Effective Date: 5 September 2026
Last Updated: 5 September 2026

1. Introduction

SwitzView Wealth Management (Private) Limited (“SwitzView”, “we”, “us” or “our”) is committed to protecting the privacy, confidentiality and security of personal information entrusted to us.

This Privacy Policy and Data Protection Notice explains how we collect, use, process, store, disclose and protect personal information when you:

• visit or use our website, www.switzview.com;

• contact or communicate with us;

• submit an enquiry;

• become or seek to become a client, investor, counterparty or business partner;

• apply for employment with us;

• engage with our investment management, advisory or capital solutions activities; or

• otherwise interact with SwitzView.

We process personal information in accordance with the laws of the Republic of Zimbabwe, including the Cyber and Data Protection Act [Chapter 12:07], applicable regulations and requirements of the Data Protection Authority, and other legal and regulatory requirements applicable to our business.

SwitzView acts as a data controller where we determine the purposes and means for which personal information is processed.

2. Who We Are

SwitzView Wealth Management (Private) Limited is a Zimbabwean financial-services company providing investment management, advisory and capital solutions.

Our contact details are:

SwitzView Wealth Management (Private) Limited
7 Kings Row, North Gate
Borrowdale, Harare
Zimbabwe

Telephone: +263 242 883 660 / 883 661
Email: switzview@switzview.com
Website: www.switzview.com

SwitzView is licensed by the Securities and Exchange Commission of Zimbabwe as an Investment Manager and as an Investment Advisor.

3. Personal Information We May Collect

The personal information we collect depends on how you interact with SwitzView and the nature of the relationship, service, transaction or enquiry involved.

We may collect the following categories of information:

3.1 Website and Enquiry Information

When you visit our website or submit an enquiry, we may collect:

• your name;

• telephone number;

• email address;

• organisation or company details;

• subject of your enquiry;

• messages or other information submitted through our website;

• correspondence with SwitzView;

• IP address;

• browser and device information;

• referral information; and

• information about how our website is accessed and used.

3.2 Client and Investor Information

Where you engage or propose to engage SwitzView for investment management or related services, we may collect information including:

• identification information;

• national identity or passport information;

• date of birth;

• contact details;

• residential or business address;

• banking information;

• financial information;

• investment objectives;

• investment preferences;

• risk profile;

• investment horizon;

• liquidity requirements;

• source-of-funds information;

• source-of-wealth information;

• tax information;

• transaction information;

• regulatory information;

• beneficial ownership information; and

• information required for client onboarding, due diligence, account administration or regulatory compliance.

3.3 Advisory, Capital Solutions and Transaction Information

Where SwitzView provides advisory, capital raising, transaction structuring or related services, we may collect information concerning:

• businesses and project sponsors;

• directors;

• shareholders;

• beneficial owners;

• authorised representatives;

• employees;

• advisers;

• counterparties;

• investors;

• financial performance;

• funding requirements;

• business operations;

• ownership structures;

• proposed transactions;

• banking arrangements;

• security arrangements;

• source and application of funds;

• investment proposals; and

• other information reasonably required to assess, structure, execute or monitor a proposed transaction or engagement.

3.4 Recruitment Information

Where you apply for employment with SwitzView, we may collect:

• your curriculum vitae;

• contact information;

• employment history;

• educational qualifications;

• professional qualifications;

• skills and experience;

• references;

• application correspondence;

• interview information;

• identification information where appropriate; and

• other information you provide or that is reasonably required for the recruitment and selection process.

3.5 Information About Other Persons

You may sometimes provide personal information relating to another person, for example a director, shareholder, beneficial owner, authorised representative, employee, adviser, referee or transaction participant.

Where you provide such information, you should ensure that you are authorised or otherwise legally permitted to provide it to us.

4. Sensitive Personal Information

Certain categories of personal information may be regarded as sensitive or may require additional protection under applicable law.

Where SwitzView needs to process sensitive personal information, we will do so only where permitted by law and, where required, with appropriate consent or another lawful basis.

We will not intentionally request or process sensitive personal information that is unnecessary for the relevant investment, advisory, compliance, recruitment, employment or business purpose.

5. How We Collect Personal Information

We may collect personal information directly from you when you:

• submit an enquiry through our website;

• communicate with us by email, telephone or other communication channels;

• complete an application, onboarding or due-diligence process;

• provide identification or supporting documents;

• enter into an agreement with us;

• invest through or engage SwitzView;

• participate in a proposed or completed transaction;

• attend meetings with us;

• apply for employment; or

• otherwise engage with SwitzView.

Where permitted by law and relevant to a legitimate business or regulatory purpose, we may also obtain information from third parties or other sources, including:

• authorised representatives;

• employers;

• financial institutions;

• custodians;

• professional advisers;

• regulators;

• public registers;

• transaction counterparties;

• investment or project sponsors;

• due-diligence providers;

• compliance or verification service providers;

• credit information sources; and

• publicly available information.

Where information is obtained from another source, we will process it in accordance with applicable data protection requirements.

6. Purposes for Which We Process Personal Information

We process personal information only for specified and legitimate purposes connected with our business, services and legal obligations.

These purposes may include:

• responding to enquiries and requests for information;

• communicating with clients, prospective clients, investors and counterparties;

• assessing and establishing client, investor or business relationships;

• providing investment management services;

• assessing investment objectives, liquidity requirements and risk profiles;

• constructing and managing investment portfolios;

• providing corporate and investment advisory services;

• carrying out investment assessments;

• conducting financial analysis and financial modelling;

• assessing investment readiness;

• supporting valuations;

• structuring transactions;

• developing capital strategies;

• supporting capital raising and structured-finance transactions;

• facilitating appropriate domestic and international capital engagement;

• administering investments, transactions and client relationships;

• conducting due diligence;

• verifying identity;

• identifying beneficial ownership;

• conducting anti-money laundering and other compliance checks;

• managing contractual relationships;

• processing authorised financial transactions;

• maintaining investment, transaction and client records;

• complying with regulatory, legal, tax, accounting and reporting obligations;

• managing risk;

• detecting, preventing and investigating fraud, financial crime, cyber threats or other unlawful activity;

• protecting SwitzView, our clients, employees and counterparties;

• managing disputes, complaints and legal claims;

• maintaining and securing our website, systems and technology infrastructure;

• improving our website, services and operational processes;

• assessing employment applications;

• conducting recruitment and selection processes;

• communicating with employment candidates;

• maintaining appropriate recruitment records; and

• communicating relevant information about SwitzView, our publications and our services where permitted by law.

We will not ordinarily use personal information for a purpose materially incompatible with the purpose for which it was collected unless permitted by law or an appropriate further basis for processing has been established.

7. Basis for Processing Personal Information

Depending on the circumstances, we may process personal information where:

• you have provided consent;

• processing is necessary for a contract or proposed engagement with you;

• processing is necessary to take steps requested by you before entering into a contract or relationship;

• processing is required to comply with a legal or regulatory obligation;

• processing is necessary to protect legitimate interests of SwitzView or another person, provided those interests do not improperly override your rights;

• processing is necessary to protect vital interests;

• processing is required for regulatory, compliance, risk-management or financial-crime prevention purposes; or

• another lawful basis for processing exists under Zimbabwean law.

Where processing relies on consent, consent will be obtained in accordance with applicable legal requirements.

Where permitted by law, you may withdraw consent previously provided. Withdrawal of consent will not affect processing lawfully undertaken before the withdrawal.

Certain information may be necessary for us to comply with regulatory requirements or to provide a requested service.

Where required information is not provided, we may be unable to establish, maintain or continue the relevant client, investment, advisory, transaction or other relationship.

8. Marketing Communications

Where permitted by law, we may communicate with existing or prospective clients, investors, counterparties and other contacts about:

• SwitzView;

• our investment management services;

• advisory services;

• capital solutions;

• market publications;

• research and insights;

• events; and

• other information that may reasonably be relevant to the recipient.

Submitting an enquiry to SwitzView does not, by itself, constitute consent to receive unrelated marketing communications where separate consent is required by law.

You may object to or opt out of direct marketing communications at any time and without charge by:

• using an unsubscribe facility provided in the communication; or

• contacting us at compliance@switzview.com.

We do not sell personal information to third parties for their independent marketing purposes.

9. Cookies and Website Technologies

Our website may use cookies and similar technologies necessary for website functionality, security, performance, analytics or user experience.

Cookies are small data files that may be stored on your device when you visit a website.

Depending on the technologies implemented on our website, cookies may be used to:

• enable essential website functions;

• maintain website security;

• improve website performance;

• understand website usage;

• remember user preferences; or

• support other functionality disclosed to users.

Some cookies may be strictly necessary for the website to operate.

Where non-essential cookies, analytics technologies or similar tracking tools require consent under applicable law, they should only be used in accordance with the applicable consent and cookie-preference controls.

You may also control cookies through your browser settings. Disabling certain cookies may affect website functionality.

Where SwitzView introduces or materially changes analytics, advertising, embedded-media or other third-party tracking technologies, this Privacy Policy and any applicable cookie controls will be reviewed and updated accordingly.

10. Website Enquiry Forms

Where you submit information through a SwitzView website enquiry or contact form, we will use the information primarily to:

• respond to your enquiry;

• communicate with you;

• understand the nature of your request;

• assess a prospective client, investor, advisory or business relationship where relevant; and

• take appropriate follow-up action requested by you.

Information submitted through an enquiry form will not automatically be treated as consent to unrelated marketing communications.

11. Third-Party Websites and Embedded Content

Our website may contain:

• links to third-party websites;

• embedded content;

• maps;

• videos;

• social-media content; or

• other services provided by third parties.

Third-party websites and services may process personal information independently under their own privacy policies and terms.

SwitzView is not responsible for the privacy practices of independent third-party websites merely because those websites or services are linked to or accessible from our website.

We encourage users to review the privacy notices of relevant third-party services before providing personal information to them.

12. Sharing Personal Information

We may disclose personal information where reasonably necessary for the purposes described in this Privacy Policy or where required or permitted by law.

Recipients may include:

• SwitzView employees and authorised personnel;

• directors and authorised governance personnel where appropriate;

• professional advisers;

• lawyers;

• auditors;

• accountants;

• consultants;

• banks;

• custodians;

• financial-service providers;

• payment-service providers;

• technology providers;

• hosting providers;

• cloud-service providers;

• communications providers;

• cybersecurity providers;

• due-diligence providers;

• identity-verification providers;

• compliance-service providers;

• transaction counterparties;

• investors;

• project sponsors;

• lenders;

• capital providers;

• advisers participating in an authorised transaction;

• regulators;

• supervisory authorities;

• courts;

• law-enforcement agencies;

• tax authorities;

• government bodies; and

• other persons to whom disclosure is required or permitted by law.

Information may also be disclosed in connection with a legitimate:

• corporate restructuring;

• merger;

• acquisition;

• investment;

• financing;

• disposal of assets or business interests; or

• similar corporate transaction.

Service providers processing personal information on our behalf are expected to process it only for authorised purposes and maintain appropriate confidentiality, privacy and security safeguards.

We do not sell personal information.

13. Service Providers and Data Processors

SwitzView may engage third-party organisations to process personal information on our behalf.

Where applicable, we will take reasonable steps to ensure that such service providers:

• process personal information only for authorised purposes;

• maintain appropriate confidentiality;

• implement appropriate security safeguards;

• comply with applicable data protection requirements; and

• appropriately protect personal information entrusted to them.

The extent of these controls will depend on the nature of the processing, information involved, risks and applicable legal requirements.

14. International and Cross-Border Transfers

SwitzView operates in an environment in which investments, advisory engagements, capital providers, professional advisers and technology services may have an international dimension.

Some service providers, technology infrastructure, advisers, investors, capital providers, counterparties or other recipients may therefore be located outside Zimbabwe or may process information using systems located outside Zimbabwe.

Where personal information is transferred outside Zimbabwe, SwitzView will take appropriate measures to ensure that the transfer complies with applicable Zimbabwean data protection requirements.

Depending on the circumstances, these measures may include:

• assessing the level of protection available in the receiving jurisdiction;

• using appropriate contractual or other safeguards;

• obtaining consent where required;

• limiting information transferred to what is reasonably necessary; or

• relying on another lawful cross-border transfer mechanism.

Cross-border processing does not remove SwitzView’s responsibility to appropriately protect personal information for which we remain the data controller.

15. Data Security

We maintain administrative, organisational, physical and technical measures designed to protect personal information against:

• unauthorised access;

• unlawful processing;

• accidental loss;

• misuse;

• unauthorised disclosure;

• alteration;

• destruction; and

• other inappropriate processing.

Access to personal information is restricted according to legitimate business and operational requirements.

Employees, representatives and relevant service providers are expected to maintain appropriate confidentiality and security standards.

Security measures may include, where appropriate:

• access controls;

• authentication controls;

• system-security measures;

• network protection;

• data-access restrictions;

• backups;

• confidentiality obligations;

• staff awareness and training;

• incident-management procedures; and

• appropriate vendor controls.

No electronic transmission, information system or storage method can be guaranteed to be completely secure.

We therefore assess risks and implement safeguards having regard to the nature of the information, available technology and relevant operational and regulatory requirements.

16. Personal Data Breaches

SwitzView maintains processes for identifying, assessing, managing and responding to personal-data security incidents.

Where a personal-data breach occurs, we will take appropriate steps to:

• contain the incident;

• investigate its nature and cause;

• assess the information and individuals affected;

• mitigate potential harm;

• preserve relevant evidence;

• address underlying security weaknesses; and

• make notifications required by applicable law.

Where required, SwitzView will notify the Data Protection Authority and affected persons within the applicable statutory requirements.

17. Retention of Personal Information

We retain personal information only for as long as reasonably necessary for:

• the purpose for which it was collected;

• maintaining the relevant client, investment, advisory or business relationship;

• providing our services;

• completing transactions;

• resolving disputes;

• exercising or defending legal rights;

• complying with legal requirements;

• complying with regulatory requirements;

• meeting accounting and tax requirements;

• financial-crime prevention;

• record keeping; or

• another legitimate and lawful purpose.

Retention periods may therefore differ depending on:

• the type of information;

• nature of the relationship;

• relevant transaction;

• regulatory requirements;

• legal obligations; and

• potential claims or disputes.

Where personal information is no longer required, it will be deleted, destroyed, anonymised or otherwise securely disposed of where reasonably practicable and permitted by law.

18. Your Data Protection Rights

Subject to applicable law and any lawful limitations, you may have rights concerning personal information held about you.

These may include the right to:

• be informed about how your personal information is processed;

• request confirmation that we process personal information concerning you;

• request access to personal information we hold about you;

• request correction of inaccurate personal information;

• request completion of incomplete personal information;

• request deletion or erasure where legally applicable;

• object to certain processing;

• request restriction of processing where applicable;

• request data portability where applicable;

• withdraw consent where processing is based on consent;

• object to direct marketing;

• raise concerns regarding unlawful or inappropriate processing; and

• request appropriate protection in relation to significant decisions based solely on automated processing where applicable.

These rights are subject to applicable legal and regulatory requirements and are not absolute.

For example, SwitzView may be legally required to retain information relating to:

• investment activities;

• transactions;

• client identification;

• anti-money laundering compliance;

• regulatory reporting;

• tax;

• accounting;

• legal claims; or

• contractual obligations.

We may request reasonable proof of identity before responding to a data protection request in order to prevent unauthorised disclosure of personal information.

We aim to respond to valid data-subject requests within 30 days, subject to applicable law and the nature and complexity of the request.

19. Automated Decision-Making

SwitzView does not intend to subject individuals to decisions producing significant legal or similar effects solely through automated processing unless such processing is permitted by law and appropriate safeguards are in place.

Where SwitzView introduces automated processing of this nature in the future, affected persons will be provided with appropriate information and protections in accordance with applicable law.

20. Children’s Personal Information

SwitzView’s website and financial services are not directed specifically at children.

We do not knowingly collect personal information from persons under eighteen years of age through the website without an appropriate lawful basis and, where required, the involvement or consent of a parent or legal guardian.

If we become aware that children’s personal information has been collected in circumstances inconsistent with applicable law, we will take appropriate corrective action.

21. Data Protection Officer and Privacy Requests

Questions, concerns, complaints or requests relating to personal information should be directed to SwitzView’s Data Protection Officer.

Data Protection Officer:
Beaulla Nemhara

Email:
compliance@switzview.com

Telephone:
+263 242 883 660

Alternatively, correspondence may be addressed to:

SwitzView Wealth Management (Private) Limited
7 Kings Row, North Gate
Borrowdale, Harare
Zimbabwe

General Email: switzview@switzview.com
Telephone: +263 242 883 660 / 883 661

22. Complaints and the Data Protection Authority

We encourage you to contact SwitzView’s Data Protection Officer first if you have concerns about the way in which your personal information has been processed.

This allows us an opportunity to investigate and address the matter.

You may also have the right to raise a complaint with the Data Protection Authority of Zimbabwe.

The Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ) performs the functions of the Data Protection Authority under Zimbabwe’s data protection framework.

Any complaint or regulatory engagement will be handled in accordance with applicable law.

23. Regulatory and Legal Disclosures

SwitzView operates within a regulated financial-services environment.

Nothing in this Privacy Policy prevents SwitzView from collecting, retaining, processing or disclosing personal information where reasonably required to comply with:

• securities regulation;

• financial-services regulation;

• anti-money laundering requirements;

• counter-terrorist financing requirements;

• sanctions requirements;

• tax obligations;

• court orders;

• regulatory investigations;

• supervisory requirements;

• lawful requests from competent authorities; or

• other applicable Zimbabwean law.

Where legally permissible and reasonably practicable, such processing will remain limited to what is necessary for the relevant legal or regulatory purpose.

24. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

• our business;

• services;

• website functionality;

• technology;

• regulatory requirements;

• legal requirements; or

• data protection practices.

The latest version will be published on www.switzview.com together with its effective or last-updated date.

Where a change materially affects how personal information is processed, we will use appropriate means to communicate the change where required by law.

25. Governing Law

This Privacy Policy and Data Protection Notice is governed by the laws of the Republic of Zimbabwe, including the Cyber and Data Protection Act [Chapter 12:07], applicable regulations and lawful requirements issued under Zimbabwe’s data protection framework.

26. Contact Us

For general enquiries concerning SwitzView:

SwitzView Wealth Management (Private) Limited
7 Kings Row, North Gate
Borrowdale, Harare
Zimbabwe

Telephone: +263 242 883 660 / 883 661
Email: switzview@switzview.com
Website: www.switzview.com

For privacy and data protection matters:

Data Protection Officer: Beaulla Nemhara
Email: compliance@switzview.com
Telephone: +263 242 883 660