LEGAL

Privacy and Security Policy

Policy operational date: October 2019

Integrity and confidentiality in all our business relationships is of paramount importance to Lodestar. Whilst obtaining accurate and timely information about our investors is important to our ability to deliver a high level of service to our investors, we respect your privacy and are committed to keeping your information confidential.

The protection of all information acquired from you in connection with your use of our website is safeguarded by a set of procedures detailed below. We also undertake not to use or distribute your personal information in any other way without notifying you in advance, via the provision of supplemental privacy policies and statements or otherwise, and giving you adequate opportunity and means to respond.

Collection of personal information

In general, you can visit our website without having to disclose any personal information about yourself.

The personal information we collect relating to you comes primarily from the information and materials you supply to us in connection with your use of this site. We may also collect information about your transactions and experiences over time as you use this site. This is done through the use of “cookies”.

Cookies are small text files consisting of encrypted information assigned to a computer’s browser, which is given to your browser by our web server when you visit our website. This data is stored on your browser. The cookie is sent back to our web server each time you visit our website. Cookies are not computer programs and do not run on a computer like programs do. They cannot gather information or function on their own. They cannot collect any personal information about you or your machine and cannot gather data or information about what you do on the Internet. Cookies merely enable us to provide a more effective and customized online service to you. While you can set up your Internet browser to disable cookie technology, we do not recommend that you do this since some parts of this website may not function properly, or at all.

We may also gather and analyse information on our visitors’ routine visits to this website. We use this information to monitor the areas of the website which are used most frequently and use this knowledge to enhance the website development in future. This information is pooled personal information, behaviour or patterns cannot be identified.

Accessing of personal information

Access to your personal information as retained by Lodestar is governed by the Promotion of Access to Information Act, 2 of 2000. For more details please refer to the relevant section of the website.

Use of personal information

Personal information is used during our normal course of business to provide the relevant information or services to you as per your request.

We may retain any of this information for the purposes of investment transaction processing and administration, to monitor our website and to communicate with you directly. This allows us to tailor our content and provide you with more relevant information.

Confidentiality of information

Lodestar respects your rights to privacy and confidentiality of your information and consequently undertakes not to sell or exchange personal information with any third party outside of the Lodestar group of companies for any purpose whatsoever. However, Lodestar reserves the right to disclose or report personal information in limited circumstances where it is believed in good faith, that disclosure is required under law (included but not limited to a violation or suspected violation of the Prevention of Organised Crime Act and the Financial Intelligence Centre Act), to co-operate with regulators or law enforcement authorities, to perform necessary credit checks or collect or report debts owed to Lodestar, to protect its rights or property, or to disclose information on reasonable request by the fund in which the investor has invested.

Only authorised Lodestar employees or agents will have access to your personal information. All of our employees, service providers and marketing partners are held to stringent standards of privacy and security and are bound by confidentiality agreements.

Security of information

Lodestar is committed to protecting the privacy and confidentiality of your personal information. We take every reasonable step to protect your personal information, including the use of encryption technology. We cannot, however, guarantee the security of any information you transmit to us electronically and you do so at your own risk.

Limitation of liability

The Privacy and Security Policy does not form part of Lodestar’s Terms and Conditions of Use. It is however recommended reading for all website users for information purposes. Whilst every reasonable care has been taken to ensure the accuracy of the information contained in the above policy, Lodestar does not guarantee its accuracy or that it will remain accurate as technology changes.

Lodestar shall not be liable for any losses or damages suffered arising from reliance being placed upon any of the contents of the above policy.

We reserve the right to amend our privacy and security policy at any time. All amendments to the Privacy and Security Policy will be posted on the website. Unless otherwise stated, the current version shall supersede and replace all previous versions of this privacy and security statement.

If you have any questions about our Privacy and Security Policy please email us on. info@lodestarfunds.com

Legal Conditions

Policy operational date: October 2019

Thank you for visiting our website. Please note that the use of Lodestar’s website and its content is governed by a legal framework which regulates the relationship between Lodestar and the users and investors. Please familiarise yourself with the content below prior to using the website.

Online Terms and Conditions of Use

The user/investor hereby acknowledges and agrees that by surfing, browsing on the Lodestar website for the purposes of accessing information and details pertaining to Lodestar, or any of its financial products and services, the user/investor is deemed to have both read and agreed to all the terms and conditions contained therein, our privacy and security policy and the disclaimers.

Lodestar does not warrant in any way that information and materials available on this site are appropriate for use in all jurisdictions available on the web, or that transactions, securities, products, instruments or services offered on this site are available or indeed appropriate for sale or use in all jurisdictions, or by all investors or other potential clients. Those who access this site do so at their own initiative, and are therefore responsible for compliance with applicable local laws and regulations.

Please familiarise yourself with the content below prior to using the website.

Acceptance of online terms and conditions

Online terms and conditions of use come into effect when you access our website for the first time and constitute a binding legal agreement between Lodestar and yourself. The current version of these terms and conditions will govern our respective rights and obligations each time you access this site, and, unless otherwise stated in the current version, all previous versions shall be superseded by the current version.

Lodestar reserves the right to amend the online terms and conditions at any time. By accessing our site you are automatically bound to the version of the conditions published on the site at the time of your visit to this site. You agree to review the current version each time you access the site.

Accuracy of information

Whilst every effort has been made to ensure the accuracy of information contained on this website, Lodestar, its directors or employees provide no representation or warranty, express or implied, regarding the accuracy, completeness or correctness of information contained in this website.

The information and content accessible through this site are provided by Lodestar as general information about the company and its products and services. We do not guarantee the suitability or potential value of any information or particular investment source. Any information in this website is not intended nor does it constitute financial, tax, legal, investment, or other advice.

Before making any decision or taking any action regarding your finances, you should consult a qualified Financial Adviser. Nothing contained in any service or any other content on our website constitutes a solicitation, recommendation, endorsement or offer by Lodestar but shall merely be deemed to be an invitation to do business with us.

Privacy and security

Lodestar respects your rights to privacy, as well as the confidentiality of any information you disclose to us, and consequently undertakes not to sell or exchange personal information with any third party outside of the Lodestar group of companies for any purpose whatsoever.

However, Lodestar reserves the right to disclose or report personal information in limited circumstances where it is believed in good faith, that disclosure is required under law (included but not limited to a violation or suspected violation of the Prevention of Organised Crime Act or the Financial Intelligence Centre Act), to cooperate with regulators or law enforcement authorities, to perform necessary credit checks or collect or report debts owed to Lodestar, to protect its rights or property, or to disclose information on reasonable request by the unit trust fund in which the investor has invested.

Lodestar limits the gathering and use of personal information to that which is deemed necessary to administer its business and to deliver an efficient service to the investor and uses the information consistent with the purpose for which it was originally requested.

More details regarding this are available under the Privacy and Security Policy section.

Copyright and intellectual property laws

In using the website you acknowledge that all information and material displayed on the Lodestar website, including but not limited to logos, graphics, multimedia items and articles, is confidential, is protected by copyright and other intellectual property laws and is restricted to utilisation for information purposes only. Any unauthorised copying, reproduction, transmission, distribution, dissemination, sale, publication or exploitation of the displayed material would constitute an infringement of the protection afforded by law and is therefore prohibited in any form whatsoever.

All logos and trademarks shown on this site are our registered and unregistered trademarks or that of third parties. Nothing on this site should be construed as granting any license or right to use any trademark without our prior written permission and/or that of third parties, as the case may be. You may not, without our prior written permission, use our intellectual property or that of third parties for any other purposes. An application to use our intellectual property must be submitted in writing to . If you do not receive an explicit written response from us within five business days of your request, please consider your request as having been rejected.

Restriction on the use of website

In particular you may not:

reproduce, modify, or create derivative works from; publish, distribute, transmit, or display; or license or transfer any of the contents on the web site – unless you have our the prior written permission;

decompile, reverse engineer, or disassemble the web site, a linked web site, or software;

post on or transmit to the web site content of an unlawful nature, for example: (a) contents that is threatening, libellous, defamatory, obscene, scandalous, inflammatory, pornographic, or profane; or (b) that could damage our image or ability to do business;

use the web site in a manner that could damage, disable, overburden, or impair any Lodestar server, or network connected to any Lodestar server, or interfere with any other party’s use of the web site; or

gain unauthorised access to information from the web site, a Lodestar server, or a network connected to a Lodestar server – through hacking, password mining, or any other means.

Limitation on virus protection

No warranty, whether express or implied, is given that any files, downloads or applications available via this site are free of viruses, trojans, bombs, time-locks or any other data or code which has the ability to corrupt or affect the operation of your computer, database, network or other information system.

Termination, suspension and limitation

We may modify, suspend or discontinue the site, whether temporarily or permanently, without notice. We may also impose limits or conditions on the right to certain services, features or functions and we may restrict access to parts of or all of the services on the site.

Warranty limitations

We do not warrant that the site will be error-free or will meet any particular criteria of accuracy, completeness or reliability of information, performance or quality.

We expressly disclaim all implied warranties, including, without limitation, warranties of merchantability, title, fitness for a particular purpose, non-infringement, compatibility, security and accuracy.

Prevailing law

The conditions and terms of use shall be governed and construed in accordance with the law of the Republic of South Africa without reference to any conflict of law provisions.