1.INTRODUCTION

1.1 www.timwillard.co.za collects, uses and, in some circumstances, shares the personal information of Users in and through this
website and during the provision of services to you.

1.2 www.timwillard.co.za respects the rights of Users whose personal information is collected and used by it, including their right to
protection against the unlawful collection, retention, sharing and use of such personal information.

1.3 The purpose of this Privacy Policy is to provide Users with information about the information processing activities of www.timwillard.co.za
and the manner in which their rights are protected.

1.4 This Privacy Policy shall serve as a blanket notification to Users about www.timwillard.co.za’ processing activities which will remain valid
for as long as one has an active account with or is using the services of www.timwillard.co.za, including the browsing of this website. Users will not be notified separately on each occasion that www.timwillard.co.za processes the same personal information in the same way over the period.

1.5 www.timwillard.co.za may amend the provisions of this Privacy Policy to comply with any changes in the law, and/or pursuant to any changes to
its information processing activities or privacy practices. Such amendments will be published on the website and will become operable from the date of such publication.

1.6 This privacy policy, and the interpretation and enforcement thereof, will be governed by the laws of the Republic of South Africa.

1.7 The provisions of this Privacy Policy is, as far as possible, incorporated into any agreement between www.timwillard.co.za and Users.

2. DEFINITIONS AND INTERPRETATION 

2.1 In this Privacy Policy, the following words bear the following meanings:

2.1.1 ‘’consent’’ means any voluntary, specific and informed expression of will in terms of which permission is given by or on behalf of a
User for the processing of their personal information;

2.1.2 ‘‘direct marketing’’ means to approach adata subject, either in person or by mail or electronic communication, for the direct or indirect purpose of promoting or offering to supply any goods or services to the data subject;

2.1.3 ‘’informationofficer’’ means the head of www.timwillard.co.za from time to time.

2.1.4 ‘‘operator’’ means an outside third party who processes personal information for or on behalf of www.timwillard.co.za in terms of a
contract or mandate;

2.1.5 ‘’personalinformation’’ means anyinformation linked to a User or information that can identify a User, including but not limited to:

2.1.5.1 information relating to a User’s gender, nationality, ethnic or social origin age, language;

2.1.5.2 a User’s email address, physical address, telephone number, location information or online identifier;

2.1.5.3 a User’s financial information including banking details and invoice information;

2.1.5.4 a User’s personal opinions, views or preferences;

2.1.5.5 correspondence sent by a User which is of a private orconfidential nature;

2.1.5.6 the User’s special personal information, including without limitation information about a User’s health; and

2.1.5.7 the User’s name if it appears with other personal information relating to that User, or if the disclosure of their name on its
own would reveal further personal information about that User;

2.1.6 ‘’POPIA’’ means the Protection of Personal Information Act of 2013, including any regulations or codes of conduct promulgated under
it;

2.1.7 ‘’PAIA’’ means the Promotion of Access to Information Act 2 of 2000;

2.1.8 ‘’process orprocessing’’ means, in relationto personal information, any operation or activity or any set of operations,
whether or not by automatic means, including:

2.1.8.1 the collection, receipt, recording,organisation, collation, storage, updating or modification, retrieval,
alteration, consultation or use of that information;

2.1.8.2 dissemination by means of transmission, distribution ormaking available in any other form; or

2.1.8.3 merging, linking, as well as restriction, degradation, erasure or destruction of that information;

2.1.9 “specialpersonal information” means the religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health, sex life or any biometric information of a User; and may include criminal behaviour of a User to the extent such data relates to the alleged commission of the User of an offence or any proceedings in respect of any offence allegedly committed by a User or the disposal of such
proceedings

2.1.10 “services” means the services provided to any User by www.timwillard.co.za;

2.1.11 ‘’User’’ means a visitor or user of this website, or any of the content or services associated with this website; and

2.1.12 ‘’thewebsite’’ means the website orany part thereof which is accessible from www.point2pointchallenge.co.za .

2.2 Any reference in this Privacy Policy to:

2.2.1 the singular includes the plural and vice versa;

2.2.2 any one gender includes the other genders, as the case maybe;

2.2.3 an act, regulation or other law is to the version of that law in force at the effective date of this Policy and includes any amendment or
re-enactment made to that law after the effective date of this Policy.

2.3 When calculating any number of days for the purposes of this Policy, the first day must be excluded and the last day of the relevant
interval included, unless the last day is not a business day, then the last day will be the next succeeding business day.

2.4 The word "include" means "include without limitation". Use of the word ‘’include’’or ‘’in particular’’ is for illustration or emphasis only and wherefollowed by specific examples must not be interpreted as limiting the meaning of the general wording preceding it.

2.5 A requirement that any Policy, request, demand or other communication made in terms of this Privacy Policy must be in writing will be
met if it is in the form of a data message as defined in the Electronic Communications and Transactions Act, No. 25 of 2002, and is accessible in a
manner usable for subsequent reference, provided that this policy may not be amended as such.

3. RESPONSIBLE PARTY 

3.1 www.timwillard.co.za will be the party who will be collecting and processing a User’s personal information and as such is designated as the
“responsible party’’ for the purposes of this Policy.

3.2 www.timwillard.co.za‘s contact details areas follows:

3.2.1 Email address: connect.with.us@navigate.co.za

3.2.2 Website address: www.timwillard.co.za

3.3 www.timwillard.co.za may instruct third party operators fromtime to time to undertake certain processing activities relating to the User’s
personal information.

4. WHAT PERSONAL INFORMATION IS COLLECTED 

4.1 www.timwillard.co.za may collect the following personal information from the User:

4.1.1 Initials, first name, surname;

4.1.2 Date of birth;

4.1.3 Email address;

4.1.4 Age and language preference;

4.1.5 Gender;

4.1.6 Cellphone and landline number;

4.1.7 Street and postal address;

4.1.8 Employment details;

4.1.9 Company registration and VAT number;

4.1.10 Identity or passport number; and

4.1.11 Banking details.

4.2 The supply of personal information by the User to www.timwillard.co.za is voluntary and not mandatory. However, if the User refuses to supply any personal information, certain consequences may naturally flow from such a refusal, such as preventing www.timwillard.co.za from concluding or performing any contract with the User, or preventing www.timwillard.co.za from complying with one or more of its obligations in law.

4.3 There is an applicable law which directly requires orauthorises www.timwillard.co.za to collect a User’s personal information, namely the Financial Intelligence Centre Act.

5. PURPOSE/S FOR COLLECTION AND PROCESSING OF PERSONAL INFORMATION 

5.1 www.timwillard.co.za shall only collect a User’s personal information for a specific, explicitly defined and lawful purpose relating to a
function or activity of www.timwillard.co.za‘s business.

5.2 Such purposes may include the following:

5.2.1 to enter into a contract with a User;

5.2.2 to perform any obligations under a contract with a User;

5.2.3 to comply with a legal obligation;

5.2.4 to protect a legitimate interest of a User (unless the User has specifically objected in writing to all or some of the processing
activities on reasonable grounds);

5.2.5 to pursue its own legitimate interests or the legitimate interests of a third party who it is sharing the information with (unless the
User has specifically objected in writing to all or some of the processing activities on reasonable grounds);

5.2.6 to process personal information for direct marketing purposes (only if the User has opted in to receiving any direct marketing material);

5.2.7 to customise and display content to the User in a way that www.timwillard.co.za feels may interest the User or be most beneficial to them;

5.2.8 to send content including, but not limited to products,articles, listings and advertisement content to the User via email or other
electronic media, where the User has consented to be contacted by www.timwillard.co.za with such content;

5.2.9 to enable the User to voluntarily participate in interactive features;

5.2.10 to notify the User about changes to the website or services.

5.3 If www.timwillard.co.za intends to process a User’s personalinformation for any other purpose not listed in clause 5.2 or which is
otherwise not automatically permitted by law, it shall ensure that it obtains
the User’s written consent to do so.

5.4 www.timwillard.co.za will not sell a User’s personalinformation to any third party without the prior written consent of the User.

6. COLLECTION DIRECTLY FROM USER

6.1 www.timwillard.co.za shall, as far as possible, always collect personal information about a User directly from the User, except in the
following circumstances:

6.1.1 Where personal information is collected from a public record, or from another source if the information has already been made public
by the User;

6.1.2 where the User has given their written consent to www.timwillard.co.za to collect their information from another source;

6.1.3 where the collection of a User’s personal information from another source will not prejudice any of the User’s legitimate interests;

6.1.4 where the collection of personal information from another source is necessary to maintain www.timwillard.co.za’ legitimate interests or
those of any third party it intends sharing the information with;

6.1.5 where the collection of personal information directly from the User would prejudice the purpose for the collection;

6.1.6 where the collection of personal information directly from the User is not reasonably practicable in the circumstances.

6.2 If www.timwillard.co.za collects personal information from a source other than the User, it shall record in writing the details of that
source, including the full names and contact details of that source where applicable.

6.3 Personal information may be collected from or supplied by the User in any of the following ways:

6.3.1 when subscribing to a service;

6.3.2 when requesting further services or information from www.timwillard.co.za;

6.3.3 when contacting www.timwillard.co.za to report a problem with the website or the services or for any other reason;

6.3.4 when completing any forms on the website.

6.4 The User may visit the website without providing any personal information. However, the website’s servers may still collect technical
information regarding the use of the website, which is aggregated for analytical purposes, technical maintenance and for improving the content
offered on the website. Such information may include details of the User’s visit, information about the User’s computer, including IP (Internet Protocol) address, operating system and browser type, the User’s location, and usage information. An individual User will not be identified from or by this information and www.timwillard.co.za is entitled to copy, distribute or otherwise use such information without limitation.

7. COOKIES 

7.1 “Cookies” are small text files transferred by a web server to a User’s hard drive and thereafter stored on their computer. The types of
information aCookie collects includes a User’s username, the date and time of their visits to the website, their browsing history and preferences.

7.2 www.timwillard.co.za may use Cookies on this website to:

7.2.1 distinguish one User from another on the website;

7.2.2 remember the User’s last session when they return to the website;

7.2.3 estimate the website's audience size and usage patterns;

7.2.4 store information about the User’s preferences, which allows www.timwillard.co.zato customize the website and content according to the Users individual preferences; and

7.2.5 speed up searches on the website.

7.3 The provisions of this clause are only applicable to Cookies used by www.timwillard.co.za. In some instances, third-party service providers
may use Cookies on the website. www.timwillard.co.za cannot and does not control or access Cookies used by third party service providers and takes no responsibility therefore.

7.4 The User has the right and ability to either accept or decline the use of Cookies on their computer’s web browser, whether they are logged in
as a member, or simply casually visiting the website. However, declining the use of Cookies may limit a User’s access to certain features on the website.

8. GENERAL CONDITIONS FOR PROCESSING PERSONALINFORMATION

8.1 www.timwillard.co.za shall comply with all laws, contracts orregulations when it processes a User’s personal information.

8.2 www.timwillard.co.za shall not act unreasonably when processing a User’s personal information. This means that it will collect and
process a User’s personal information in a way that the User can reasonably expect and in a way that is fair.

8.3 www.timwillard.co.za shall respect the User’s right to privacy at all times. If there is another way in which it can achieve the same goal
without posing any risk of harm to the privacy rights of the User, then it will choose that option.

8.4 Similarly, if www.timwillard.co.za needs to process personal information but there are less privacy-invasive methods of collecting, using
and sharing that information, then it will use those methods.

8.5 www.timwillard.co.za shall ensure that the personal information that is collected and processed is and remains relevant to the
identified purpose/s for such processing, and that such information is and remains adequate, but not excessive, for achieving the identified purpose/s.

8.6 If there are any alternative ways to achieve the identified purpose/s without processing personal information, www.timwillard.co.za shall
not process that personal information.

8.7 www.timwillard.co.za shall ensure that the processing activities it chooses to apply are proportionate to achieving the identified
purpose/s and that no less privacy invasive measures are available to achieve the same purpose/s.

8.8 www.timwillard.co.za shall ensure that, regardless of the stated purpose/s for processing personal information, the rights and interests
of Users will not be unnecessarily prejudiced or infringed, unless it cannot be avoided, and then in such cases, it shall ensure that its own rights and/or interests justify such prejudice or infringement taking place.

8.9 www.timwillard.co.za shall be entitled to store the personal information of Users indefinitely unless the User objects thereto. In the event
a User objects to the indefinite storage, once www.timwillard.co.za has achieved the purpose for the collection of the User’s personal information, it
will destroy or delete such information, unless the User has directed otherwise in writing, or www.timwillard.co.za is required by law to retain the
information for a longer period of time.

8.10 If www.timwillard.co.za no longer needs to process personal information to achieve the purpose originally specified, it will stop using
that information.

9. DISCLOSURE AND SHARING OF PERSONAL INFORMATION

9.1 www.timwillard.co.za may, in the course of providing any content or services on this website, or for the purposes of concluding or
performing any other services or transaction with a User, share certain personal information with third party operators who perform certain processing activities on behalf of www.timwillard.co.za.

9.2 The information shared and the categories of third party operators with whom it is shared will always be notified to you prior to being
shared other than if we share with:

9.2.1 Regulators or government departments;

9.2.2 Employees or consultants; and

9.2.3 Professional advisers.

9.3 www.timwillard.co.za may also share aggregated information about Users of this website and their usage patterns. www.timwillard.co.za may
also use such aggregated information to help advertisers target specific audiences. Such aggregated information will be deidentified and the User’s
personal information will not be disclosed.

9.4 Other than as stated in clause 9.1 and 9.3, www.timwillard.co.za shall not share a User’s personal information with any third parties unless it
has the User’s express consent to do so.

10. USER’S RIGHTS IN RELATION TO THE PROCESSING OF THEIR PERSONAL INFORMATION 

10.1 Users shall have the following rights in relation to the processing of their personal information:

10.1.1 to access and correct any personal information held by www.timwillard.co.za about them;

10.1.2 to object to the processing of their information; and

10.1.3 to lodge a complaint with the Information Regulator.

10.2 Users may make a request in terms of clause

10.1.1 by following the process for making such a request as set out in www.timwillard.co.za’ POPIA compliant PAIA manual.

11. FURTHER PROCESSING 

11.1 www.timwillard.co.za shall not process a User’s personal information for any purpose not previously specified except in the following
circumstances:

11.1.1 where the User has consented to such further processing;

11.1.2 where the further processing is necessary for the exercise of any contractual rights or the fulfillment of any obligations between www.timwillard.co.za
and the User;

11.1.3 where the further processing activities are linked to or compatible with the original purpose;

11.1.4 where the further processing is necessary for the prevention, detection, investigation, prosecution and punishment of an offence;

11.1.5 where the further processing is necessary to enforce any law;

11.1.6 where the further processing is necessary for the conduct of legal proceedings in any court or tribunal that have commenced or are
reasonably contemplated;

11.1.7 where the further processing is necessary to prevent or mitigate a serious and imminent threat to the life or health of the User or
another individual;

11.1.8 where the further processing is necessary for historical, statistical or research purposes.

11.2 www.timwillard.co.za shall ensure that if it intends processing personal information for other purposes not previously specified, it
shall notify the User of such further purposes and the possible consequences of the intended further processing for the User.

12. ACCURACY, CORRECTNESS AND COMPLETENESS OF PERSONAL INFORMATION

12.1 www.timwillard.co.za shall take reasonably practicable steps to ensure that the personal information kept by it about Users is complete,
accurate, not misleading and is updated when necessary.

12.2 However, if a User is aware of any personal information in www.timwillard.co.za’s custody that is incorrect, inaccurate or which needs to be updated, the User must make a written request to www.timwillard.co.za’s information officer at connect.with.us@navigate.co.za to update or correct the relevant information.

12.3 If a User has contested the accuracy of any personal information being used by www.timwillard.co.za, it shall immediately stop using
that information until its accuracy has been verified.

12.4 www.timwillard.co.za reserves its right to only adhere to a request from a User in terms of clause 12.2 if the correction or updating of
that information will result in the personal information being correct and accurate.

12.5 Where personal information that has been shared by www.timwillard.co.za with a third party is subsequently updated or corrected, www.timwillard.co.za shall ensure that all third parties, with whom that information was shared, receives the updated and/or corrected version of the information as soon as it has been updated and/or corrected.

13. SECURITY SAFEGUARDS 

13.1 www.timwillard.co.za is committed to protecting the personal information in its custody against any loss of, damage to or unauthorised
destruction of that information, and to prevent any unauthorised parties from accessing that information.

13.2 www.timwillard.co.za takes steps to continually identify and document any risks to the personal information it has in its possession or
under its control and that appropriate security safeguards are in place against those risks.

13.3 www.timwillard.co.za shall ensure that in any contracts entered into with third party operators who process personal information on www.timwillard.co.za’s behalf, include the following obligations:

13.3.1 the operator shall not process any personal information without www.timwillard.co.za’ knowledge and authority;

13.3.2 the operator shall treat all personal information given to it as confidential and shall not disclose it to any unauthorised third parties;

13.3.3 the operator shall establish and maintain adequate security measures which are the same or offer similar protection over the personal
information as that employed by www.timwillard.co.za;

13.3.4 the operator shall notify www.timwillard.co.za immediately where there are reasonable grounds to believe that any personal information has
been leaked to or accessed by any unauthorised person;

13.3.5 if the operator is situated in another country, it must comply with the data protection laws in that country and be able to provide
verification that it is so compliant;

13.3.6 if an operator is legally obliged to disclose any personal information processed by them on www.timwillard.co.za’ behalf to other parties,
it must notify www.timwillard.co.za beforehand to enable www.timwillard.co.za and/or individual Users to protect their rights if necessary.

13.4 www.timwillard.co.za shall ensure that all personal information on its systems is properly backed-up and that back-up copies are
stored separately from the live files.

14. NOTIFICATION OF BREACH OF SECURITY 

14.1 If personal information about a User is inadvertently leaked or www.timwillard.co.za’ security has been unlawfully breached by any
unauthorised party, www.timwillard.co.za shall immediately identify the relevant Users who may be affected by the security breach, and shall contact them at their last known email address or contact details or by the quickest means possible.

14.2 www.timwillard.co.za shall provide sufficient information to the User to allow him or her to take the necessary protective measures against
the potential consequences of the compromise, or shall advise Users of the steps to be taken by them and the possible consequences that may ensue from the breach for them.

15. DECISIONS BASED ON PERSONAL INFORMATION PROCESSED

15.1 If www.timwillard.co.za is required to make a decision about a User using any personal information that has been obtained, it shall ensure
that a record of such information and the decision made is kept for a reasonable period of time to give the User an opportunity to request access to
that record.

15.2 www.timwillard.co.za shall allow a User a reasonable opportunity to make representations before any decision is made solely on the
basis of the personal information processed, if that decision will affect the legal position of the User, or will otherwise adversely affect them in some
manner or form.

15.3 www.timwillard.co.za shall always ensure that the underlying logic behind any decision made pursuant to the automated processing of personal information is sound and that this underlying logic can be communicated to the User to enable them to make representations.

15.4 If www.timwillard.co.za has made a decision/s based on incorrect personal information, it shall immediately revisit that decision as
soon as it receive Policy or becomes aware of the error or inaccuracy of that information.

16. LINKED THIRD PARTY WEBSITES

16.1 This website may contain links or references to other websites, including those of advertisers (“third party websites“)which are not under www.timwillard.co.za’ control.

16.2 The provisions of this Privacy Policy are not applicable to third party websites and www.timwillard.co.za shall not responsible for the
information processing practices and/or privacy policies of those third party websites, or the cookies that those websites may use.

17. DIRECT MARKETING

17.1 The User hereby consents to the processing of their personal information for the purpose of direct marketing by means of electronic
communications including automatic calling machines, facsimile machines, SMS’s or electronic mail.

17.2 www.timwillard.co.za will only send electronic communications to the User for the purpose of marketing similar products or services offered
by www.timwillard.co.za, with the User’s consent.

17.3 The User may object, free of charge, and without unnecessary formality, to the use of their details either when the information was first
collected from them or when each subsequent electronic communication is sent to them by www.timwillard.co.za.

17.4 The User can opt out of receiving further marketing communications by un-checking certain boxes on the forms used on the website to
collect their personal information (if those are in use), or by contacting www.timwillard.co.za at connect.with.us@navigate.co.za.

18. CHILDREN’S PERSONAL INFORMATION 

www.timwillard.co.za shall not process any personal information relating to a person under the age of 18 years unless it has obtained consent
from that person’s parent or legal guardian. If this website is being accessed by the parent or guardian of a child under the age of 18 years, and personal information pertaining to that child is being provided by the parent or guardian, then they hereby expressly consent to www.timwillard.co.za processing such information according to the further provisions of this Privacy Policy.

19. CROSS BORDER TRANSFERS OF PERSONAL INFORMATION 

19.1 www.timwillard.co.za may transfer personal information to another country in the following circumstances:

19.1.2 the transfer is necessary for the conclusion or performance of a contract with a third party which is for the benefit of or in the interest
of the User;

19.1.2 the transfer is necessary for the conclusion or performance of a contract with a third party which is for the benefit of or in the interest
of the User;

19.1.3 the transfer is otherwise for the benefit of the User;

19.1.4 the transfer is for research purposes to prevent or curb the spread of COVID-19 or another viral outbreak; or

19.1.5 the User has consented to the transfer of their information.

19.2 If www.timwillard.co.za is required to transfer personal information from South Africa to a third party in a foreign country, such
foreign country may not have data protection laws with a similar or adequate level of protection as POPIA.

20. RETENTION OF INFORMATION 

20.1 www.timwillard.co.za will keep a record of any personal information collected for no longer than agreed by the User or as is necessary
to achieve the specific purpose for which it collected such information in the first place unless:

20.1.1 It is required by law to keep a record of such information for a longer period of time; or

20.1.2 It needs to keep a record of such information for another lawful purpose; or

20.1.3 It has a contractual obligation to keep a record of such information; or

20.1.4 The User has consented to their information being kept for a longer period.

20.2 www.timwillard.co.za may, if it hasde-identified personal information, kept such information for historical, statistical or research
purposes. www.timwillard.co.za shall ensure that appropriate safeguards are in place to prevent those records from being used for any other purposes, or against the information being re-identified.

21. RETURNING, DESTROYING OR DELETING PERSONAL INFORMATION 

21.1 Where www.timwillard.co.za is no longer authorised to retain a record of any personal information, it shall either:

21.1.1 ensure that the information is permanently destroyed or deleted as soon as reasonably practicable; or

21.1.2 return the information to the User or transfer it to a third party, if requested by the User in writing to do so.

22. CONSENT

22.1 The User hereby consents to the processing of their personal information in terms of the provisions of this Privacy Policy.

22.2 The User acknowledges and agrees that such consent has been given voluntarily after the User has read and understood the provisions of this
Privacy Policy, in particular, regarding the following:

22.2.1 the types of personal information to be processed, including specifically special personal information;

22.2.2 the specific processing activities to be undertaken;

22.2.3 the specific purpose/s for such processing; and

22.2.4 the possible consequences for the User that may arise from such processing.

22.3 Should a User wish to withdraw any consent previously given by the User, they must notify www.timwillard.co.za’s information officer in
writing.

23. LODGING AN OBJECTION 

23.1 A User may, on reasonable grounds, object to the processing of their personal information at any time after that processing has started.

23.2 If a User wishes to object to the processing of their personal information, they must send written Policy of their objection to www.timwillard.co.za’s information officer, together with their reasons for doing so.

24. CHOICE OF LAW 

This Privacy Policy shall be governed and interpreted in accordance with the laws of the Republic of South Africa.

25. AMENDMENT OF THIS PRIVACY POLICY

25.1 www.timwillard.co.za reserves the right to change, update, add, remove and/or amend any of the provisions of this Privacy Policy from time
to time. Such changes, updates, additions, removals or amendments will become effective from the date of their publication on this website.

25.2 It is the User's obligation to periodically check the provisions of this Privacy Policy for any such changes, updates, additions,
removals or amendments.

25.3 The User's continued use of this website following any changes, updates, additions, removals or amendments to this Privacy Policy will
be considered Policy of the User's acceptance to abide by and be bound by this Privacy Policy, as amended. Contact For more information on your rights to privacy over your information, or the information processing activities of www.timwillard.co.za, please do not hesitate to contact us directly on connect.with.us@navigate.co.za

Date of last update: October 2023