Privacy Policy
How Namayani Group collects, uses, and protects personal information.
Last updated: 29 September 2026
Namayani Group (Pty) Ltd and its group companies (“Namayani”, “we”, “us”, “our”) respect your privacy. This Policy explains how we handle personal information when you visit namayani.com, contact us, or do business with any Namayani company.
We work with partners, governments, and offtakers across South Africa, Zambia, the Democratic Republic of the Congo, and India. We handle personal information in line with the laws of the countries where we operate, including:
- South Africa: the Protection of Personal Information Act 4 of 2013 (POPIA)
- Zambia: the Data Protection Act No. 3 of 2021
- DRC: the data-protection provisions of the Digital Code (Ordinance-Law No. 23/010 of 13 March 2023)
- India: the Digital Personal Data Protection Act, 2023
Where the EU General Data Protection Regulation (GDPR) applies to you, we also follow its principles.
1. Who we are
This Policy covers the following Namayani companies:
- Namayani Group (Pty) Ltd, the parent company, registered in South Africa
- Namayani Refinery
- Namayani Construction
- Namayani Michello Produce Ltd
Namayani Group (Pty) Ltd is the responsible party for this website. The group company you deal with is responsible for the information it collects about you.
Head office: Bryanston, Johannesburg, South Africa
Information Officer: privacy@namayani.com
2. Information we collect
Information you give us
- Identity and contact details: name, job title, employer, email, phone and WhatsApp numbers, and postal address.
- Enquiries and correspondence: messages sent through our contact and haulage-quote forms, by email, by WhatsApp, or by phone.
- Commercial information: quotes, orders, contracts, invoices, delivery and payment details.
- Logistics information: consignor and consignee details, driver and vehicle details, cargo documents, and customs and border-crossing records.
- Due-diligence and compliance information: for gold refining, commodity trading, and other regulated transactions:
- identity and company registration documents
- directors and beneficial owners
- licences and permits, including mining and trading licences
- source-of-origin and chain-of-custody records
- bank details
- results of sanctions, politically exposed person (PEP), and adverse-media screening
- Recruitment information: CVs and supporting documents, if you apply to work with us.
Information we collect automatically
When you use namayani.com, we and our service providers collect technical information through cookies and similar technologies, including:
- IP address and approximate location
- device and browser type
- pages visited and time spent
- the site you came from
See section 9.
Information from third parties
We may receive information about you from:
- your employer or the business you represent
- public registers, such as company, licensing, and mining registers
- sanctions and PEP screening services
- banks, logistics partners, and customs agents
- referees you give us
3. Why we use it
We use personal information to:
- respond to enquiries and prepare quotes and proposals
- enter into and perform contracts, including supply, refining, trading, construction, haulage, and equipment contracts
- carry out know-your-customer (KYC), anti-money-laundering (AML), and sanctions checks, and responsible-sourcing due diligence in line with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals
- meet legal, tax, customs, licensing, and regulatory obligations in each country where we operate
- manage cargo movements, border clearances, and delivery
- protect our business, staff, sites, and cargo, and prevent fraud and illicit trade
- run, secure, and improve our website and services
- send you news about Namayani, only where you have agreed to receive it or where the law allows it; you can opt out at any time
- assess job applications
We do not make decisions about you based solely on automated processing.
4. Lawful basis
We process personal information only where the law allows it. That means one of the following:
- you have consented
- the processing is needed to conclude or perform a contract with you
- the law requires it
- it protects a legitimate interest of yours, ours, or a third party’s, and that interest is not overridden by your rights
Where we process special personal information, we do so only where the law permits. This includes information about alleged criminal behaviour that comes up in sanctions or AML screening.
5. Who we share it with
We do not sell personal information. We share it only where needed, with:
- other Namayani group companies
- service providers acting on our instructions, such as website hosting, email, cloud storage, analytics, IT support, and screening services
- logistics partners, clearing and forwarding agents, and customs authorities
- banks, insurers, assayers, auditors, and professional advisers
- regulators, courts, and law-enforcement authorities, where the law requires it
- a buyer or investor, as part of a proposed sale, merger, or restructuring, under confidentiality
We require our service providers to keep personal information confidential and secure.
6. International transfers
We operate across several countries, and some of our service providers are based abroad. Your information may therefore be transferred to or stored in other countries, including:
- South Africa, Zambia, the DRC, and India
- countries where our cloud providers host data
When we transfer information across borders, we do so only where one of the following applies:
- the receiving country or party gives adequate protection
- a binding agreement protects the information
- you have consented
- the transfer is needed to perform a contract with you
- the law otherwise permits it, as required by POPIA and the other laws listed above
7. How long we keep it
We keep personal information only as long as we need it for the purposes above, or as the law requires. As a guide:
| Type of record | How long we keep it |
|---|---|
| Contracts, invoices, and accounting records | 7 years after the transaction |
| KYC, AML, and due-diligence records | At least 5 years after the business relationship ends, or longer where the law or a regulator requires it |
| Enquiries that do not lead to business | Up to 2 years |
| Unsuccessful job applications | Up to 12 months, unless you ask us to keep them longer |
After that, we securely delete or anonymise the information.
8. How we protect it
We use reasonable technical and organisational measures to protect personal information against loss, misuse, and unauthorised access or disclosure. These include:
- access controls
- encrypted connections to our website
- secure hosting and email providers
- confidentiality obligations for staff and contractors
If a security compromise affects your personal information, we will notify you and the relevant regulator as the law requires.
9. Cookies and analytics
namayani.com uses:
- essential cookies, to make the site work
- analytics and advertising technologies, including Google Analytics and Google Ads measurement, to understand how visitors use the site and to measure our campaigns
These providers may set cookies and receive technical information about your visit.
You can block or delete cookies in your browser settings. You can also opt out of Google Analytics with Google’s browser add-on, and manage ad personalisation in your Google account. Blocking cookies may affect how the site works.
10. Your rights
Subject to the law that applies to you, you may:
- ask whether we hold personal information about you, and request a copy
- ask us to correct, update, or delete it
- object to processing, including direct marketing, at any time
- withdraw consent, where we rely on consent
- complain to a data-protection regulator
To exercise these rights, email privacy@namayani.com. We may need to verify your identity first. We will respond within the time the law requires.
In South Africa, you can lodge a complaint with the Information Regulator ( inforegulator.org.za). In Zambia, you can complain to the Office of the Data Protection Commissioner. We would appreciate the chance to address your concern first.
11. Children
Our website and services are intended for businesses and adults. We do not knowingly collect personal information from children.
12. Links to other sites
Our site may link to other websites, such as social media or partner sites. We are not responsible for their privacy practices. Please read their policies.
13. Changes to this Policy
We may update this Policy from time to time. The date at the top of this page shows the latest version. Where changes are significant, we will take reasonable steps to let you know.
14. Contact us
Information Officer, Namayani Group (Pty) Ltd
Bryanston, Johannesburg, South Africa
For general enquiries, email info@namayani.com.