HYVE MOBILE’S POLICY ON COOKIE CONSENT

Welcome to our cookie policy. This policy operates alongside and is incorporated by reference in our Privacy Policy.

1. PURPOSE

1.1. This Cookie Policy explains how Hyve Mobile (Pty) Ltd (“the Company”, “we”, “us” or “our”) uses cookies and similar technologies on its website, which is published at www.hyvemobile.co.za and at www.hyvemobile.com (both addresses serve the same website).

1.2. The Company’s website is intended to provide general, informational content regarding the services offered by the Company. No contracts, transactions or services are concluded through this Website.

1.3. This policy must be read together with the Company’s Privacy Policy and PAIA Manual, as contained on the Website, and forms part of the Company’s broader data protection and information security governance framework, including the information security policies and procedures adopted by the Company from time to time.

1.4. This policy explains, amongst other things, how personal information is collected, used and protected in accordance with POPIA and PAIA.

2. DEFINITIONS

2.1. In this policy, unless the context indicates otherwise, the following terms shall have the meanings set out below -

2.1.1. "Cookie(s)" - means small text files that are placed on a user’s device when a website is visited and which are used to enable website functionality, improve performance, or collect usage information;

2.1.2. "Information Officer" - means the person appointed by the Company in terms of

POPIA and PAIA, whose contact details are set out in this policy and the Company’s PAIA manual;

2.1.3. "PAIA" - means the Promotion of Access to Information Act 2 of 2000, together with any regulations issued thereunder;

2.1.4. "Personal Information" - has the meaning assigned to it in section 1 of POPIA and includes any information relating to an identifiable, living natural person or juristic person, where applicable;

2.1.5. "POPIA" - means the Protection of Personal Information Act 4 of 2013, together with any regulations issued thereunder;

2.1.6. "Processing" - has the meaning assigned to it in section 1 of POPIA and includes any operation or activity concerning personal information, whether or not by automated means; and 2.1.7. “Website” - means the website operated by the Company and accessible at www.hyvemobile.co.za and www.hyvemobile.com.

3. WHAT ARE COOKIES?

3.1. Cookies are small text files placed on your device (computer, smartphone or tablet) when you visit a website.

3.2. Cookies help websites to function properly, maintain security and accessibility, and collect information about how visitors interact with the website.

3.3. Cookies may enable certain website features, remember limited user preferences; or collect website usage or performance data.

3.4. Cookies do not usually identify users personally. However, in some instances, information collected through Cookies may constitute Personal Information as defined under POPIA.

4. TYPES OF COOKIES THAT MAY BE USED

The categories of Cookies set out below are used on the Website. The individual Cookies falling within each category, the party that places them, their purpose and how long they remain on your device are listed in the table in paragraph 4.5 below.

4.1. Essential / Strictly Necessary Cookies

4.1.1. These Cookies are necessary for the website to function correctly and securely. They may include Cookies that enable page navigation, support basic security features and ensure correct website display.

4.1.2. These Cookies generally cannot be disabled without impacting website functionality. The Company has a legitimate interest in maintaining a functional and secure website.

4.1.3. On this Website, the strictly necessary Cookies comprise a session security token placed by the Company’s website platform and the Cookies that record the Cookie preferences you select in the Cookie notice referred to in paragraph 5.2 below.

4.2. Performance or Analytics Cookies

4.2.1. Performance or analytics Cookies are used to collect information about how visitors interact with the website, including, for example -

4.2.1.1. the number of visitors;

4.2.1.2. pages visited;

4.2.1.3. time spent on the website; and

4.2.1.4. general geographic region.

4.2.2. The information collected through these Cookies is analysed in aggregated and statistical form to assess website performance, monitor usage trends and improve website content and functionality. It is not intended to identify individual users.

4.2.3. The analytics tools used on the Website are the website analytics functionality built into the Company’s website platform (Squarespace) and Google Analytics 4, operated by Google LLC.

4.2.4. Where analytics Cookies involve the Processing of Personal Information, such Cookies are processed only with the user’s consent, as contemplated in POPIA, and are not activated unless and until such consent has been provided.

4.3. Marketing, Advertising or Social Media Cookies

4.3.1. The Company does not use Cookies for advertising, marketing, behavioural tracking or social media purposes on the Website. No advertising pixels, social media plug-ins or cross-site tracking technologies are deployed. If any such technology is introduced in future, this policy will be updated and the necessary consent mechanisms will be implemented before it is activated.

4.4. Third Party Cookies

4.4.1. Certain content on the Website is provided by third party service providers. The third party services embedded in the Website are -

4.4.1.1. Google Maps, which is embedded on the “Contact Us” page to display the Company’s location; and

4.4.1.2. Google Analytics, as described in paragraph 4.2 above.

4.4.2. These third parties may collect information about your interaction with their content, including your IP address, in accordance with their own privacy policies. The Website also loads fonts, images and scripts from content delivery networks operated by the Company’s website platform and by Adobe (Typekit); these do not place Cookies on your device.

4.4.3. While the Company does not directly control the operation of third party Cookies, the Company takes reasonable steps to assess and permit the use of third party services in line with its data protection and information security obligations. Users are encouraged to review the privacy policies of the relevant third party providers.

4.5. Cookies currently placed on the Website

4.5.1. The table below lists the Cookies placed on the Website as at the date of this policy. The Company reviews this table at least annually and whenever the Website’s functionality or service providers change.

5. LEGAL BASIS FOR USING COOKIES

5.1. Where Cookies involve the Processing of Personal Information, the Company relies on one or more lawful grounds under POPIA, including -

5.1.1. your consent, where required, in respect of performance and analytics Cookies;

5.1.2. the Company’s legitimate interests, as contemplated in section 11(1)(f) of POPIA, in operating and securing the Website and its underlying systems, in respect of strictly necessary Cookies; and

5.1.3. compliance with legal obligations.

5.2. A Cookie notice is displayed when you first access the Website. You may use that notice to accept or decline non-essential Cookies, and your selection is recorded in the Cookies listed in paragraph 4.5 above.

6. MANAGING OR DISABLING COOKIES

6.1. Most web browsers allow users to manage Cookies through their browser settings. You may -

6.1.1. delete Cookies stored on your device;

6.1.2. block certain types of Cookies; or

6.1.3. configure your browser to notify you when Cookies are placed.

6.2. In addition to managing cookies through your browser settings, you may withdraw your consent or update your cookie preferences at any time by contacting the Company's Deputy Information Officer using the details provided in Section 11 below. Please note that withdrawing your consent will not affect the lawfulness of any processing that occurred prior to such withdrawal, but it may impact the functionality of certain non-essential website features

6.3. Should certain Cookies be disabled, this may affect website functionality.

6.4. Guidance on managing Cookies is typically available in your browser’s help section.

6.5. Google also makes available a browser add-on that prevents Google Analytics from collecting information about your visit, which can be obtained at tools.google.com/dlpage/gaoptout.

7. RETENTION OF COOKIE DATA

7.1. Cookies remain on your device for different periods depending on their purpose. They may be -

7.1.1. session Cookies, which are deleted when you close your browser; or

7.1.2. persistent Cookies, which remain on your device for a defined period or until deleted.

7.2. The retention period applicable to each individual Cookie is set out in the table in paragraph 4.5 above. Where Personal Information is processed via Cookies, such information is not retained longer than necessary for the purpose for which it was collected and is managed in accordance with the Company’s data retention and information security practices.

8. PROTECTION OF PERSONAL INFORMATION

8.1. Where Cookies involve the Processing of Personal Information, the Company processes such information in accordance with -

8.1.1. POPIA; and

8.1.2. the Company’s Privacy Policy.

8.2. Reasonable technical and organisational measures are implemented to safeguard Personal Information against loss, unauthorised access or misuse, in accordance with the Company’s information security policies, procedures and risk management practices.

8.3. Any actual or suspected security incident affecting Personal Information processed via Cookies will be managed in accordance with the Company’s incident response and data breach management procedures, as required by applicable law.

8.4. Information collected through the analytics and third party Cookies described in paragraphs 4.2 and 4.4 above, including Cookies operated by Google LLC, may be transmitted to and stored on servers located outside the Republic of South Africa, including in the United States of America. The Company takes reasonable measures to ensure that such third party providers are subject to binding corporate rules, agreements or legal frameworks that provide an adequate level of data protection substantially similar to the conditions for lawful processing set out in POPIA, as contemplated in section 72 of POPIA.

9. YOUR RIGHTS UNDER POPIA AND PAIA

9.1. Subject to applicable law, you may have the right to -

9.1.1. request confirmation of whether Personal Information is held;

9.1.2. request access to, correction or deletion of Personal Information;

9.1.3. object to certain Processing activities; and

9.1.4. lodge a complaint with the Information Regulator of South Africa.

9.2. Requests for access to records must be submitted in accordance with the procedures set out in the Company’s PAIA Manual.

10. UPDATES TO THIS COOKIE POLICY

10.1. The Company may update this Policy from time to time to reflect changes in applicable law, technology, website functionality or its data protection and information security governance framework.

11. CONTACT DETAILS

11.1. If you have any questions about this Policy or the Processing of Personal Information, please contact the Company’s Deputy Information Officer as follows -

Deputy Information Officer: Danielle Thaysen

E-mail: danielle@hyvemobile.co.za

Physical Address: 1st Floor, The Studios, 112 Buitengracht Street, Cape Town, 8001

12. CHANGE HISTORY

The policy is updated and reviewed as part of the continual improvement process.