary for the performance of a contract or to take steps at your request prior to entering into a contract, where processing is required to comply with a legal obligation, where processing is necessary for Lionhead’s legitimate interests and those interests are not overridden by your rights, or where you have provided consent. Where consent is relied upon, it may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.
1.4 Personal Information may be disclosed to Lionhead’s affiliates, service providers, professional advisers, administrators, regulators, auditors, financial institutions, and other third parties where such disclosure is necessary for the purposes described above or required by applicable law. All third parties processing Personal Information on our behalf are required to implement appropriate technical and organisational safeguards and to process Personal Information only in accordance with Lionhead’s instructions and applicable legal requirements.
1.5 Lionhead implements reasonable and appropriate technical, organisational, and physical security measures designed to protect Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access, having regard to the nature of the information, the risks associated with processing, and generally accepted information security practices. These measures are reviewed and updated periodically to ensure ongoing compliance with applicable law and evolving risks.
1.6 Personal Information is retained only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal, regulatory, and contractual obligations, and to resolve disputes or enforce agreements. Retention periods are determined with reference to applicable legal requirements and business needs, after which Personal Information is securely deleted, destroyed, or irreversibly anonymised.
1.7 Subject to applicable law, individuals have the right to request access to their Personal Information, request correction or deletion of inaccurate, irrelevant, excessive, or unlawfully processed Personal Information, object to or restrict certain processing activities, and, where processing is based on consent, withdraw such consent. Individuals located in the European Union also have the right to data portability and the right not to be subject to decisions based solely on automated processing, including profiling, where such processing produces legal or similarly significant effects. Lionhead does not engage in automated decision-making or profiling through the Website that produces legal or similarly significant effects without meaningful human involvement. Requests to exercise data subject rights may be submitted using the contact details below and will be addressed within the timeframes prescribed by applicable law, subject to any lawful grounds for refusal or limitation.
1.8 Under POPIA, data subjects also have the right to lodge a complaint with the Information Regulator of South Africa if they believe their Personal Information has been processed unlawfully. The Information Regulator can be contacted through its official channels as published from time to time. EU data subjects have the right to lodge a complaint with a supervisory authority.
1.9 Lionhead may use cookies or similar technologies on the Website to ensure functionality, improve user experience, and analyse usage, to the extent permitted by law. Where required, cookie consent mechanisms are implemented, and users may manage cookie preferences through their browser settings or any cookie management tools made available on the Website.
1.10 Personal Information may be transferred to and processed in jurisdictions outside South Africa or the European Economic Area in connection with Lionhead’s international operations. Where such transfers occur, Lionhead ensures that an adequate level of protection is maintained by relying on legally recognised transfer mechanisms, including adequacy decisions, standard contractual clauses approved by the European Commission, or other appropriate safeguards permitted under applicable law.
1.11 The Information Officer for purposes of POPIA and the Data Protection Officer for purposes of GDPR may be contacted at privacy@lionheadcapital.com.
1.12 Any questions, requests, or concerns regarding this Privacy Policy or Lionhead’s processing of Personal Information should be directed to this address.
1.13 By accessing or using the Website or providing Personal Information, you acknowledge that your Personal Information will be processed in accordance with this Privacy Policy and applicable law. If you do not agree with the terms of this Privacy Policy, you should refrain from using the Website or submitting Personal Information. We may change the terms of this Privacy Policy at any time by updating this webpage. This Privacy Policy must be read together with our terms of service, available on our Website.