Privacy Policy

Effective date: November 2nd, 2027

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1. Who we are

FRONESIS Sarl (“Fronesis”, “we”, “us”) is an advisory firm focused on investment in the Democratic Republic of the Congo (DRC) corridor, covering minerals, real estate and infrastructure, agribusiness and land. We operate from DR Congo and are the party responsible for your personal information (the “controller” under GDPR and the “responsible party” under DR Congo’s law).

• Registered address: [ADDRESS]

• Email: info@fronesisllc.com

• Information Officer : Jonathan M. Ilunga, Founder 

 

2. What this policy covers

This policy applies to visitors to our website, people who contact us, prospective and current clients, and the limited personal information of other people that we handle while carrying out an engagement (for example counterparties, local partners and beneficial owners). A signed engagement letter may add further terms for client work.

 

3. Information we collect

Website enquiries. Name, email address, phone number and the message you send through our contact form or by email.

Technical data. IP address, browser and device type, pages viewed and cookie identifiers. This is collected through our website platform provider, Wix.

Client and engagement information. Business, financial and investment information you share with us (company documents, financial statements, models, asset and project details); contact and role details of your team; billing details; and, where required for compliance, identity and source-of-funds documents.

Information about third parties in due diligence. When we vet a deal, asset or local partner we may handle names, ownership and director details, land or title records, and the results of sanctions, politically-exposed-person and adverse-media screening. We obtain this from public registries, from our clients, from the third party, or from commercial sources, and handle it in strict confidence and only where lawful.

We do not knowingly collect sensitive information (such as health, religion or biometric data) except where the law requires or allows it in connection with compliance screening.

 

4. Why we use your information

Purpose

Legal basis

Respond to enquiries and prepare proposals

Steps before a contract; our legitimate interest in running our business

Deliver advisory, financial and reporting services

Performance of a contract

Due diligence, anti-money-laundering, sanctions and anti-corruption checks

Legal obligation; our legitimate interest in preventing fraud and financial crime

Invoicing, bookkeeping and tax records

Legal obligation; contract

Keep the website secure and understand how it is used

Legitimate interest; consent where cookie laws require it

Send market updates or newsletters

Your consent, which you can withdraw at any time

Under POPIA we rely on the equivalent justification grounds (consent, contract, legal obligation or legitimate interest). Where the DRC Digital Code requires consent for processing, we ask for it. We do not make decisions about you using fully automated processing, and we do not sell your personal information.

 

5. Who we share it with

We share personal information only as needed and under confidentiality or contract terms:

• Service providers: website hosting and forms (Wix), email, cloud storage, accounting software and payment processors.

• Professional advisers: lawyers, notaries, auditors, surveyors, technical consultants and local counsel, where an engagement requires it.

• Transaction parties: counterparties, partners, banks or authorities, when you instruct us to share information to progress a transaction.

• Authorities: where required by law, regulation or legal process.

• Successors: in a merger, acquisition or restructuring, subject to the same protections.

 

6. International transfers

We work across several countries. Your information may be processed in South Africa, the United States, the European Union, the DRC or other countries where our providers operate. Where the law requires, we use safeguards such as contractual clauses with providers and recipients, or ensure the recipient is bound by rules that give substantially similar protection.

 

7. How long we keep it

• Enquiries that do not become engagements: up to 24 months after our last contact.

• Client engagement and financial records: 7 years after the engagement ends, or longer where the law requires.

• Marketing contact details: until you withdraw consent.

• Website technical data: according to our provider’s settings.

After these periods we delete or anonymise the information.

 

8. Security and breaches

We use access controls, encryption in transit, confidentiality commitments and need-to-know access to protect information. No system is completely secure. If a breach affects your information, we will notify the relevant regulator and affected people as the law requires.

 

9. Your rights

Depending on where you live, you may have the right to access your information, correct it, delete it, restrict or object to its use, receive a portable copy, and withdraw consent at any time. To exercise a right, email info@fronesisllc.com. We may need to verify your identity, and we aim to respond within 30 days.

If you are unhappy with how we handle your information, please contact us first. You may also complain to the relevant Information Regulator, to your local data protection authority if you are in the EU or EEA, or to the competent authority in the DRC.

 

10. Cookies

Our website uses cookies and similar technologies that are necessary for it to work and, where enabled, to measure traffic. You can accept or decline non-essential cookies through the cookie banner and can block cookies in your browser settings, though parts of the site may not work as intended.

 

11. Links to other sites

Our website may link to third-party sites. We are not responsible for their privacy practices.

 

12. Children

Our services are for businesses and investors. We do not knowingly collect information from anyone under 18.

 

13. Changes to this policy

We may update this policy and will post the new version here with a revised date.

 

14. Contact

FRONESIS SARL / FRONESIS LLC

1740 Dell Range blvd. Cheyenne Wyoming, USA 82009

Email: info@fronesisllc.com

Information Officer: Jonathan M. Ilunga