POPIA POLICY

Last updated: 7 September 2026

1. Policy statement

Frigipan (Pty) Ltd is committed to processing personal information lawfully, reasonably and securely in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”). This policy applies to personal information relating to customers, potential customers, suppliers, contractors, employees, website users and other identifiable persons.

2. POPIA principles

Frigipan applies the following conditions for lawful processing:

1. Accountability: responsibility is assigned for POPIA compliance.
2. Processing limitation: information is processed lawfully, minimally and for a justified purpose.
3. Purpose specification: the purpose is identified and information is not retained longer than necessary.
4. Further processing limitation: further use must be compatible with the original purpose or otherwise lawful.
5. Information quality: reasonable steps are taken to keep information complete, accurate and updated.
6. Openness: data subjects are informed about relevant processing practices.
7. Security safeguards: reasonable measures protect information against loss, damage and unauthorised access.
8. Data-subject participation: people may exercise applicable access, correction and objection rights.

3. Categories and purposes

Frigipan processes contact, identity, company, account, project, quotation, order, delivery, invoice, correspondence and website-use information. It is used to manage business relationships; manufacture and supply products; deliver or arrange collection; administer accounts and payments; provide support; manage quality, warranty and legal matters; secure systems; conduct lawful marketing; and comply with legal obligations.

4. Minimality and accuracy

Only information reasonably required for a stated, lawful business purpose should be collected. Employees and authorised service providers must take reasonable steps to keep information accurate and must not use it for an incompatible purpose without a lawful basis.

5. Operators and third parties

Where a service provider processes personal information for Frigipan, Frigipan will take reasonable steps to use an appropriate operator and require confidentiality and suitable security safeguards. Information will be disclosed to other third parties only where authorised, necessary for the transaction or required by law.

6. Security safeguards

Frigipan applies safeguards appropriate to the nature of the information and foreseeable risks. These may include access controls, passwords, backups, system updates, staff confidentiality, secure disposal and service-provider controls.

Suspected loss, unauthorised access or disclosure must be reported promptly to Frigipan’s Information Officer or management. Incidents will be investigated and notifications will be made to the Information Regulator and affected data subjects where required by POPIA.

7. Retention and destruction

Records must be retained only for the period required by law, contract, operational necessity or a legitimate evidentiary purpose. When no longer required, personal information should be securely deleted, destroyed or de-identified.

8. Direct marketing

Direct electronic marketing will be conducted only where permitted by POPIA and other applicable law. Required consent will be obtained, the sender will be identifiable and recipients will be given a reasonable opportunity to opt out.

9. Cross-border processing

Personal information may be transferred outside South Africa only where the transfer complies with POPIA, including through adequate protection, contractual safeguards, binding rules, consent or another permitted ground.

10. Data-subject requests

A data subject may, subject to applicable law, request access to personal information, correction or deletion of inaccurate or unlawfully retained information, or object to certain processing. Requests should be sent to info@frigipan.co.za and must contain enough information to identify the requester and the relevant record.

Frigipan may request proof of identity and may refuse or limit a request where authorised by law. Reasons will be provided where required.

11. Information Officer

Frigipan’s Information Officer is responsible for encouraging compliance, handling requests, working with the Information Regulator, overseeing awareness and maintaining appropriate internal measures. Requests may be directed to:

Email: info@frigipan.co.za
Address: Plot 251, Van Der Hoff Road, Zandfontein 317-JR, Pretoria, 0030
Telephone: 012 752 8765

12. Complaints

Concerns should first be reported to Frigipan at info@frigipan.co.za. A data subject may also complain to the Information Regulator (South Africa) through the current channels published at https://inforegulator.org.za/.

13. Review

This policy will be reviewed periodically and updated when legal requirements, systems or business practices change.