Privacy Policy

I. Definitions

For the purposes of this Privacy Policy ("Policy"), the following terms shall bear the meanings assigned to them below, unless the context indicates otherwise. "Personal Information" means information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person, as defined in section 1 of the Protection of Personal Information Act, 4 of 2013 ("POPIA"). "Processing" means any operation or activity performed on Personal Information, including collection, receipt, recording, organisation, collation, storage, updating, retrieval, alteration, consultation, use, dissemination, or destruction thereof. "Data Subject" means the person to whom Personal Information relates, being a visitor, prospective client, or client of the website operated at havrento.site. "Responsible Party" means HVR Ventures (Pty) Ltd, a Proprietary Limited (Pty) Ltd duly registered under the laws of the Republic of South Africa under registration number 8173799074, trading as HVR Ventures, with its registered address at 214 Lois Avenue, 0181 Pretoria, South Africa. "Operator" means any third party which Processes Personal Information for or on behalf of the Responsible Party pursuant to a written contract, including hosting providers and email service providers. "Services" means the financial consulting services (Финансовый консалтинг) marketed and, where applicable, rendered by HVR Ventures via the website at havrento.site, together with the contact form and email subscription facilities made available thereon. "Contact Form" means the electronic form hosted on the website through which a Data Subject may submit an enquiry to HVR Ventures. "Subscription" means the opt-in mechanism by which a Data Subject elects to receive periodic correspondence, newsletters, or marketing communications from HVR Ventures by electronic mail.

II. Identity and Contact Details of the Responsible Party

The Responsible Party for the Processing of Personal Information described in this Policy is HVR Ventures (Pty) Ltd (Proprietary Limited (Pty) Ltd), trading as HVR Ventures, registered with the Companies and Intellectual Property Commission under registration number 8173799074, with its registered physical address at 214 Lois Avenue, 0181 Pretoria, South Africa. Enquiries relating to this Policy, or to the exercise of rights under POPIA, may be directed to [email protected] or by telephone to +27 12 772 4850. HVR Ventures has not appointed a separate Information Officer distinct from the Responsible Party; the functions of Information Officer as contemplated in POPIA are discharged by the Responsible Party at the contact details recorded above, pending any registration with the Information Regulator of South Africa.

III. Personal Information Collected and the Manner of its Collection

HVR Ventures collects Personal Information from two principal sources arising directly out of a Data Subject's voluntary interaction with the website. The first is the Contact Form, through which a Data Subject who wishes to enquire about the Services is invited to submit their full name, email address, telephone number, and any further information they elect to include in the free-text message field, such as details of their financial position or the nature of the consulting assistance sought. The second is the Subscription facility, through which a Data Subject who wishes to receive periodic correspondence from HVR Ventures submits their email address, and optionally their name, for the purpose of being added to the HVR Ventures mailing list. In addition to information volunteered through these two channels, HVR Ventures's hosting infrastructure automatically records limited technical information in server logs in the ordinary course of operating the website, including the Internet Protocol address of the requesting device, the date and time of the request, the browser type and version, and the page requested, for purposes of ensuring the security, stability, and proper functioning of the website.

IV. Purpose and Lawful Basis for Processing

Personal Information submitted through the Contact Form is Processed for the purpose of responding to the Data Subject's enquiry, assessing the nature of the financial consulting assistance requested, and, where the Data Subject proceeds to engage HVR Ventures, for the negotiation and performance of a resultant agreement for the rendering of Services. This Processing is undertaken on the lawful basis that it is necessary for the conclusion or performance of a contract to which the Data Subject is party, alternatively on the basis of the Data Subject's consent freely given upon submission of the form, in accordance with sections 11(1)(a) and 11(1)(b) of POPIA. Personal Information submitted through the Subscription facility is Processed for the purpose of transmitting newsletters and marketing communications concerning the Services, and is Processed solely on the basis of the Data Subject's explicit, opt-in consent, which may be withdrawn at any time as described in Section VIII below, in accordance with section 11(1)(a) of POPIA and, insofar as such communications constitute direct marketing by electronic means, in accordance with section 69 of POPIA. Server log information is Processed on the basis of HVR Ventures's legitimate interest, as contemplated in section 11(1)(f) of POPIA, in maintaining the security and integrity of its website infrastructure.

V. Cookies and Similar Technologies

The website operated at havrento.site makes use of cookies and comparable tracking technologies to the extent, and for the categories of purpose, described in the separate Cookie Policy published on the website. In summary, strictly necessary cookies are deployed without consent insofar as they are essential to the functioning of the website; analytics cookies, which assist HVR Ventures in understanding how visitors use the website, and marketing cookies, which may be used to measure the effectiveness of communications sent pursuant to the Subscription facility, are deployed only where the Data Subject has provided consent through the cookie consent mechanism presented on first visiting the website. A Data Subject may withdraw or amend such consent at any time through the mechanism described in the Cookie Policy.

VI. Disclosure of Personal Information to Third Parties

HVR Ventures does not sell, rent, or trade Personal Information to third parties. Personal Information may be disclosed to Operators engaged by HVR Ventures strictly for the purpose of enabling the Services described in this Policy, including the provider responsible for hosting the website and its underlying database, and the provider responsible for the dispatch of Subscription correspondence. Each such Operator Processes Personal Information solely on the written instruction of HVR Ventures and is contractually bound to implement appropriate security safeguards consistent with the requirements of Chapter 3, Part A of POPIA. Personal Information may further be disclosed where required by law, by order of a competent court, or by lawful request of a regulatory authority, including the Information Regulator of South Africa.

VII. Cross-Border Transfer, Storage, and Retention

Where any Operator engaged by HVR Ventures stores or Processes Personal Information on infrastructure located outside the borders of the Republic of South Africa, such transfer is effected only where the recipient jurisdiction is subject to laws, or the recipient is bound by contractual undertakings, affording a level of protection to Personal Information substantially similar to that provided for under POPIA, as required by section 72 of POPIA. Personal Information submitted through the Contact Form is retained for so long as is reasonably necessary to address the relevant enquiry and, where a client relationship results, for the duration of that relationship and thereafter for such period as is required by applicable South African tax, financial services, and record-keeping legislation. Personal Information submitted through the Subscription facility is retained for as long as the Data Subject remains subscribed, and is deleted or anonymised within a reasonable period following unsubscription. Server log data is retained for a limited period consistent with security and diagnostic purposes and is thereafter purged in the ordinary course.

VIII. Rights of the Data Subject

A Data Subject in respect of whom HVR Ventures Processes Personal Information enjoys the rights afforded under Chapter 3 of POPIA, including the right to be notified that Personal Information concerning them is being collected; the right to establish whether HVR Ventures holds Personal Information concerning them and to request access to the record or a description thereof; the right to request the correction, updating, or deletion of Personal Information which is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully; the right to object, on reasonable grounds, to the Processing of their Personal Information; the right to object at any time to the Processing of their Personal Information for purposes of direct marketing; and the right to withdraw any consent previously given, without affecting the lawfulness of Processing carried out prior to such withdrawal. A Data Subject who wishes to exercise any of the foregoing rights, including a request to unsubscribe from the Subscription facility, may do so by written communication addressed to [email protected] or by telephone to +27 12 772 4850, and HVR Ventures shall respond within a reasonable period and in any event within the time limits prescribed by POPIA. A Data Subject who is dissatisfied with HVR Ventures's handling of their Personal Information, or with the outcome of any request made under this Section, is entitled to lodge a complaint with the Information Regulator of South Africa.

IX. Security Safeguards

HVR Ventures has implemented appropriate, reasonable technical and organisational measures, as contemplated in section 19 of POPIA, to secure the integrity and confidentiality of Personal Information in its possession or under its control, and to prevent loss, damage, unauthorised destruction, unlawful access to, or unauthorised Processing of, such Personal Information. These measures are reviewed periodically and updated as appropriate having regard to generally accepted information security practices applicable to businesses of the nature and scale of HVR Ventures.

X. Amendment of this Policy

HVR Ventures reserves the right to amend this Policy from time to time to reflect changes in its Processing practices, in applicable law, or in the Services offered. The version of this Policy published on the website at havrento.site at any given time shall be the version applicable to Processing conducted by HVR Ventures as at that time, and Data Subjects are encouraged to review this Policy periodically. This Policy was last reviewed and published in 2026.