02 / 11 —Status

Draft — under legal review.

This document is a draft under legal review and is not yet binding. The final version will replace it here.

03 / 11 —1

Roles under POPIA.

For material uploaded into a workspace (documents, forensic images, and the personal information they contain), the subscribing firm is the responsible party and Klarity (Octio (Pty) Ltd) acts as its operator under the Protection of Personal Information Act, 2013. For account and usage information described in section 2, Klarity is the responsible party.

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What we collect.

Account information — name, email address, password hash, workspace

memberships, roles.

Customer Data — documents and forensic material uploaded by the firm.

Evidence material may contain any category of personal information,

including special personal information; it is processed only on the firm's

instruction and is never used for any other purpose.

Usage information — product analytics (only with your consent, which

you can withdraw at any time in Account settings), security and audit logs,

and support correspondence.

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Why we process it.

To provide and secure the service; to maintain chain-of-custody and audit records; to communicate service messages (invitations, password resets, production deliveries); and, with consent, to understand product usage.

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Where it is processed.

Primary storage and processing is in the AWS Africa (Cape Town) region (af-south-1) — inside South Africa. Sub-operators: Amazon Web Services (hosting), PostHog (product analytics, consent-gated), Google Workspace (support mailbox).

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Retention.

Customer Data is retained under the firm's control and deleted when the firm deletes it or the engagement terminates (subject to a reasonable wind-down period). Audit and custody records are retained for as long as the related workspace exists. Password-reset tokens expire after one hour; invitations after seven days.

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Security.

Per-tenant storage isolation, encryption in transit and at rest, role-based access control, session revocation on password reset, and audited operator access.

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Your rights.

You may request access to, correction of, or deletion of your personal information, and may object to processing, by contacting our Information Officer at support@getklarity.co.za. If unresolved, you may lodge a complaint with the Information Regulator (South Africa).

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Changes.

Material changes to this policy take effect when you accept the revised version, which the application will request on next sign-in.

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Contact.

Information Officer — support@getklarity.co.za