IMPORTANT POSITIONING NOTICE

IVC Health provides digital wellness platforms, care navigation tools, and business support services.

IVC Health does not provide medical diagnosis, treatment, clinical monitoring, or medical advice, and its digital platforms are not medical devices.

Any interaction with licensed healthcare professionals occurs outside the core wellness platform and is governed by separate professional and regulatory obligations.

1. INTRODUCTION

IVC Health (Pty) Ltd is a private company registered in the Republic of South Africa under registration number 2014/148595/07.

The Company develops and operates digital wellness, care navigation platforms, together with related business and administrative support services for healthcare‑adjacent industries across Africa.

The Company is committed to:

• Transparency and accountability;

• Compliance with the Constitution of the Republic of South Africa;

• Compliance with the Promotion of Access to Information Act, 2000 (“PAIA”); and

• Compliance with the Protection of Personal Information Act, 2013 (“POPIA”).

This Manual is compiled in accordance with section 51 of PAIA, as amended by POPIA, and sets out:

• Procedures for access to information; and

• Standards for the lawful Processing of Personal Information.

2. DEFINITIONS

Unless the context indicates otherwise, the following terms shall have the meanings assigned below:

2.1 CLIENT

Any natural or juristic person that provides services to the Company.

2.2 COMPANY

Collectively refers to the following private companies registered in South Africa:

• IVC Health (Pty) Ltd (2014/148595/07)

• IVC Financial Services (Pty) Ltd (2016/171791/07)

2.3 CUSTOMERS
Any natural or juristic person who receives wellness, coordination, or administrative services from the Company.

2.4 PERSONAL INFORMATION, PROCESSING, OPERATOR, RESPOMSIBLE PARTY, DATA SUBJECT

As defined in POPIA.

2.5 WELLNESS SERVICES

Non‑clinical, non‑diagnostic digital services intended to support general well‑being awareness, care navigation, and administrative coordination.

All other defined terms shall have the meanings ascribed to them in PAIA and POPIA.

3. PURPOSE OF THIS MANUAL

This Manual aims to:

3.1 PAIA

• Promote the right of access to information;

• Establish transparent procedures for requesting access to records.

3.2 POPIA

• Describe how Personal Information is lawfully Processed;

• Identify categories of Data Subjects and Personal Information;

• Identify recipients of Personal Information;

• Confirm safeguards for Personal Information.

4. COMPANY DETAILS

Physical Address:
50 Betty Street, Riviera, Pretoria, 0184

Postal Address: Same as physical address

5. INFORMATION OFFICER

• Information Officer: Ilse Battheu – Compliance Officer

• Email: ilseb@ivc.co.za

• Telephone: +27 (0)12 001 0020

6. AUTOMATICALLY AVAILABLE RECORDS

No records are currently available automatically without a formal PAIA request.

7. RECORDS AVAILABLE ON REQUEST

The Company holds records relating to:

• Corporate registration and governance

• Financial, accounting, and tax records

• Information technology and security policies

• Operational, contractual, and administrative documentation

Access may be refused where disclosure is restricted under PAIA, POPIA, contractual obligations, or third‑party confidentiality.

8. RECORDS AVAILABLE WITHOUT FORMAL REQUEST

The following may be accessed upon payment of prescribed fees:

• Public records

• Non‑confidential website disclosures

• Statutory filings

• General informational materials

9. RECORDS AVAILABLE UNDER OTHER LEGISLATION

Records are retained in accordance with applicable South African legislation, including but not limited to:

• Companies Act

• National Health Act

• POPIA

• PAIA

• Financial Intelligence Centre Act

• Labour and tax legislation

10. PAIA GUIDE

The PAIA Guide compiled by the Information Regulator is available at: www.inforegulator.org.za

11. TRANSBORDER DATA FLOWS

The Company complies with section 72 of POPIA regarding cross‑border transfers of Personal Information.

12. GROUNDS FOR REFUSAL

Access may be refused where disclosure would:

• Violate privacy rights;

• Expose confidential commercial information;

• Compromise security or legal privilege;

• Harm the Company’s legitimate commercial interests.

13. RECORDS NOT FOUND

If a record cannot be located, the Requester will receive an affidavit detailing the steps taken.

14. REMEDIES FOR REQUESTERS

Requesters may lodge appeals or complaints with:

• The Information Officer;

• The Information Regulator; or

• A competent court, as applicable.

15. REMEDIES FOR THE COMPANY

The Company may lodge complaints where disclosures unlawfully infringe its rights.

16. DATA SUBJECT RIGHTS

Data Subjects have the right to:

• Access their Personal Information;

• Request correction or deletion;

• Object to Processing;

• Lodge complaints with the Information Regulator.

17. REQUEST PROCEDURE

Requests must:

• Be submitted on the prescribed PAIA form;

• Identify the record requested;

• Specify the right being exercised.

18. FEES

Fees apply in accordance with PAIA Regulations (Government Gazette 45057 of 27 August 2021).

19. DECISION ON ACCESS

Requesters will be notified in writing of approval or refusal, with reasons and appeal rights.

20. PROTECTION OF PERSONAL INFORMATION

IVC Health:

• Processes Personal Information lawfully and securely;

• Acts as an Operator where applicable;

• Implements appropriate technical and organisational safeguards.

For further detail, refer to: https://ivc.health/privacy-policy/