1. Scope and responsible party
This policy applies when you visit nascent.group, contact us, or otherwise interact with Nascent Group. For personal information processed in South Africa, Nascent Group (South Africa), registration number 2014/056222/07, is the responsible party under POPIA.
Our group also operates through an entity registered in the Republic of Georgia under registration number 436048830. Where another group entity is responsible for a specific engagement, we will identify that entity where appropriate.
2. Personal information we process
Depending on how you interact with us, we may process:
- contact and identity information, such as your name, email address, telephone number, organisation, and role;
- correspondence and enquiry information that you choose to provide when contacting us;
- business relationship information relevant to prospective or existing engagements; and
- technical information routinely generated when you access a website, such as IP address, browser and device information, access times, referring pages, and security logs.
We generally collect this information directly from you or your organisation, from referrals or publicly available business sources, and automatically through ordinary website and server activity.
Providing personal information is generally voluntary. If you do not provide information reasonably required for an enquiry or engagement, we may be unable to respond, proceed with the relationship, or provide the relevant service.
Please do not send special personal information or personal information about children unless it is necessary and we have specifically requested it.
3. How and why we use personal information
We process personal information only where permitted by law, including to:
- respond to enquiries and communicate with you;
- assess, establish, manage, and perform business relationships or agreements;
- operate, protect, and improve our website and systems;
- prevent fraud, misuse, security incidents, and unlawful activity;
- comply with legal, regulatory, and contractual duties; and
- protect our rights, property, personnel, clients, and the public.
The grounds for processing may include your consent, steps required to enter into or perform an agreement, compliance with a legal obligation, or the legitimate interests of you, Nascent Group, or a third party, as contemplated by POPIA.
Website cookies and analytics
This website does not currently use advertising or analytics cookies. Our hosting and security providers may process normal server logs required to deliver and protect the website. If we introduce non-essential cookies or analytics, we will update this policy and implement consent controls where required.
5. Retention and security
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, to manage our relationship with you, and to satisfy legal, regulatory, accounting, dispute-resolution, or legitimate business requirements. We then delete, destroy, or de-identify it where reasonably practicable and legally permitted.
We apply reasonable technical and organisational measures to protect personal information against loss, unauthorised access, interference, misuse, alteration, disclosure, or destruction. No internet transmission or storage system can be guaranteed to be completely secure.
6. Your rights
Subject to POPIA and other applicable law, you may:
- ask whether we hold personal information about you and request access to it;
- request correction, updating, deletion, or destruction of inaccurate, irrelevant, excessive, outdated, incomplete, misleading, or unlawfully obtained information;
- object to processing on reasonable grounds;
- withdraw consent where processing is based on consent, without affecting earlier lawful processing;
- object to or opt out of direct marketing; and
- lodge a complaint with South Africa's Information Regulator.
We may need to verify your identity before actioning a request. Some rights are subject to lawful limitations, and information may be retained where the law requires or permits it.
7. Contact us and lodge a complaint
Send privacy questions or requests to engage@nascent.group or write to us at 609 Buiten Street, Cape Town City Centre, 8001, South Africa.
We encourage you to contact us first so that we can try to resolve your concern. You may also lodge a POPIA complaint with the Information Regulator (South Africa):
- website: inforegulator.org.za
- complaints email: POPIAComplaints@inforegulator.org.za
- telephone: 010 023 5200
You can read the official Protection of Personal Information Act on the South African Government website.
8. Changes to this policy
We may update this policy when our processing activities, services, or legal obligations change. The effective date at the top of this page identifies the current version.