LIVE TRACTION

1. Introduction and Acceptance of Terms

These Terms and Conditions ("Terms") constitute a legally binding agreement between you ("User," "you," or "your") and Kupfuma Ventures (Pty) Ltd, a company incorporated under the laws of the Republic of South Africa and trading as "Live Traction" ("Live Traction," "we," "us," or "our"), governing your access to and use of the website, dashboards, applications, application programming interfaces, and related services made available under the name Live Traction (collectively, the "Platform" or "Services").

By creating an account, accessing, or using the Platform in any capacity — whether as a founder, an investor, a job applicant, or any other authorized user — you acknowledge that you have read, understood, and agree to be bound by these Terms, together with our Privacy Policy, which is incorporated into these Terms by reference. If you do not agree to these Terms in their entirety, you must not access or use the Platform.

If you are entering into these Terms on behalf of a company, fund, partnership, or other legal entity, you represent and warrant that you have the authority to bind that entity to these Terms, in which case "you" and "your" refer to that entity.

The Platform is intended for use by persons who have reached the age of majority in their jurisdiction of residence (and in any event no younger than 18 years old) and who have the legal capacity to enter into binding contracts.

2. Definitions

"Founder" means a User who registers a startup profile on the Platform for the purpose of sharing business, financial, and operational information with prospective investors.

"Investor" means a User who accesses a Founder's Live Traction Link or registers an investor account for the purpose of reviewing startup information made available through the Platform.

"Live Traction Link" means the unique, access-controlled URL generated by the Platform through which a Founder shares startup information with a designated Investor.

"Content" means all data, text, graphics, metrics, documents (including pitch decks and curricula vitae), messages, and other materials submitted, uploaded, generated, or transmitted through the Platform by any User.

"Connected Source" means any third-party service (including payment processors, analytics providers, and databases) that a Founder authorizes the Platform to access for the purpose of displaying business metrics.

"Personal Data" has the meaning given to it in our Privacy Policy and, where applicable, under South Africa's Protection of Personal Information Act, 2013 (POPIA), the General Data Protection Regulation (Regulation (EU) 2016/679), and other applicable data protection laws.

3. Nature of the Platform and Services

Live Traction is a data analytics and traction-sharing platform. Its purpose is (a) to help Founders aggregate, visualize, and share verifiable business metrics and company information with prospective Investors in order to facilitate introductions and meetings, and (b) to give Investors a structured, comparable, and efficient way to review, filter, and screen early-stage opportunities as part of their own independent due diligence process.

THE PLATFORM IS A SCREENING, FILTERING, AND COMMUNICATION TOOL. IT IS NOT AN INVESTMENT ADVISER, BROKER-DEALER, FUND MANAGER, PLACEMENT AGENT, OR ANY OTHER TYPE OF REGULATED FINANCIAL INTERMEDIARY IN ANY JURISDICTION. Live Traction does not solicit, recommend, endorse, underwrite, or facilitate the purchase or sale of any security, and no Content displayed on the Platform should be construed as an offer to sell or a solicitation of an offer to buy any security or investment product.

Live Traction does not participate in, negotiate, structure, or execute any investment, funding round, or transaction between Founders and Investors. Any decision by an Investor to engage with, meet, negotiate with, or invest in a Founder — and any decision by a Founder to accept capital from or engage with an Investor — is made entirely independently by the parties concerned, outside of the Platform, and at their own risk.

The Platform does not perform, and is not intended to be a substitute for, legal, tax, accounting, financial, or investment due diligence. Users are solely responsible for conducting their own independent verification and diligence before entering into any transaction or relationship formed as a result of using the Platform.

4. Eligibility and Account Registration

To use certain features of the Platform, you must register for an account and provide accurate, current, and complete information. You are responsible for maintaining the confidentiality of your login credentials and for all activity that occurs under your account.

You must notify us promptly at the contact details set out in Section 33 if you become aware of any unauthorized use of your account or any other breach of security.

We reserve the right to refuse registration, suspend, or terminate any account at our sole discretion where we reasonably believe these Terms have been violated, where required by applicable law, or where we are unable to verify the information provided.

5. Founder Accounts and Obligations

As a Founder, you are solely responsible for the accuracy, completeness, and legality of all Content you submit to the Platform, including but not limited to company descriptions, team information, pitch decks, curricula vitae processed through the job board, fundraising status, valuation, round size, and any metrics displayed on your dashboard.

Where you connect a Connected Source (such as a payment processor, analytics tool, or database) to display live metrics, you represent and warrant that you have all necessary rights, consents, and authority to authorize the Platform to access and display that data, and that the data displayed accurately reflects your underlying systems.

Live Traction does not independently verify, audit, or guarantee the accuracy of any metric, statement, or document that a Founder chooses to display on their live link, dashboard, or profile. The label "live" refers to the technical synchronization between a Connected Source and the Platform's display layer, and does not constitute a representation by Live Traction as to the accuracy, completeness, or reliability of the underlying data.

Founders are solely responsible for determining what information is appropriate to share with a given Investor and for selecting the appropriate access tier (including duration and scope of access) for each Live Traction Link they generate.

Founders acknowledge that features permitting the scheduling of meetings and the sharing of third-party video conferencing links (such as Google Meet or Zoom) are provided for convenience only; Live Traction is not a party to, and assumes no responsibility for, any meeting conducted using such links.

6. Investor Accounts and Obligations

As an Investor, you may access Founder information either through a Live Traction Link shared directly with you or, where you register an investor account, through a portfolio-style dashboard that aggregates the startups you have been granted access to.

You agree to use any information accessed through the Platform solely for your own internal evaluation purposes and not to redistribute, resell, or make available to third parties any non-public Founder information without the Founder's express consent, except to your own advisers, employees, or partners who are bound by equivalent confidentiality obligations and who need the information for the purpose of evaluating the opportunity.

You represent that any indication of interest, request for a meeting, or other action you take through the Platform reflects your own independent judgment and, where applicable, complies with your internal investment policies and any regulatory obligations applicable to you (including, where relevant, obligations relating to your status as an accredited, sophisticated, professional, or qualified investor under the laws applicable to you).

You acknowledge that Live Traction does not screen, qualify, or verify the investment sophistication, accreditation status, or regulatory status of any Investor, and that Founders remain solely responsible for satisfying themselves as to the suitability of any Investor before sharing information or entering into any transaction.

7. No Investment Advice; No Recommendation; No Fiduciary Duty

NOTHING ON THE PLATFORM CONSTITUTES, AND SHOULD NOT BE INTERPRETED AS, INVESTMENT ADVICE, A RECOMMENDATION TO INVEST IN OR ENGAGE WITH ANY PARTICULAR FOUNDER OR STARTUP, OR AN ASSESSMENT OF THE MERITS, RISKS, OR SUITABILITY OF ANY INVESTMENT OPPORTUNITY.

Any ranking, filtering, sorting, badge, metric summary, or comparative display generated by the Platform is a functional, data-organization feature intended to help Investors manage information more efficiently. It is not, and must not be relied upon as, a rating, score, endorsement, or opinion by Live Traction as to the quality, viability, or investment potential of any Founder or startup.

Live Traction does not act as agent, broker, fiduciary, or intermediary for either Founders or Investors, and no fiduciary, advisory, or agency relationship is created between Live Traction and any User by virtue of using the Platform.

You should seek independent financial, legal, tax, and professional advice before making any investment decision or entering into any agreement with a party you encounter through the Platform. Past traction, growth, or metrics displayed on the Platform are not indicative of future performance, and early-stage investments carry a high degree of risk, including the potential loss of the entire amount invested.

8. Data Accuracy and Founder Representations

While the Platform is designed to display metrics sourced directly from Connected Sources in order to reduce the risk of manual manipulation, Live Traction makes no representation or warranty, express or implied, as to the accuracy, completeness, timeliness, or reliability of any Content, including data pulled from Connected Sources, which may be affected by integration errors, synchronization delays, third-party outages, or inaccurate underlying source data.

Founders who misrepresent their metrics, connect falsified or manipulated data sources, or otherwise provide materially misleading information do so in breach of these Terms and may be liable to affected Investors and third parties independently of any liability of Live Traction, which liability Live Traction expressly disclaims to the fullest extent permitted by applicable law.

9. Subscription Fees, Billing, and Refunds

Founder access to paid features of the Platform is offered on a subscription basis at the pricing displayed on the Platform at the time of purchase, currently structured as a monthly or annual subscription per startup, with fees charged in advance and payment processed through our third-party payment processor.

Subscriptions renew automatically at the end of each billing cycle unless cancelled prior to the renewal date through the account settings or by contacting us. You authorize us (and our payment processor) to charge your designated payment method for all applicable fees.

Refund Policy. Kupfuma Ventures (Pty) Ltd, trading as "Live Traction," is committed to providing excellent service and ensuring customer satisfaction.

Customers may request a full refund within 14 days of the original payment date, with no exceptions or conditions.

Refunds will be processed using the original payment method where possible.

If you wish to request a refund, please contact our support team within the 14-day refund period, providing your account details and proof of purchase. We will review your request promptly and keep you informed throughout the refund process.

Refunds will be processed using the original payment method where possible. We reserve the right to decline refund requests where services have been fully delivered, the Platform has been misused, or where fraud or abuse is suspected.

For all refund requests, please contact our support team with your account details and the reason for your request. We will review each request promptly and keep you informed throughout the process.

We reserve the right to change our pricing on prospective notice; continued use of the Platform after a pricing change takes effect constitutes acceptance of the new pricing.

You are responsible for any taxes, duties, or similar governmental assessments associated with your use of the Platform, other than taxes based on Live Traction's net income.

10. Free Trial

Where a free trial period is offered, it will convert automatically to a paid subscription at the end of the trial unless cancelled before the trial expires. We reserve the right to modify, limit, or discontinue free trial offers at any time and to determine eligibility for a free trial at our discretion, including limiting free trials to one per Founder or startup.

11. Third-Party Integrations and Services

The Platform enables integration with third-party services, including payment processors, web and product analytics tools, databases, video conferencing providers, and email services. Your use of any such third-party service is governed by that provider's own terms of service and privacy policy, and Live Traction is not responsible for the acts, omissions, availability, or security practices of any third-party service.

You are solely responsible for ensuring that you have the necessary rights and consents to connect any third-party service or data source to the Platform, and for complying with that provider's terms in doing so.

12. Meeting Scheduling Features

The Platform may allow Investors to request meetings with Founders and allow Founders to confirm such requests and attach a third-party video conferencing link. These features are provided as a convenience for coordinating communication between Users. Live Traction is not responsible for the scheduling, conduct, content, recording, or outcome of any meeting arranged through the Platform, and assumes no liability arising from any such meeting.

13. Job Board Features

The Platform permits Founders to post job or co-founder listings and permits applicants to submit applications, including personal contact information and curricula vitae. Founders are solely responsible for their recruitment practices and compliance with applicable employment and anti-discrimination laws in the jurisdictions in which they hire. Live Traction acts solely as a technical conduit for the submission of applications and does not verify, endorse, or take responsibility for any job listing, applicant, or hiring decision.

14. Intellectual Property Rights

The Platform, including its software, design, text, graphics, logos, and underlying technology (excluding User Content), is owned by Live Traction or its licensors and is protected by copyright, trademark, and other intellectual property laws worldwide. Except as expressly permitted by these Terms, you may not copy, modify, distribute, sell, or lease any part of the Platform, nor reverse engineer or attempt to extract the source code of the underlying software.

"Live Traction" and associated logos are trademarks of Kupfuma Ventures (Pty) Ltd, trading as Live Traction. Nothing in these Terms grants you any right to use our trademarks without our prior written consent.

15. User Content License

You retain all ownership rights in the Content you submit to the Platform. By submitting Content, you grant Live Traction a worldwide, non-exclusive, royalty-free, sublicensable license to host, store, reproduce, display, transmit, and otherwise process that Content solely for the purpose of operating, maintaining, and improving the Platform and providing the Services to you and to the Users you authorize to receive it.

This license terminates when you delete the relevant Content or close your account, except to the extent that Content has been shared with another User in accordance with your instructions (for example, via a Live Traction Link), or where retention is required for legal, regulatory, security, or backup purposes as described in our Privacy Policy.

16. Acceptable Use Policy

You agree not to: (a) use the Platform for any unlawful purpose or in violation of any applicable law, including securities, anti-fraud, anti-bribery, export control, and sanctions laws; (b) misrepresent your identity, affiliation, or the accuracy of any Content; (c) upload malicious code or attempt to gain unauthorized access to the Platform or other Users' accounts or data; (d) scrape, harvest, or use automated means to extract data from the Platform without our prior written consent; (e) use the Platform to send unsolicited communications or spam; (f) impersonate any person or entity; or (g) interfere with or disrupt the integrity or performance of the Platform.

We reserve the right to investigate and take appropriate action against any User who violates this Acceptable Use Policy, including removing Content, suspending or terminating accounts, and reporting conduct to law enforcement or regulatory authorities where appropriate.

17. Suspension and Termination

We may suspend or terminate your access to the Platform, with or without notice, if we reasonably believe you have breached these Terms, engaged in fraudulent or harmful conduct, or where required to do so by law. You may terminate your account at any time through your account settings or by contacting us.

Upon termination, your right to access the Platform ceases immediately. Provisions of these Terms which by their nature should survive termination — including Sections 7, 8, 14, 15 (to the extent Content has already been lawfully shared), 18, 19, 20, 24, and 25 — shall survive.

18. Disclaimers of Warranties

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE PLATFORM AND ALL CONTENT AND SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, ACCURACY, OR THAT THE PLATFORM WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE.

LIVE TRACTION DOES NOT WARRANT THE ACCURACY OR RELIABILITY OF ANY CONTENT, METRIC, OR INFORMATION OBTAINED THROUGH THE PLATFORM, WHETHER SUPPLIED BY A USER OR SOURCED FROM A CONNECTED SOURCE, AND DISCLAIMS ANY RESPONSIBILITY FOR DECISIONS MADE IN RELIANCE ON SUCH INFORMATION.

19. Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL LIVE TRACTION, ITS OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, REVENUE, DATA, GOODWILL, OR BUSINESS OPPORTUNITY, ARISING OUT OF OR RELATED TO YOUR USE OF THE PLATFORM, ANY TRANSACTION OR RELATIONSHIP FORMED AS A RESULT OF USING THE PLATFORM, OR THESE TERMS, WHETHER BASED ON CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE, EVEN IF LIVE TRACTION HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

LIVE TRACTION'S TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATED TO THESE TERMS OR THE PLATFORM SHALL NOT EXCEED THE GREATER OF (A) THE TOTAL FEES PAID BY YOU TO LIVE TRACTION IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED UNITED STATES DOLLARS (USD 100).

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES OR WARRANTIES; IN SUCH JURISDICTIONS, OUR LIABILITY IS LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW.

20. Indemnification

You agree to indemnify, defend, and hold harmless Live Traction and its officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, and expenses, including reasonable legal fees, arising out of or in any way connected with: (a) your access to or use of the Platform; (b) your Content, including any inaccuracy or misrepresentation therein; (c) your violation of these Terms; or (d) your violation of any applicable law or the rights of any third party, including any securities, employment, or data protection law.

21. Confidentiality

Each User agrees to treat non-public information received from another User through the Platform as confidential and to use it solely for the purpose of evaluating a potential business relationship, unless the disclosing User consents otherwise or disclosure is required by law. This obligation does not apply to information that is or becomes publicly available through no fault of the receiving User, was already known to the receiving User without an obligation of confidentiality, or is independently developed without use of the confidential information.

22. Export Control and Sanctions Compliance

You represent that you are not located in, organized under the laws of, or ordinarily resident in any country or territory subject to comprehensive sanctions administered by the United Nations, the European Union, the United Kingdom, the United States, or South Africa, and that you are not identified on any restricted party or denied persons list maintained by such authorities. You agree to comply with all applicable export control and economic sanctions laws in your use of the Platform.

23. Anti-Money Laundering and Know-Your-Customer Acknowledgment

Live Traction is a data and communications platform and does not hold, transmit, or manage client funds or securities and is not a reporting entity for anti-money laundering purposes in the ordinary course of its operations. Nonetheless, we reserve the right to request identity verification information from any User and to suspend or terminate accounts where we reasonably suspect fraudulent, illegal, or sanctioned activity, and to cooperate with competent authorities as required by applicable law.

24. Dispute Resolution and Arbitration

The parties shall first attempt to resolve any dispute arising out of or relating to these Terms through good-faith negotiation. If a dispute is not resolved within thirty (30) days of written notice, it shall be referred to and finally resolved by arbitration administered by the Arbitration Foundation of Southern Africa (AFSA) in accordance with its rules, pursuant to the South African International Arbitration Act 15 of 2017.

The seat of arbitration shall be Johannesburg, South Africa, the language of the arbitration shall be English, and the tribunal shall consist of one (1) arbitrator unless the parties agree otherwise. Judgment on the award rendered may be entered in any court having jurisdiction. Nothing in this Section prevents either party from seeking interim or injunctive relief from a court of competent jurisdiction to protect its intellectual property or confidential information.

Where mandatory consumer protection law in your jurisdiction of residence grants you the right to bring proceedings in your local courts or otherwise limits the enforceability of this arbitration provision, this Section shall apply only to the extent permitted by that law.

25. Governing Law and Jurisdiction

These Terms and any dispute or claim arising out of or in connection with them (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of the Republic of South Africa, without regard to its conflict of laws principles, save to the extent that mandatory laws of your country of residence apply notwithstanding this choice of law.

Subject to Section 24, the courts of the Republic of South Africa shall have exclusive jurisdiction to settle any dispute arising out of or in connection with these Terms that is not subject to arbitration.

26. International Use and Local Law Compliance

The Platform is designed to be accessible to Founders and Investors globally. We make no representation that the Platform, or any Content displayed on it, is appropriate, lawful, or available in every country. If you access the Platform from outside South Africa, you do so on your own initiative and are responsible for compliance with local laws, including securities laws, data protection laws, and any restrictions on cross-border data transfer or investment solicitation applicable in your jurisdiction.

In particular, Founders and Investors are solely responsible for ensuring that any offer, solicitation, or sharing of financial information complies with the securities laws of every jurisdiction in which they operate or from which they access the Platform, including any applicable prohibitions on general solicitation or advertising of securities offerings.

27. Force Majeure

Live Traction shall not be liable for any failure or delay in performance resulting from causes beyond its reasonable control, including acts of God, natural disasters, war, terrorism, civil unrest, labor disputes, internet or telecommunications failures, cyberattacks, governmental action, or failures of third-party service providers.

28. Changes to the Terms

We may modify these Terms from time to time. Where changes are material, we will provide notice by posting the updated Terms on the Platform and updating the "Last Updated" date, and, where required by law, through additional notice such as email. Your continued use of the Platform after the effective date of any change constitutes your acceptance of the revised Terms. If you do not agree to the revised Terms, you must stop using the Platform.

29. Assignment

You may not assign or transfer these Terms or any rights or obligations under them without our prior written consent. We may assign these Terms without restriction, including in connection with a merger, acquisition, corporate reorganization, or sale of assets.

30. Severability

If any provision of these Terms is found to be invalid or unenforceable by a court or tribunal of competent jurisdiction, that provision shall be limited or eliminated to the minimum extent necessary, and the remaining provisions of these Terms shall remain in full force and effect.

31. Entire Agreement; Waiver

These Terms, together with the Privacy Policy and any other policies referenced herein, constitute the entire agreement between you and Live Traction regarding the Platform and supersede any prior agreements. No waiver of any provision of these Terms shall be effective unless in writing, and no failure to enforce any provision shall constitute a waiver of that provision or any other.

32. Notices

We may provide notices to you by email, through the Platform, or by posting on the Platform. Notices to Live Traction should be sent to the contact details set out in Section 33.

33. Contact Information

Kupfuma Ventures (Pty) Ltd, trading as Live Traction
Registered in the Republic of South Africa
Email: startups@livetraction.vc
For data protection inquiries, please see the "Contact and Data Protection Officer" section of our Privacy Policy.

1. Introduction and Scope

This Privacy Policy explains how Kupfuma Ventures (Pty) Ltd, incorporated in the Republic of South Africa and trading as "Live Traction" ("Live Traction," "we," "us," or "our"), collects, uses, discloses, and protects Personal Data in connection with the Live Traction platform (the "Platform").

This Privacy Policy applies to all Users of the Platform worldwide, including Founders, Investors, job applicants, and visitors to our website, regardless of where they are located. Because our Users and their data may be located in numerous jurisdictions, this Policy is drafted to address the requirements of multiple data protection frameworks, including without limitation South Africa's Protection of Personal Information Act, 2013 (POPIA), the EU General Data Protection Regulation (GDPR), the UK GDPR and Data Protection Act 2018, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and comparable data protection laws in other jurisdictions. Where a specific jurisdiction's law grants rights beyond those described in the general sections of this Policy, the jurisdiction-specific provisions in Section 20 apply in addition.

2. Data Controller

For the purposes of applicable data protection law, Kupfuma Ventures (Pty) Ltd, trading as Live Traction, is the data controller (or equivalent term, such as "business" under the CCPA) responsible for Personal Data processed through the Platform, except where a Founder or Investor acts as controller of Personal Data they choose to submit about a third party (for example, an Investor's contact details entered by a Founder, or a founder's team member details), in which case that User is the controller and Live Traction acts as processor on their behalf, subject to a data processing agreement available on request.

3. Categories of Personal Data We Collect

Account and profile data: name, email address, phone number, password (stored in hashed form), role (founder, investor, admin), company or fund name, and job title.

Founder business data: company metrics synced from Connected Sources (such as payment and analytics platforms), company story and description, team member details, fundraising status and target, pitch decks, job postings, and related business information you choose to submit.

Investor data: firm or fund name, tracked startups, meeting requests, stage/status preferences, and communications with Founders through the Platform.

Job applicant data: full name, email address, phone number, curriculum vitae or resume, and any information contained within an application note.

Payment data: billing name, billing address, and payment method details, which are collected and processed directly by our third-party payment processor; we do not store full payment card numbers on our own systems.

Usage and device data: IP address, browser type, device identifiers, pages viewed, access times, referring URLs, and similar technical data collected automatically through cookies and similar technologies as described in Section 13.

Communications data: the content of messages, meeting requests, and support inquiries you send through or in connection with the Platform.

4. Sources of Personal Data

We collect Personal Data: (a) directly from you when you register, complete your profile, or otherwise interact with the Platform; (b) automatically through your use of the Platform, via cookies and similar technologies; (c) from Connected Sources that a Founder authorizes us to access; and (d) from other Users who submit information about you (for example, a Founder who shares your details as an intended Investor recipient, or an employer who lists you as a team member).

5. Legal Bases for Processing

Where the GDPR, UK GDPR, or an equivalent legal framework applies, we rely on the following legal bases to process Personal Data: (a) performance of a contract, where processing is necessary to provide the Platform and Services you have requested; (b) legitimate interests, where processing is necessary for our legitimate interests in operating, securing, and improving the Platform, provided those interests are not overridden by your rights; (c) consent, where we rely on your consent, such as for certain cookies or marketing communications, which you may withdraw at any time; and (d) legal obligation, where processing is necessary to comply with applicable law.

6. How We Use Personal Data

We use Personal Data to: provide, operate, and maintain the Platform; create and manage accounts; generate and manage Live Traction Links and control access permissions; synchronize and display metrics from Connected Sources; facilitate meeting requests and confirmations; process job applications; process payments and manage subscriptions; provide customer support; send transactional and, where consented to, marketing communications; monitor, analyze, and improve the performance, security, and functionality of the Platform; detect, prevent, and address fraud, abuse, and security incidents; and comply with our legal and regulatory obligations.

7. Data Sharing and Disclosure

With other Users, as directed by you: for example, a Founder's business data is shared with an Investor to whom they issue a Live Traction Link, and a job applicant's data is shared with the Founder to whose listing they apply.

With service providers: we engage third-party service providers to perform functions on our behalf, including hosting and infrastructure providers, payment processors, analytics providers, email delivery services, and customer support tools. These providers are contractually bound to process Personal Data only on our instructions and to apply appropriate security measures.

For legal reasons: we may disclose Personal Data where required to comply with applicable law, regulation, legal process, or governmental request, or where necessary to protect the rights, property, or safety of Live Traction, our Users, or the public.

In connection with a business transaction: Personal Data may be disclosed or transferred in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, subject to appropriate confidentiality safeguards.

We do not sell Personal Data to third parties for monetary consideration. To the extent certain sharing described above could be considered a "sale" or "sharing" under the CCPA/CPRA, see Section 20(c) for your applicable rights.

8. International Data Transfers

As a global platform, Personal Data we collect may be transferred to, stored, and processed in countries other than the country in which it was originally collected, including South Africa and countries in which our hosting and service providers operate.

Where we transfer Personal Data originating from the European Economic Area, the United Kingdom, or Switzerland to a country that has not been recognized as providing an adequate level of data protection, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses (or the UK International Data Transfer Addendum), and, where applicable, South Africa's status as a jurisdiction with a data protection framework substantially aligned with international standards under POPIA. Copies of relevant safeguards are available upon request to our Data Protection Officer.

9. Data Retention

We retain Personal Data for as long as necessary to provide the Platform and fulfill the purposes described in this Policy, including to comply with our legal, accounting, and regulatory obligations, resolve disputes, and enforce our agreements. Retention periods vary by data category; for example, account data is generally retained for the duration of the account plus a limited period thereafter for legal and audit purposes, while data displayed through an expired or revoked Live Traction Link ceases to be accessible to the relevant Investor immediately upon expiry or revocation, subject to backup retention.

Where you request deletion of your Personal Data, we will delete or anonymize it within a reasonable period, except where retention is required by law or necessary for the establishment, exercise, or defense of legal claims.

10. Data Security

We implement technical and organizational measures designed to protect Personal Data against unauthorized access, alteration, disclosure, or destruction, including encryption in transit, access controls, and regular security reviews. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

11. Your Data Protection Rights

Subject to applicable law and to the limitations set out therein, you may have the right to: (a) access the Personal Data we hold about you; (b) request correction of inaccurate or incomplete data; (c) request erasure of your data; (d) request restriction of, or object to, certain processing, including processing based on legitimate interests and direct marketing; (e) request portability of data you have provided to us in a structured, commonly used, machine-readable format; (f) withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal; and (g) lodge a complaint with your local data protection supervisory authority.

To exercise any of these rights, please contact us using the details in Section 18. We may need to verify your identity before responding, and we will respond within the timeframe required by applicable law.

12. Cookies and Similar Technologies

We use cookies and similar technologies (such as local storage and pixels) to operate the Platform, remember your preferences, understand how the Platform is used, and, where you consent, for analytics and marketing purposes. You can control cookies through your browser settings and, where required by law, through a cookie consent banner presented on your first visit. Disabling certain cookies may affect the functionality of the Platform.

13. Children's Privacy

The Platform is not directed to, and we do not knowingly collect Personal Data from, individuals under the age of 18. If we become aware that we have collected Personal Data from a person under 18 without appropriate consent, we will take steps to delete that data.

14. Automated Decision-Making and Profiling

We do not use Personal Data to make decisions producing legal or similarly significant effects about Users through solely automated means without human involvement. Sorting, filtering, and comparison features on the Platform are provided as functional tools to help Users organize information; they do not constitute automated decision-making that determines investment outcomes, and no automated system on the Platform approves, denies, or recommends any investment or funding decision.

15. Third-Party Links and Services

The Platform may contain links to or integrations with third-party websites and services (including payment processors, analytics tools, and video conferencing providers). This Policy does not apply to those third-party services, and we encourage you to review their respective privacy policies.

16. Data Breach Notification

In the event of a Personal Data breach that poses a risk to your rights and freedoms, we will notify the competent supervisory authority and affected individuals without undue delay, in accordance with the timeframes and thresholds required by applicable law, including South Africa's POPIA and, where applicable, the GDPR.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. Material changes will be notified through the Platform or by email, and the "Last Updated" date will be revised accordingly. Your continued use of the Platform after the effective date of any update constitutes your acknowledgment of the revised Policy.

18. Contact and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

Kupfuma Ventures (Pty) Ltd, trading as Live Traction — Data Protection Officer
Email: startups@livetraction.vc
EU/UK Representative (if applicable): [Insert Article 27 GDPR representative details, if the volume or nature of EU/UK processing requires one].

19. Supervisory Authorities

In South Africa, you may lodge a complaint with the Information Regulator (South Africa), which serves as South Africa's data protection supervisory authority under POPIA. If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with its own data protection authority, you may lodge a complaint with your local supervisory authority in addition to, or instead of, contacting us directly.

20. Jurisdiction-Specific Provisions

(a) European Economic Area and United Kingdom. Where the GDPR or UK GDPR applies to our processing of your Personal Data, the legal bases described in Section 5, the international transfer safeguards described in Section 8, and the rights described in Section 11 apply to you in full, including the right to lodge a complaint with your competent supervisory authority.

(b) South Africa. As a data controller registered and operating in South Africa, we process Personal Data in accordance with the Protection of Personal Information Act, 2013 (POPIA). Data subjects in South Africa have the rights described in Section 11 (which correspond closely to the POPIA conditions for lawful processing) and may lodge complaints with the Information Regulator (South Africa).

(c) California and other U.S. States. If you are a California resident, the CCPA as amended by the CPRA grants you the right to know what Personal Data we collect, use, disclose, and (where applicable) "sell" or "share"; the right to delete Personal Data we hold about you, subject to certain exceptions; the right to correct inaccurate Personal Data; the right to opt out of the sale or sharing of Personal Data and of certain targeted advertising; the right to limit the use of sensitive Personal Data; and the right to non-discrimination for exercising your rights. We do not sell Personal Data for monetary consideration. To the extent our use of analytics or advertising cookies constitutes "sharing" under the CPRA, you may opt out through your cookie preferences or by contacting us. Residents of other U.S. states with comparable privacy laws (including but not limited to Virginia, Colorado, Connecticut, and Utah) may exercise equivalent rights available under those laws by contacting us using the details in Section 18.

(d) Other Jurisdictions. Where you are located in a jurisdiction with a data protection framework not specifically addressed above (including, for example, Canada's PIPEDA, Brazil's LGPD, Kenya's Data Protection Act 2019, or Nigeria's NDPA), we will honor rights equivalent to those described in Section 11 to the extent required by the applicable law of that jurisdiction, and you may contact us using the details in Section 18 to exercise those rights.