Surveillance & Monitoring Policy

Parthenius Air (Pty) Ltd ("Parthenius Air") operates licensed BVLOS drone and aerial intelligence systems as part of its Adaptive Deterrence Intelligence deployments. These operations may involve the collection of footage and imagery that could identify individuals. This policy sets out how such data is collected, used, stored, and protected in accordance with POPIA and applicable South African law.

Scope

This policy applies to all surveillance and monitoring activities conducted by Parthenius Air in the course of its drone operations and Zerathis Blindspot™ platform deployments. It covers:

• Aerial footage and imagery collected during BVLOS drone operations
• Video and photographic evidence collected in connection with operational intelligence deployments
• Any other data collected through monitoring systems that may identify individuals

This policy does not apply to data collected through the website enquiry form, which is governed by the Privacy Policy.

Purpose of surveillance

Surveillance and monitoring activities are conducted exclusively for the following lawful purposes:

• Protection of client assets, infrastructure, and personnel
• Detection and deterrence of criminal activity on client sites
• Intelligence collection in support of Zerathis Blindspot™ adversary behaviour modelling
• Operational documentation and incident evidence collection
• Compliance with client contractual obligations

Surveillance activities are conducted only within the operational boundaries of client sites under active deployment agreements. Parthenius Air does not conduct surveillance beyond the scope of its contractual mandate.

Legal basis for processing

Surveillance data is processed on the following lawful grounds under POPIA:

• Legitimate interests — the protection of client property and the prevention of crime
• Contractual necessity — the fulfilment of operational intelligence and security obligations to clients
• Compliance with legal obligations — cooperation with law enforcement where required by law

Data collection

Surveillance data collected by Parthenius Air may include:

• Aerial video footage from drone operations
• Still imagery from aerial and ground-based systems
• Thermal and low-light imagery where operationally required
• Geolocation and movement data associated with detected activity

Data collection is proportionate to the operational purpose. Footage is not collected beyond what is operationally necessary for the intelligence and protection functions contracted by the client.

Access to surveillance data

Surveillance data is accessible to:

• Parthenius Air operational personnel directly involved in the deployment
• The client, through the Zerathis Blindspot™ platform portal, for footage and intelligence outputs relating to their site
• Law enforcement or regulatory authorities where required by law or court order

Client access is role-based and controlled through the Zerathis Blindspot™ platform authentication system. Clients may only access footage and data relating to their own deployment.

Surveillance data is not shared with third parties except as described above or where required by law.

Retention

Surveillance footage and imagery are retained for a period of five years from the date of collection, unless:

• A shorter retention period is specified in the client agreement
• A longer period is required for ongoing legal proceedings or law enforcement purposes
• The client requests earlier deletion, subject to any legal hold obligations

After the retention period, footage and imagery are securely deleted from all systems.

Security of surveillance data

Parthenius Air implements appropriate technical and organisational security measures to protect surveillance data, including:

• Encrypted storage of footage and imagery
• Access controls limiting data access to authorised personnel only
• Secure transmission of data between operational systems and the platform
• Regular security reviews of data storage and access systems

Rights of data subjects

Individuals who believe they have been captured in surveillance footage collected by Parthenius Air have the following rights under POPIA:

• The right to request access to their personal information
• The right to request correction or deletion of inaccurate personal information
• The right to object to processing
• The right to lodge a complaint with the Information Regulator

Requests relating to surveillance data should be submitted in writing to the Information Officer. Parthenius Air will respond within 30 days. Access to surveillance data may be refused where disclosure would compromise ongoing operations, client confidentiality, or law enforcement activities.

Regulatory compliance

All drone surveillance operations are conducted in compliance with:

• South African Civil Aviation Authority (SACAA) regulations — UASOC G1424D
• Private Security Industry Regulation Act — PSIRA Reg. 4340995
• Protection of Personal Information Act 4 of 2013
• Civil Aviation Act 13 of 2009

Information Officer