Privacy Policy

1. Purpose of This Policy

This Privacy Policy outlines how we collect, use, store, and disclose your personal information in line with POPIA. It applies to all data subjects whose personal information we process, including clients, employees, service providers, and other stakeholders.

2. What Information We Collect

We may collect and process the following types of personal information:

• Full name
• Identity or passport number
• Contact information (email, phone number, physical address)
• Demographic information (age, gender, race only where legally required or with consent)
• Employment or company details
• Financial information (e.g. bank account number, payment details)
• Records of correspondence or enquiries
• Technical information (IP address, browser type, cookies, etc.)

In some cases, we may collect special personal information, including biometric data or health-related information, but only with your explicit consent or where legally required.

3. How We Collect Your Information

We collect personal information in the following ways:

• Directly from you when you engage with us (e.g. filling out forms, emailing us, signing a contract)
• From publicly available sources
• Automatically through your use of our website (cookies and usage analytics)
• From third parties, where applicable and lawful

4. Why We Collect and Use Your Information

We only process your personal information for lawful and specific purposes, including:

• Providing and managing our products or services
• Managing customer relationships and communications
• Conducting due diligence, onboarding, and verification
• Processing payments or fulfilling contractual obligations
• Recruitment and employment matters
• Ensuring legal and regulatory compliance
• Sending you service-related or promotional communications (where permitted)

We will not use your information for any other purpose without your consent, unless required by law.

5. Legal Grounds for Processing

We process personal information based on one or more of the following legal bases:

• Your consent
• The performance of a contract with you
• Compliance with a legal obligation
• Our legitimate interest in managing our business or preventing fraud

6. Sharing Personal Information

We may share your personal information with:

• Service providers and business partners who assist in our operations
• Regulatory or government authorities (where legally required)
• Auditors, legal advisors, or consultants
• Other third parties where you have given your consent

All third parties are required to treat your information with confidentiality and in accordance with POPIA.

7. Cross-Border Transfers

Where we transfer personal information outside South Africa (e.g. to cloud service providers), we will:

• Ensure the recipient country has adequate data protection laws, or
• Enter into binding agreements with the recipient to ensure your data is protected
• Obtain your consent, where required

8. Data Security

We take appropriate and reasonable measures to protect your personal information from:

• Loss or destruction
• Unauthorised access or disclosure
• Unlawful processing

These measures include firewalls, encryption, secure servers, and access controls.

9. Data Retention

We will retain your personal information only as long as necessary for the purpose it was collected or as required by law. Once it is no longer needed, we will securely delete or de-identify it.

10. Your Rights Under POPIA

As a data subject, you have the right to:

• Access the personal information we hold about you
• Request correction or deletion of your personal information
• Object to or restrict the processing of your information
• Withdraw consent where processing is based on consent
• Lodge a complaint with the Information Regulator if you believe your rights have been violated

To exercise your rights, please contact us using the details below.

11. Use of Cookies

Our website may use cookies and tracking technologies to enhance your browsing experience and analyse website traffic. You can manage cookie settings in your browser preferences.

12. Changes to This Policy

This Policy will be reviewed annually or sooner if required to align with applicable laws and regulations.