Elysium Management Company (USA & South Africa)

Effective Date: 27th February 2026
Last Updated: 27th Feburary 2026


1. Introduction

Elysium Management Company (“Elysium,” “Company,” “we,” “our,” or “us”) operates through registered entities in the United States and the Republic of South Africa.

This Privacy Policy explains how we collect, process, store, transfer, and protect personal information in connection with:

  • Membership package purchases

  • Website usage

  • Equity participation

  • Shareholder onboarding

  • Regulatory compliance requirements

Equity-related matters are governed separately by the applicable Shareholder Agreement, which purchasers must review and accept at the time of equity issuance.


2. Categories of Personal Information We Collect

We may collect the following:

A. Identity Information

  • Full legal name

  • Date of birth

  • Nationality

  • Government-issued ID

  • Residential address

B. Contact Information

  • Email address

  • Telephone number

  • Country of residence

C. Financial & Transaction Data

  • Payment confirmation records

  • Billing information

  • Membership purchase records

  • Share allocation records

⚠️ Elysium does not store full payment card details. Payments are processed via First National Bank (FNB), South Africa, through our merchant account infrastructure.


D. Compliance & Regulatory Information (If Required)

Because membership may include equity allocation, we may collect:

  • Proof of identity

  • Proof of residence

  • Tax identification information

  • Source of funds documentation

This information is collected strictly for legal and regulatory compliance purposes.


E. Technical Data

When you access our website:

  • IP address

  • Browser type

  • Device information

  • Usage data

  • Cookies


3. Purpose of Processing

We process personal information to:

  • Provide membership services

  • Process payments

  • Allocate shares in accordance with the Shareholder Agreement

  • Conduct identity verification (KYC/AML)

  • Comply with corporate and financial regulations

  • Prevent fraud and unlawful activity

  • Communicate operational updates

We do not sell personal information.


4. Legal Basis for Processing

🇿🇦 Under POPIA (South Africa)

Processing is conducted:

  • With consent

  • For contractual necessity

  • For legal compliance

  • For legitimate business purposes

🇺🇸 Under U.S. Laws

Processing is based on:

  • Contractual performance

  • Compliance with applicable securities and financial laws

  • Legitimate business interests


5. Cross-Border Data Transfers

Due to our dual registration in the USA and South Africa, and international customer base (including South Africa, Mexico, Philippines, South America, and the USA), your data may be transferred between:

  • United States

  • South Africa

  • Approved international service providers

We implement appropriate safeguards for international transfers.


6. Payment Processing (FNB Merchant Services)

All online payments are processed via:

First National Bank (FNB), South Africa

  • Transactions are encrypted

  • Payment security is governed by FNB banking standards

  • Elysium does not retain full card data

We are not responsible for independent third-party banking system breaches beyond our control.


7. Data Retention

We retain personal information:

  • For the duration of membership

  • For the duration of shareholding

  • As required by corporate, tax, and financial regulations

Certain shareholder records may be retained beyond membership duration where legally required.


8. Your Rights

Depending on your location, you may have the right to:

  • Access your personal information

  • Correct inaccurate information

  • Request deletion (subject to legal limitations)

  • Object to certain processing

  • Lodge complaints with regulatory authorities

South Africa:

Complaints may be submitted to the Information Regulator.

United States:

Certain state-level privacy rights may apply.

To exercise your rights, contact:
📧 [Insert Privacy Email]


9. Data Security Measures

We implement:

  • SSL encryption

  • Secure hosting environments

  • Restricted internal access controls

  • Compliance documentation procedures

  • Shareholder record protection protocols

While we apply commercially reasonable safeguards, no system is fully immune from risk.


10. Relationship to Shareholder Agreement

Where a purchaser receives equity shares:

  • Data required for share issuance is governed by the Shareholder Agreement

  • Shareholder data may be maintained in official corporate records

  • Regulatory disclosures may occur where legally required

The Shareholder Agreement governs equity rights and obligations.


11. Cookies & Website Analytics

We use cookies to:

  • Improve site performance

  • Monitor website traffic

  • Enhance user experience

Users may disable cookies in browser settings.


12. Minors

Membership and equity participation are available only to individuals aged 18 years or older.

We do not knowingly collect personal data from minors.


13. Updates to This Policy

We may update this Privacy Policy periodically.

The most recent version will be posted on our website with the updated effective date.


14. Contact Information

Elysium Management Company
Registered in: United States & South Africa

Privacy Contact:
📧 info@elysiummanagementcompany.co.za