1. Your privacy. This Privacy Policy explains our policies and practices regarding the collection, use, storage, and disclosure of your personal information by HR Focus Holdings (Pty) Ltd. We want you to feel secure when visiting our website and are committed to maintaining your privacy when doing so. The information below provides an overview of how we protect your privacy.

2. What personal information do we gather? In general, you may visit HR Focus website without providing us with any personal information about yourself. However, there are times when we may need information from you, which includes your internet address so that we can track unique visits to our site for analytic purposes. Additionally, we may need your personal information such as your name, and your postal and email address in order to grant you access to protected and secured sites or provide you with the opportunity to register for an event, to fulfill your requests for information including white papers, download updates to our products, or participate in an online survey. In other instances, we may ask you to provide us with information such as your product interests so that we can send you only the information that is useful to you, including articles, newsletters, product and service alerts, new product and service announcements and event invitations. When we collect this type of information, we will inform you as to why we are asking for information and how the information will be used. However, please note that providing any personal information is optional. When you receive your confirmation email or when you receive any email from the list server, you will be given instructions on how to remove yourself from the list.

3. How do we collect your personal information? We collect information directly through response forms that you choose to complete. We may also collect information indirectly through the use of cookies. The cookies we use identify you only as a number. "Persistent" cookies are stored on your computer and used in subsequent visits to our sites. "Session" cookies only exist for a specific visit. You can disable your computer from accepting one or both cookie types by changing the settings in preferences or options menu in your browser.

4. How do we use your personal information? Information we collect is used to determine what is most effective about our website, to help us identify ways to improve sites, to personalize the visit for you through the use of "persistent cookies" if you permit it, and to determine how we can tailor our website to make it more effective. We may also use data for other purposes, which we would describe to you at the point we collect the information (for example, if you are invited to register for an event).

5. Do we share your information with outside parties? We do not sell personal information and we share it only with our advisors, suppliers and selected partners and only to the extent it is necessary to facilitate the transaction or an event related to you. For example, we may need to share information in the case of an event where we need to provide our caterer with meal preference information. But again, before you submit any information, we will inform you of the reason we are asking you for specific information, the parties to whom such information may be disclosed, and it is up to you whether or not you want to provide it. You may separately agree to provide your personal information to third parties that provide content for HR Focus, in order to access and/or use their products and/or services. If you agree to provide such information to these third parties, then your personal information will be subject to their privacy policies.

In addition to the foregoing, the following are the additional instances where we may disclose your personal information to third parties:

• To investigate potentially fraudulent or questionable activities regarding your account(s) or the violation of our Terms of Use
• In anticipation of and in the course of an actual or potential sale, reorganization, consolidation, merger or amalgamation of our business
• When required or permitted by law

The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances such as a legal proceeding or court order, we may also be required to disclose certain information to authorities. Only the information specifically requested will be disclosed and we will take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so.

There are some situations where we are legally permitted to disclose personal information, such as employing reasonable and legal methods to enforce our rights or to investigate suspicion of illegal activities.

6. What about sensitive data? We do not typically collect sensitive personal data through this website. If we do seek to collect such data, we will inform you as to our intended use of such sensitive data and ask you to consent to our storing and the proposed uses of such data. We may also collect some sensitive personal data incidentally. For instance, we may collect data incidentally when a user uploads his/her resume, because the resume may contain this information. By providing us with unsolicited sensitive personal data, you consent to our using the data subject to applicable law as described in this Privacy Policy. The references to "sensitive personal data" apply to the various categories of personal data identified by the applicable data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent. These categories comprise personal identity numbers; personal data about personality and private life; racial or ethnic origin; nationality; political opinions; membership of political parties or movements; religious, philosophical, or other similar beliefs; membership of a trade union or profession or trade association; physical or mental health; genetic code; addictions; sexual life; property matters; or criminal record (including information about suspected criminal activities). HR Focus does not knowingly collect data from or market to children anywhere.

7. What about security? The security of your personal information is important to HR Focus and we take appropriate steps to maintain security of your personal information. The open nature of the internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended. While this is out of our control, we aim to apply appropriate levels of security at all times. We use industry standard technologies and maintain current security standards to ensure that your personal information is protected against unauthorized access, disclosure, inappropriate alteration, or misuse. Electronic customer files are kept in a secured environment with restricted access.

We manage our server environment appropriately and our firewall infrastructure is strictly adhered to. We routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised. Our BETS Support and Partner Pavilion websites use Secure Socket Layer (SSL) to enhance security. SSL is the industry standard technology for protecting and maintaining the security of message transmissions over the internet. When you access your accounts or send information from secured sites, encryption will scramble your data into an unreadable format to inhibit unauthorized access by others.

To safeguard against unauthorized access to your accounts, you are required to "sign on" using a user ID and a password to certain secured areas of the www.hr-focus.com website. Both user ID and password are encrypted when sent over the internet. If you are unable to provide the correct password, you will not be able to access these sections. Despite all of our efforts, the internet is inherently unsecure and we cannot guarantee that information provided online will be secure at all times. Suffice it to say that the security of your personal information is important to us and we will use all reasonable means to keep it as safe as possible.

8. Do we give you access to your information? You are entitled to know whether we hold information about you and, if we do, to have access to that information and require it to be corrected if it is inaccurate. You can do this by contacting us via info@hr-focus.com.

9. Updating this Privacy Policy. Any changes to our Privacy Policy and information handling practices will be acknowledged in this Privacy Policy in a timely manner. We may add, modify or remove portions of this Privacy Policy when we believe it is appropriate to do so. You may determine when we last updated it by referring to the modification date found at the bottom of this Privacy Policy.

10. General. Put simply, we value your trust in us. So we want to maintain your privacy and work with you to ensure that this website and the information and services we provide to you are a valuable resource for you. For any more information about this website or your visit, please contact us at info@hr-focus.com.