Introduction

This statement (the “Privacy Policy”) sets forth the privacy standards that Makosi Audit and Tax Services, LLC, together with its affiliates, Tidal Wave Holdings, LLC, Tidal Wave Audit and Tax LLC (together, the “Company(ies),” “us,” “we,” or “our”) utilize to collect, retain, and use personal data obtained from individuals using or accessing our website(s) located at www.makosi.com or mobile services or making use of any of the talent recruitment and placement services offered by any of the Companies (the “Makosi Services”).

This Privacy Policy also forms part of the Makosi Applicant Terms of Service and it applies to every person (“you”, “user(s)”,”he”, “she” “they”) who accesses or uses Makosi’s online and/or mobile services and websites, including any software, service, feature, product, program and element provided by or on behalf of Makosi in connection with such services or websites (collectively, the “Website”) and including, but not limited to, any products, programs, and services described in the Terms of Service .

1. Introduction and purpose of the Privacy Policy

1.1. The Makosi Services can be accessed at www.makosi.com. All intellectual property (including Our Website) is currently owned and operated by Tidal Wave Holdings LLC, New York, USA.

1.2. The Makosi Services facilitate opportunities for suitably qualified auditors and/or accountants on the (global) job market (“Applicants”) with fixed term employment and/or secondment opportunities at Certified Public Accountant (CPA) firms in the United States (“Makosi Secondment Partners”).

1.3. This Privacy Policy describes the way we collect, store, use, and protect personal information which you submit to us, either through the Website or other form of communication, whether digital or hard copy, in writing or verbally.

1.4. Please read this Privacy Policy, the Terms of Service and our Browser Terms carefully before using the Makosi Website or any of the services that we may offer.

2. Acceptance and consent

2.1. You accept all the terms in this Privacy Policy, the Browser terms and our Terms of Service when you use our Website or make use of any Makosi Services and consent to us collecting and processing and storing the personal information as referred to in this Privacy Policy.

3. Changes to this Privacy Policy

3.1. We may change the terms of this Privacy Policy from time to time in line with any changes that the law or our internal business operations require, without prior notice. It is your responsibility to consider the Privacy Policy each time you use our Website or the Makosi Services. If you do not agree with any terms of this Privacy policy, you must stop using our Website.

4. Privacy laws and protecting your Personal Information

4.1. We will take the necessary steps to protect your privacy, including as applicable, compliance with the Protection of Personal Information Act, 4 of 2013 ("POPI") (for data subjects in South Africa), General Data Protection Regulations (“GDPR”) (for data subjects in the EU or EEA), and all reasonable steps to be in compliance with the applicable privacy laws governing data subjects outside of the EU/EEA and South Africa.

4.2. International transfers of your personal data – For EU/EEA Data Subjects Only

In this Section 4.2, we provide information about the circumstances in which your personal data may be transferred to countries outside the EEA (Austria, Belgium, Bulgaria, Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom to the extent applicable) or Switzerland.

The Company has its principal place of business located at 244 Fifth Avenue, Suite 1293, New York, NY 10001 (USA). The European Commission has made an "adequacy decision" with respect to the data protection laws of the United States. In the event the Company transfers any of your personal data to a third party in the United States or elsewhere outside of the EEA, such transfers will be protected by appropriate safeguards through the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

By providing your personal data to the Company, you are agreeing to the transfer and processing of your personal data to and in the United States in accordance with this Privacy Statement.

By using the Makosi Services, you are agreeing to the transfer and processing of your personal data to and in the United States in accordance with this Privacy Statement.

4.3. Your Rights - EU/EEA Data Subjects Only

In this Section 4.3, we have summarized the rights that EU/EEA data subjects have under applicable data protection law, including the GDPR. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

• the right to access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to object to processing;
• the right to data portability;
• the right to complain to a supervisory authority; and
• the right to withdraw consent under certain circumstances.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing where no other legitimate basis for retention exists; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation (including contractual obligations); or for the establishment, exercise or defense of legal claims.

In some circumstances you may have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

If you do not wish to receive emails about special offers and other promotions from us, click the unsubscribe link located in our emails.

You may exercise the same rights as individuals from California (United States) pursuant to Section 12 below by using the contact information instructions set forth in Section 12, or below in this Section.

If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Statement, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request, or your request to exercise any of your rights in relation to your personal data by written notice to us at:

Attention: Privacy Officer ( [email protected] ) Makosi Audit and Tax Services, LLC 244 Fifth Ave, Suite 1293 New York, NY 10001

With a copy (including the words “MAKOSI - GDPR” in the subject line) to: OlenderFeldman LLP 422 Morris Avenue Summit, NJ 07901 (USA)

Attention: Michael J. Feldman, Esq. ( [email protected] )

4.4. We have listed your rights that you have under data protection laws under GDPR and South Africa Privacy laws.

4.4.1. the right to access - you can ask for copies of your personal data;

4.4.2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

4.4.3. the right to erasure - you can ask us to erase your personal data;

4.4.4. the right to restrict processing - you can ask use to restrict the processing of your personal data;

4.4.5. the right to object to processing - you can object to the processing of your personal data;

4.4.6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

4.4.7. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

4.4.8. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

4.5. These rights are subject to certain limitations and exceptions.

4.6. In addition to the above, you can learn more about the rights of data subjects subject to the GDPR by visiting

https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

5. Personal and Non-personal Information we may collect

5.1. The term “personal information” refers to any information that relates to a natural person (as opposed to a business or corporate entity) that makes you identifiable. The term “non-personal information” refers to information which does not specifically identify you.

5.2. As used in this Privacy Policy, personal information we may collect from you on or through the Website or Makosi Services may include, without limitation: your full name, surname, IP address, email address, age, race, gender, nationality, identity number, passport and visa details, photographs which identify you, personal contact details, work and schooling history when connected with other personal information, and your address or other location data.

6. Collecting your Personal Information

6.1. We collect information about you when you use our Website and communicate with us.

6.2. We may collect all types of personal information about you as described above. By using the Website and/or the Makosi Services, you agree that we may collect and process all such personal information that you provide to us or that is provided to us on your behalf, to enable us to provide the Makosi Services.

Please do not supply the following to us:

• Any other person's personal information, unless the Company explicitly asks you to do so;
• Any categories of your personal information that have not been explicitly requested by the Company;
• Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by the Company to provide; and
• Any confidential, proprietary, secret or legally protected information which are under any legal obligation to not provide to or share with the Company.

6.3. You provide us with different types of information in order for us to provide the Makosi Services, products and features to you.

6.4. Makosi may collect and store personal information from you in connection with:

6.4.1. providing the Makosi Services or any other product which Makosi offers;

6.4.2. creation of your user profile as an Applicant and verification of your profile;

6.4.3. communicating with you about employment and/or secondment opportunities;

6.4.4. visits or browsing on the Website.

6.4.5. Tracking of referrals that you make.

6.5. When you apply on the Website to become a Makosi Applicant, you provide us with your e-mail address and your resume details, which contain your personal information. By providing us with this information, you consent to us collecting and processing your personal information in order for you to make use of and to allow us to provide and optimise the Makosi Services for you.

6.6. We may also collect information about you from third parties. For example, you will be able to register and initiate the application process using Linked-In. To this end, the Website will be linked via your secure log-in portal to your Linked- In profile page. You consent to this integration and to Makosi accessing and importing information from your Linked-In profile, such as profile picture and employment history, in order to create your Makosi Applicant profile for presentation to appropriate Secondment Partners.

6.7. Privacy of Children Who Visit the Website.

We recognize the importance of children’s safety and privacy. Neither the Website nor the Makosi Services are for use by, nor designed to attract, anyone under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are under age 18, you do not have permission to use the Website or the Makosi Services. If we learn that we have collected personal information of a child under 18, we will take the appropriate steps to delete such information from our files as soon as possible. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you can alert us at [email protected].

7. Use of Cookies

7.1.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

7.1.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

7.1.3. Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

7.1.4. Shared local objects (commonly referred to as “FLASH cookies”) are cookies that are placed on your computer that are not removed through normal browser management tools. If we use FLASH cookies, we will only do so in a manner consistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service.

7.2. Cookies That We Use

We use cookies for the following purposes related to the services we provide for and to you and our users:

7.2.1. authentication - we use cookies to identify users of the website and/or the location of individuals accessing the website;

7.2.2. status - we use cookies to help us to determine if you are logged into our website;

7.2.3. personalization - we use cookies to store information about your preferences and to personalize the website for you;

7.2.4. security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

7.2.5. advertising - we use cookies to help us to display advertisements that will be relevant to you

7.2.6. EU/EEA Data Subjects Only – You can disable advertising cookies as set forth herein. In addition, if you provide us with notice as set forth in Section 13 hereof, we may be able to show you how to disable advertising cookies. However, because we may derive income related to our services from advertising cookies, if such cookies are disabled, it may impact your ability to use our website and/or our services and/or impact the cost of our services to you;

7.2.7. analysis - we use cookies to help us to analyze the use and performance of our website and services; and

7.2.8. cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

7.3. Cookies Used By Our Service Providers And Vendors

7.3.1. Our service providers and vendors may use cookies and those cookies may be stored on your computer when you visit our website. These service providers and vendors include: Salesforce (www.salesforce.com) Hubspot (www.hubspot.com) Outreach (www.outreach.com) Google Analytics (www.google.com/analytics) Google Tag Manager (www.google.com/analytics/tag-manager) Google AdWords (https://adwords.google.com) Facebook ( www.facebook.com ) LinkedIn (www.linkedin.com) Wordpress (https://wordpress.com)

You should review the privacy and cookie policies of the above websites to learn more about the cookies that are used in connection with the above.

7.4. Managing Cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

• https://support.google.com/chrome/answer/95647?hl=en (Chrome);

•https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

• http://www.opera.com/help/tutorials/security/cookies/(Opera);

• https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

• https://support.apple.com/kb/PH21411 (Safari); and

• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking some or all cookies will have a negative impact upon the usability of many websites, including our website and our Services.

7.5. Use of Web Beacons, Clear-GIFs, Pixel Tags and JavaScript

7.5.1. Except as set forth herein, our use of web beacons, clear-gifs, pixel tags and JavaScript is critical to proper functionality our website, and disabling them may impact the functionality of the website and the services we provide.

7.5.2. We also may use “pixel tags” (also called “action pixels,” “web beacons” or “clear gifs”) and/or JavaScript plug-ins, placed on the website and in our emails to you.

7.5.3. These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message which are used for such things as recording webpages and advertisements clicked-on by a user, or for tracking the performance of email marketing campaigns. These devices help us analyze our users’ online behavior and measure the effectiveness of our website and our marketing.

7.5.4. We may also work with third-party service providers that help us track, collect, and analyze this information. Third-party entities with whom we have agreements may place these devices on the website and/or in emails to use information obtained from them such as pages viewed, emails opened and items upon which you may click in emails. These third-party providers may also place cookies onto your computer. Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources as well as our information we have about you. See above for more information on our cookies.

7.5.5. EU/EEA Data Subjects Only – You may be able to disable use of web beacons, clear-gifs, pixel tags and JavaScript if you provide us with notice as set forth in Section 13 hereof. However, doing so may impact your ability to use our website and/or our services and/or impact the cost of our services to you.

7.6. Server Logs

A web “server log” is a record of activity created by a computer that delivers certain webpages to your browser. Certain activities that you perform on our website may record information in server logs. For example, if you enter a search term into a search box located on the website, the server log may record the search term, the link you clicked on to bring you to our website and/or information about your browser, such as your IP address and the cookies set on your browser.

8. Purpose, uses and disclosure of information

8.1. Personal information which you provide to us will only be used for the purposes listed in this Privacy Policy and the Terms of Use of the Makosi Service.

8.2. Makosi may use your Personal Information to:

8.2.1. provide the Makosi Services and/or any other products and services to you, which may necessitate sharing your personal information with third party service providers located in the USA or your country of residence.

8.2.2. manage its relationship with you and third-party service providers;

8.2.3. communicate with you about the Makosi Services and any other products, services or support offered by us and to send marketing communications in connection these services and products;

8.2.4. provide support to you in respect of the Makosi Services;

8.2.5. improve the Makosi Services;

8.2.6. provide personalised offers;

8.2.7. measure performance of marketing initiatives;

8.2.8. allow you to participate in competitions and surveys;

8.2.9. answer enquiries, provide information, support or advice about the Makosi and any new products or services offered;

8.2.10. assess and improve the performance and operation of the Website;

8.2.11. prevent and detect security threats, fraud or other malicious activity;

8.2.12. process and respond to any complaint made by or about you;

8.2.13. updating our records;

8.2.14. in connection with any application for employment;

8.2.15. internal analysis of our business;

8.2.16. any statutory or regulatory purpose which requires the processing of your personal information;

8.2.17. legal and regulatory compliance;

8.2.18. fraud and crime prevention;

8.2.19. third party transactions, sales or due diligence;

8.2.20. if required by any law enforcement agency or in connection with any legal requirement where we are required by law to present this;

8.2.21. internal or external audits; and/or

8.2.22. any other purpose for which valid consent is obtained.

8.3. Makosi will not sell, rent or otherwise disclose your personal information to any third party without your consent provided that by using the Website and/or subscribing to the Makosi Service, you provide your express and informed consent for Makosi to disclose your personal information to third parties as follows:

8.3.1. provide the Makosi Services and/or any other products and services to you, which may necessitate sharing your personal information with third party service providers located in the USA or your country of residence.

8.3.2. manage its relationship with you and third-party service providers;

8.3.3. communicate with you about the Makosi Services and any other products, services or support offered by us and to send marketing communications in connection these services and products;

8.3.4. provide support to you in respect of the Makosi Services;

8.3.5. improve the Makosi Services;

8.3.6. provide personalised offers;

8.3.7. measure performance of marketing initiatives;

8.3.8. allow you to participate in competitions and surveys;

8.3.9. answer enquiries, provide information, support or advice about the Makosi and any new products or services offered;

8.3.10. assess and improve the performance and operation of the Website;

8.3.11. prevent and detect security threats, fraud or other malicious activity;

8.3.12. process and respond to any complaint made by or about you;

8.3.13. updating our records;

8.3.14. in connection with any application for employment;

8.3.15. internal analysis of our business;

8.3.16. any statutory or regulatory purpose which requires the processing of your personal information;

8.3.17. legal and regulatory compliance;

8.3.18. fraud and crime prevention;

8.3.19. third party transactions, sales or due diligence;

8.3.20. if required by any law enforcement agency or in connection with any legal requirement where we are required by law to present this;

8.3.21. internal or external audits; and/or

8.3.22. any other purpose for which valid consent is obtained.

8.4. Our Website may connect to various social media sites or apps, including Facebook, Twitter, LinkedIn, Instagram and Google+. You should visit the privacy policies of such sites or apps if you are connected to them as each individual sites’ or apps’ privacy policy will govern your use and access to same. If you want to use our Website for social media integration, including to create user profiles and login functionality, we will share your information with the relevant social media sites or apps.

8.5. We may transmit or transfer personal information to countries outside of your home country, whether that is the United States, South Africa or otherwise. By using the Website or the Makosi Services, you are agreeing to such transfer.

8.6. Should you believe we are in contravention of the GDPR, you may contact our privacy officer at [email protected] and we will ensure we revert within 48 hours of your correspondence.

8.7. We reserve the right to share non-personal, non-individual information in aggregate form with third parties for business purposes, for example with business associates and partners. You will not be identifiable from such data as such. Makosi is not responsible and cannot be held liable for the privacy practices of such third parties.

8.8. Demographical and statistical information about user behaviour may be collected and used to analyse the popularity and effectiveness of the Website. Any disclosure of this information will be in aggregate form and will not identify individual users.

9. Quality and protection of your information

9.1. You are responsible for the accuracy of the information submitted to us and for ensuring that it is up-to-date, complete and accurate. It is your duty to maintain your profile and the details of your resume that is provided to us.

9.2. Makosi will take all reasonable measures to prevent the destruction, unlawful access and loss of personal information including establishing appropriate physical, electronic and managerial procedures to safeguard the personal information collected from you. This helps prevent unauthorised access, maintains data accuracy and ensures that personal information is used correctly. In order to carry out these security procedures, Makosi may ask for proof of identity before personal information is disclosed to you.

9.3. Please contact the Makosi by phone or email [email protected] if you:

9.3.1. require access to any of your personal information which is being held by Makosi;

9.3.2. wish to notify Makosi of any change, modification or correction to your personal information which you are unable to change for yourself;

9.3.3. would like to have your personal information removed from our records;

9.3.4. believe that someone is impersonating or otherwise unlawfully using your login details or your account.

9.3.5. While every effort will be made to adopt appropriate security procedures to help prevent unauthorised access to your personal information, Makosi will not be liable for any attempt to hack or crack or otherwise gain access to any of your personal information on servers owned and maintained by or on behalf of Makosi.

10. How Makosi stores information collected from you

10.1. Information, including your personal information is stored in Salesforce and Dropbox which may be based in various locations around the world including the USA.

10.2. Information is held for as long as you maintain a profile with Makosi (until you request us to delete it) or as long as may be legally required.

10.3. Information which you provide to us will be stored electronically and/or in hard copy, with reasonable security measures protecting this information. However, please note that we work with third party contractors, some of which host and operate certain features of the Website. Therefore, information that Makosi collects from you may be collected in or transferred to a destination outside South Africa, including in the USA or any other such region as deemed appropriate from time to time and/or may be processed by employees/independent contractors operating outside South Africa who work for or are contracted to Makosi. By submitting personal information to us, you agree to the transfer, storage and processing of your personal information as set out in this Privacy Policy. Makosi will take all appropriate steps to ensure that your data and personal information is treated securely and in accordance with this Privacy Policy.

11. Your California Privacy Rights

11.1. We collect various types of personal information about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us about how we have shared your information with third parties for their direct marketing purposes. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same brand name, if the third party will use such information for its direct marketing purposes.

11.2. If you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below. Please include your postal address in your request. Within thirty (30) days of receiving your written request, we will provide you with a Third Party Direct Marketing Opt-Out Form so you may request that your personal information not be disclosed to third parties for their direct marketing purposes.

E-mail Address: [email protected]

Postal Address: 244 Fifth Ave, Suite 1293, New York, NY 10001