1.1 Responsible Party Structure

Licentia Franchise SA (Pty) Ltd
Registration Number: 2015/172514/07
("Licentia Head Office")

is designated as the Primary Responsible Party in terms of the Protection of Personal Information Act 4 of 2013 ("POPIA").

The following registered provincial entities operate under the Licentia brand and function as Joint Responsible Parties within their defined territorial jurisdictions:

• Licentia Mpu Malanga (Pty) Ltd – 2022/218545/07
• Licentia KwaZulu Natal (Pty) Ltd – 2020/054282/07
• Licentia Gau Teng (Pty) Ltd – 2021/493538/07
• Licentia Free State (Pty) Ltd – 2021/619945/07
• Licentia Limpopo (Pty) Ltd – 2022/836315/07
• Licentia North West (Pty) Ltd – 2023/574703/07

Collectively referred to as the "Licentia Group".

1.1.1 Legal Status of Processing Structure

For purposes of POPIA:

• Each Provincial Entity is an independent registered juristic person authorised to process personal information within the scope of its territorial franchise mandate.
• Licentia Head Office exercises centralised governance, compliance oversight, operational system control, audit authority, and risk management supervision over all Provincial Entities operating under the Licentia brand.
• The processing of personal information within the Licentia Group is structured as a Joint Responsible Party model in terms of POPIA, read with Sections 8, 11, 19, 20, and 21 thereof.

Head Office retains ultimate authority to:

• implement uniform data protection standards;
• issue mandatory compliance directives to Provincial Entities;
• conduct compliance audits and investigations;
• restrict, suspend, or revoke system access; and/or
• intervene where regulatory, legal, operational, or reputational risk arises.

1.1.2 Scope of Processing Authority (MaxMind Legal Department Integrated)

Personal information may be processed by:

• the Provincial Entity directly mandated by a client; and/or
• Licentia Head Office; and/or
• authorised internal departments (including Legal, Compliance, Finance, Audit, IT Governance); and/or
• where required, the Legal Department operated within MaxMind Group of Companies (Pty) Ltd (Registration Number: 2021/997887/07), as the group legal function supporting Licentia Head Office and its provincial entities; and/or
• appointed operators, professional advisors, external attorneys, advocates, or specialist consultants, strictly where necessary for lawful service execution, regulatory processes, enforcement, or dispute resolution.

Such processing may occur where reasonably required for:

• mandate execution;
• regulatory submissions;
• compliance verification;
• governance oversight;
• royalty and financial administration;
• risk management and internal audit;
• dispute resolution and legal enforcement; and
• business continuity and system security.

1.1.3 Franchise and System-Level Authority

All Provincial Entities operate under binding Franchise Agreements and internal governance policies issued by Licentia Head Office.

Accordingly:

• data collected by a Provincial Entity may form part of the Licentia Group’s central compliance and governance system;
• Head Office may lawfully access, monitor, review, regulate, and control such data where required for lawful and reasonable business purposes; and
• access is governed by role-based system controls and audit logging protocols.

1.1.4 Accountability and Liability Framework

In accordance with Section 8 of POPIA:

• the Responsible Party bears accountability for compliance with the conditions for lawful processing;
• Licentia Head Office coordinates compliance standards across the Licentia Group;
• Provincial Entities remain accountable for processing activities conducted within their mandate; and
• where processing occurs jointly, accountability is determined according to the nature of the processing activity and applicable contractual governance instruments.

Nothing in this structure limits statutory obligations under POPIA.

1.1.5 No Agency Misrepresentation

Provincial Entities operate as independent registered companies under territorial licence.

Nothing in this Notice shall be construed as creating:

• a partnership;
• an unlimited agency; or
• a legal merger of entities.

The Joint Responsible Party structure applies strictly for purposes of lawful processing and governance coordination under POPIA.

1.1.6 Future Provincial Entities

Any future entity lawfully registered under the Licentia brand and operating under a valid franchise or territorial licence agreement shall automatically fall within this Responsible Party framework without requiring amendment to this Notice.

1.2 Franchise Governance Model

Licentia operates under a structured franchise and territorial licensing governance model within the Republic of South Africa.

Under this model, Licentia Franchise SA (Pty) Ltd ("Licentia Head Office") governs, standardises, and enforces operational and compliance frameworks for provincial entities and authorised franchise operators who deliver Licentia services within defined territories.

1.2.1 Provincial Entity Structure and Territorial Authority

Provincial entities operate as independently registered juristic persons under the Licentia brand and are authorised to deliver Licentia services within defined territorial jurisdictions.

Each provincial entity is contractually bound by:

• Franchise Agreements (or territorial licensing agreements);
• Service Level Agreements (SLA) and operational policies;
• governance directives and compliance manuals issued by Licentia Head Office; and
• system rules applicable to Licentia’s digital platforms and compliance processes.

Provincial entities are responsible for direct client engagement and service delivery within their territory, including client communications, regulatory processes, and operational execution of mandates.

1.2.2 Franchise Operators / Independent Contractors

Where provincial entities appoint franchise operators, consultants, or representatives to deliver services under the Licentia brand, such persons/entities operate as:

Independent Contractors / Independent Franchise Operators authorised to process personal information under the Licentia Group governance framework and central systems, subject to mandatory compliance directives, audit rights, and role-based system controls.

Nothing in this governance model shall be construed as creating a partnership or general agency between Licentia Head Office, provincial entities, and/or franchise operators, except to the limited extent required to execute authorised services within defined mandates and system workflows.

1.2.3 Centralised Systems Governance and Documentation Control

All provincial entities and authorised franchise operators utilise Licentia’s centralised systems, platforms, templates, and compliance frameworks, which are administered and controlled through governance oversight by Licentia Head Office.

Accordingly:

• Client documentation, application records, inspection records, compliance evidence, correspondence logs, and processing histories may be captured, stored, maintained, and audited within the Licentia Group’s central systems.
• Licentia Head Office retains system-level governance authority to:

• implement uniform processing standards;
• regulate workflow steps and approvals;
• enforce operational rules and compliance controls;
• monitor system access and data movement;
• conduct audits and investigations; and
• restrict or revoke access where risk, breach, non-compliance, or governance failure arises.

Access to client data is strictly managed through role-based permissions, audit logging, and security controls.

1.2.4 Client Payments and Financial Governance

Clients ordinarily pay service fees to the relevant provincial entity within the territory.

Licentia Head Office facilitates and governs the operational financial framework through centralised systems, which may include:

• invoicing structures and numbering rules;
• workflow verification and service tracking;
• internal audit and governance review;
• financial reporting required for franchise administration, risk management, and royalty governance (where applicable); and
• system-level controls to ensure traceability, integrity, and lawful processing of financial records.

This financial governance function is exercised to protect clients, provincial entities, franchise operators, and the Licentia Group, and to ensure consistent operational compliance across territories.

1.2.5 Governance Oversight, Compliance Integrity, and Audit Rights

Licentia’s governance model is designed to ensure:

• uniform compliance standards across provinces;
• centralised data protection oversight;
• regulated workflows and process integrity;
• consistent recordkeeping for regulated applications;
• risk mitigation and regulatory consistency; and
• lawful processing aligned with POPIA and applicable South African legislation.

Licentia Head Office retains audit and oversight rights across the Licentia network and may intervene where necessary to:

• prevent regulatory breaches;
• protect the integrity of client submissions;
• manage reputational and compliance exposure; and
• enforce the Licentia compliance framework.

1.3 Legal Department & External Counsel

MaxMind Group of Companies (Pty) Ltd
Registration Number: 2021/997887/07

("MaxMind Group")

maintains a Legal Department which provides legal oversight and legal services to Licentia Head Office, provincial entities, and other group companies as required.

1.3.1 Role and Scope of the Legal Department

The Legal Department provides:

• Internal Legal Oversight
  Including legal risk identification, legal compliance guidance, governance support, and legal review of regulated submissions, contractual frameworks, enforcement exposure, and dispute positioning.
• External Enforcement and Litigation Management
  Including the issuing and management of formal demands, breach notices, regulatory enforcement steps, dispute escalation, litigation coordination, arbitration management, and engagement with regulators, counterparties, and professional representatives where lawful and required.
• Legal Services to Licentia and Group Entities (Subject to Mandate)
  The Legal Department may provide legal services to Licentia Head Office and its provincial entities, and may also support other MaxMind Group entities, subject always to proper authority, mandate scope, internal governance protocols, and legal capacity requirements.

1.3.2 External Counsel and Specialist Appointments

Where a matter requires specialist expertise, external representation, urgent escalation, jurisdictional support, or capacity beyond internal resources, the Licentia Group (including through the Legal Department) may brief or appoint:

• external attorneys or law firms;
• advocates/senior counsel;
• compliance specialists;
• investigators;
• expert witnesses; and/or
• other professional advisors,

strictly as required to protect lawful interests, execute a mandate, comply with regulatory requirements, or pursue/enforce legal remedies.

Where a client appoints their own external legal representatives, Licentia will cooperate as reasonably required within the lawful scope of the client mandate, POPIA, confidentiality duties, and system governance controls.

1.3.3 Confidentiality, Privilege, and Lawful Processing Controls

Where personal information is processed for legal oversight, enforcement, dispute resolution, or litigation, such processing is limited to what is necessary and lawful, and is subject to strict confidentiality controls.

Accordingly:

• Legal confidentiality and professional secrecy apply to information processed within the Legal Department and to information shared with appointed external legal representatives.
• Information may be processed and shared for legal purposes, including:

• defending or enforcing rights;
• preparing and issuing legal notices;
• responding to regulatory investigations;
• preparing litigation or arbitration material;
• engaging with insurers, auditors, or regulators where lawful and required; and
• preserving evidence relevant to disputes or enforcement.

Where external counsel is engaged, the Licentia Group will apply confidentiality and processing safeguards appropriate to the nature and urgency of the matter, and will limit access to the minimum information reasonably required for lawful execution.

1.3.4 System Access and Governance Logging

The Legal Department may require access to client records, compliance files, inspection evidence, financial records, communications logs, and regulatory submissions within Licentia systems for lawful legal oversight and enforcement functions.

Where such access is granted:

• access must be role-based and permissioned;
• all access must be logged;
• exports and downloads must be recorded;
• internal handling must comply with Licentia governance standards; and
• information must be used only for lawful purposes within mandate scope.

1.3.5 No Unlawful Expansion of Mandate

Nothing in this section authorises the unlawful processing of personal information or the collection of information beyond what is necessary for:

• service delivery;
• compliance obligations;
• internal governance;
• lawful enforcement; or
• legal dispute resolution.

All processing remains subject to POPIA and applicable South African legislation.