The Onyx Company ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in compliance with the Protection of Personal Information Act, 2013 (POPIA) of South Africa.
1. Information We Collect
Personal Information
We may collect the following types of personal information:
- Contact Information: Name, email address, phone number, physical address
- Professional Information: Company name, job title, LinkedIn profile
- Business Information: Pitch decks, business plans, financial information (for investment applicants)
- Communication Records: Correspondence via email, contact forms, or other channels
- Technical Data: IP address, browser type, device information, website usage data
How We Collect Information
We collect information through:
- Direct submission via our website forms (newsletter, funding applications, contact forms)
- Email correspondence
- In-person meetings and events
- Third-party referrals (with your consent)
- Cookies and similar technologies on our website
2. Purpose of Processing
We process your personal information for the following purposes:
- Investment Evaluation: To assess funding applications and conduct due diligence
- Communication: To respond to inquiries and provide information about our services
- Newsletter: To send updates about our portfolio, insights, and investment opportunities (with your consent)
- Legal Compliance: To comply with applicable laws, regulations, and legal processes
- Business Operations: To improve our services and website functionality
3. Legal Basis for Processing
Under POPIA, we process your personal information based on:
- Consent: Where you have given explicit consent (e.g., newsletter subscription)
- Contract: Where processing is necessary for entering into or performing a contract
- Legal Obligation: Where we are required to comply with legal requirements
- Legitimate Interest: Where we have a legitimate business interest that does not override your rights
4. Information Sharing
We do not sell your personal information. We may share your information with:
- Service Providers: Third parties who assist with website hosting, email services, and business operations
- Legal Requirements: When required by law, court order, or governmental authority
- Business Transfers: In connection with a merger, acquisition, or sale of assets
- With Your Consent: For any other purpose with your explicit permission
5. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Secure data storage and encryption
- Access controls and authentication
- Regular security assessments
- Staff training on data protection
6. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Specifically:
- Investment Applications: Retained for 5 years after last contact
- Newsletter Subscribers: Until you unsubscribe
- General Inquiries: 2 years after last communication
- Legal Records: As required by applicable law
7. Your Rights Under POPIA
As a data subject, you have the following rights:
- Right to Access: Request confirmation of whether we hold your personal information and access to that information
- Right to Correction: Request correction of inaccurate or incomplete information
- Right to Deletion: Request deletion of your personal information (subject to legal requirements)
- Right to Object: Object to processing of your personal information
- Right to Data Portability: Request transfer of your data to another party
- Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
- Right to Lodge a Complaint: Lodge a complaint with the Information Regulator of South Africa
8. Cookies and Tracking
Our website may use cookies and similar technologies to enhance your browsing experience. You can control cookies through your browser settings. We use:
- Essential Cookies: Necessary for website functionality
- Analytics Cookies: To understand how visitors use our site
- Preference Cookies: To remember your settings (e.g., dark/light mode)
9. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.
10. Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected such information, please contact us immediately.
11. International Transfers
If we transfer your personal information outside South Africa, we will ensure appropriate safeguards are in place to protect your information in accordance with POPIA requirements.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "Last Updated" date. We encourage you to review this policy periodically.
13. Contact Us
If you have questions about this Privacy Policy, wish to exercise your rights, or have concerns about our data practices, please contact us:
14. Information Regulator
You have the right to lodge a complaint with the Information Regulator of South Africa: