Privacy Notice

Version / Effective Date: 20 September 2026

1. Who we are

This Privacy Notice explains how 27four Investment Managers (Pty) Ltd, acting through its agricultural investment division, Agrarius ("Agrarius", "we", "us" or "our"), processes personal information. See the section “Contact us” for full contact details.

For purposes of the Protection of Personal Information Act, 2013 ("POPIA"), 27four Investment Managers (Pty) Ltd is the responsible party.

Our financing activities may include relationships involving Agrarius Agri Value Chain RF (Pty) Ltd or another relevant financing entity.

This Notice applies to information processed through our public website, the Agrarius Portal at portal.agrarius.co.za and Agrarius Website at www.agrarius.co.za (the “Sites”) funding applications, investment enquiries and our related business activities.

2. Who this Notice applies to

We may process information relating to:

existing clients and borrowers;
their directors, employees, representatives and authorised Site users;
prospective clients and funding applicants;
persons representing funding applicants;
prospective and existing investors;
persons who make enquiries or request information from us; and
other persons whose information is provided to us in connection with these relationships.

Where applicable, this Notice also applies to information relating to identifiable existing juristic persons as contemplated by POPIA.

3. Information we process

Depending on your relationship with us, we may process:

Identification and contact information, such as names, email addresses, telephone numbers, identifying information, organisations, user details and roles.

Business and company information, including ownership, activities, operations, assets, locations and funding requirements.

Financial and credit information, including financial statements, management accounts, budgets, forecasts, financial ratios, funding requirements, facilities, balances, payments and covenant information.

Agricultural and operational information, including information about farms, businesses, crops, production, planted areas, yields, harvests and operational performance.

KYC and transaction information, including identifying, banking, risk and other information required for due diligence, compliance and transaction administration.

Funding application information, including information and documents submitted when applying for or enquiring about funding and our records relating to the assessment of that application.

Investor information, including contact details, organisation, investment interests and information provided when you enquire about an Agrarius fund or investment opportunity.

Documents and correspondence provided through our Sites or otherwise exchanged with us.

Technical and usage information, including authentication information, IP addresses, browser or device information, login activity, security and system logs, and information about the use of our Sites where analytics have been enabled.

We may also generate financial metrics, forecasts, covenant information and other analytical or monitoring information from information available to us.

4. How we obtain information

We may obtain information:

directly from you;
from the organisation you represent;
through funding applications and investment enquiries;
through the Agrarius Sites;
under applicable financing and transaction documents;
from our accounting, portfolio-management, data-warehouse and other internal systems;
from entities within the 27four group;
from contracted service providers, professional advisers and transaction parties; and
from other lawful sources relevant to the application, transaction or relationship.

5. How we use information

We may process information for the following purposes.

Funding applications

We may use information to:

consider and assess funding applications and enquiries;
analyse an applicant and its business;
assess financial and credit risk;
undertake appropriate due diligence;
communicate with applicants and their representatives;
determine whether an opportunity falls within our lending or investment mandate; and
maintain appropriate records of applications and decisions.

Submitting an application does not oblige Agrarius or any relevant financing entity to provide funding.

Existing financing relationships

We may use information to:

administer facilities and transaction documents;
monitor financial performance and covenants;
monitor agricultural, production, harvest and operational performance;
calculate and monitor balances and payments;
perform credit, investment, risk and portfolio monitoring;
undertake forecasting and internal analysis;
prepare internal reports; and
exercise contractual rights.

We may combine information submitted through the Sites with accounting, payment, portfolio and data-warehouse information for these purposes.

Investors and investment enquiries

If you enquire about an Agrarius investment opportunities, we may use your information to:

respond to your enquiry;
provide information you have requested;
understand your investment interest; and
communicate with you in connection with that enquiry.

Where you have separately consented to receive updates about future Agrarius funds and products, we may also use your contact information for that purpose.

You may unsubscribe from marketing communications at any time using links provided within messages.

General purposes

We may also process information for:

KYC, regulatory and compliance purposes;
accounting and audit;
risk management;
fraud and security prevention;
establishing, exercising or defending legal rights;
operating and securing our website and Portal;
improving our services and systems; and
complying with applicable legal and regulatory requirements.

Depending on the circumstances, our processing may be necessary to take steps requested before entering into an agreement, to perform an agreement, to comply with law, to pursue legitimate interests, on the basis of consent, or on another basis permitted by POPIA.

6. Research, analysis and de-identified information

Where permitted by applicable agreements and law, we may aggregate or appropriately de-identify information and use the resulting information for purposes including:

statistical analysis and research;
benchmarking;
portfolio, industry and agricultural analysis;
model and methodology development;
forecasting;
improving our services; and
developing products, analytical tools and other services.

We do not intend to publish or provide externally an aggregated or de-identified output in a form that identifies the relevant applicant, client or data subject unless otherwise permitted by applicable law and agreement.

Specific contractual rights relating to client information are governed by the applicable finance or transaction documents.

Where necessary for the purposes described in this Notice, we may share information:

within the 27four group;
with the relevant lender or other transaction party;
with contracted professional advisers, consultants and auditors;
with technology and other service providers supporting our operations;
with persons engaged to assist us in administering, analysing or monitoring an application, company, investment or financing relationship; and
with regulators, courts, authorities or other persons where required or permitted by law or applicable agreements.

Where another party processes personal information on our behalf, we require appropriate confidentiality, data-protection and security arrangements.

We do not disclose applicant, client or investor information to unrelated third parties for their own marketing purposes merely because information has been submitted to us.

8. International processing

Our principal Site database, application functions and document-storage infrastructure are hosted in South Africa.

Some supporting technology and service providers may process information outside South Africa.

Where personal information is transferred outside South Africa, we take appropriate steps to ensure that the transfer is permitted under applicable law and subject to appropriate safeguards.

9. How long we keep information

We retain personal information for as long as reasonably necessary for the purposes for which it was collected or subsequently processed.

This may include retention for periods required or permitted by applicable law or reasonably required for purposes such as:

assessing and maintaining records of applications;
administering client and investment relationships;
regulatory and compliance requirements;
audit and accounting;
risk management;
complaints and disputes; and
establishing, exercising or defending legal rights.

Where information is no longer required or authorised to be retained, we will delete, destroy or appropriately de-identify it.

Information that has been properly de-identified may be retained and used for statistical, research, analytical and other lawful purposes.

10. Automated tools and decision-making

We may use automated calculations and analytical tools to assist with financial, covenant, application, portfolio and other monitoring or analysis.

Decisions having material contractual, credit or enforcement consequences are made by authorised personnel and are not made solely through automated processing.

11. Cookies, browser technologies and analytics

We use cookies and similar technologies on our Sites.

Some technologies are essential for functions such as security, authentication, access control and remembering your cookie preferences.

We also use Google Analytics, implemented through Google Tag Manager, to understand how visitors use our Sites and to improve their performance and functionality.

Analytics technologies are optional. They are only activated after you choose to accept analytics cookies.

You may accept or reject optional analytics technologies when first visiting the relevant site and may change your choice at any time using the Cookie settings link.

The technologies used on our Sites may differ.

Details of the cookies, browser storage and other technologies currently used are available in:

These disclosures identify the relevant technologies, their providers, purposes and typical duration.

If we introduce additional optional technologies, such as marketing or advertising technologies, we will update the relevant disclosure and cookie-preference controls where appropriate.

12. Direct marketing

Where you have consented to receive marketing communications, we may contact you about relevant Agrarius funds, investment opportunities or related products using the communication method covered by your consent.

You may withdraw your consent or unsubscribe at any time using the method provided in the communication or by contacting us.

Withdrawing consent does not affect communications necessary to deal with an existing application, enquiry, investment, financing relationship or other legitimate business matter.

We may retain limited information necessary to record and respect an unsubscribe or objection request.

13. Security

We maintain technical and organisational safeguards appropriate to the nature of the information we process.

These include measures relating to authentication, access control, secure communications, system and data security, monitoring and audit trails.

No system can guarantee absolute security. Users of Sites are also responsible for protecting their devices and access methods and should promptly notify us of suspected unauthorised access.

14. Your rights

Subject to POPIA and other applicable law, you may have the right to:

ask whether we hold personal information about you;
request access to your personal information;
request correction of inaccurate or incomplete information;
request deletion or destruction where the applicable requirements are satisfied;
object to certain processing where permitted by law;
withdraw consent where processing relies on consent; and
lodge a complaint with the Information Regulator.

We may need to verify your identity or authority before acting on a request.

Privacy requests may be sent to the Privacy email provided in the “Contact us” section.

15. Changes to this Notice

We may update this Privacy Notice from time to time, including where our activities, systems, technologies or legal obligations change.

The current version and effective date will be made available through our Sites.

The Cookie & Technology Disclosures may be updated separately where the technologies used on the relevant site change.

16. Contact us

27four Investment Managers (Pty) Ltd, acting through its Agrarius division

Registration number: 2007/006556/07 | FSCA licence number 31045

Address: Firestation Rosebank, Fifth floor, 16 Baker Street, Rosebank, Johannesburg, 2196

Attention: Marlene Luizinho Dos Santos

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You may also lodge a complaint with the Information Regulator (South Africa) in accordance with its applicable procedures.