Legal
Privacy policy
What we collect when you use SmartMatchHub, why we collect it, who else sees it, how long we keep it, and what you can tell us to do with it.
- Last updated
- [[LAST_UPDATED]]
- Applies from
- [[EFFECTIVE_DATE]]
- Applies to
- Adults aged 18 and over
Last updated: [[LAST_UPDATED]]. Applies from [[EFFECTIVE_DATE]].
1. Summary
SmartMatchHub is a South African dating app in which short audio calls replace swiping. This policy sets out what personal information we collect, why we process it, who receives it, how long we keep it, and what rights you have. We collect account details, profile details, personality assessment answers, records of your calls, the details you give us on our website to join early access, and any message you send us through the contact form on our website. We do not record, transcribe, listen to or analyse calls. We do not collect photographs, images or video at any stage. We do not sell personal information and we do not share it for advertising. Some of what we ask you for is special personal information, and we process that only with your consent, which you may withdraw; a message you send us can hold special personal information we never asked for, and section 7 says what we do with it. If you joined early access, our email to you normally carries a link to a page where you can see those details, change them, stop the emails or delete them yourself, and where it does not, you can ask us to do the same things. The service is for people aged 18 and over.
2. Who we are and how to contact us
The responsible party under the Protection of Personal Information Act 4 of 2013 (POPIA), and the controller under the UK General Data Protection Regulation (UK GDPR), is [[LEGAL_ENTITY]], registration number [[COMPANY_REG_NO]], registered address [[REGISTERED_ADDRESS]], postal address [[POSTAL_ADDRESS]].
Our Information Officer, appointed under section 55 of POPIA, is [[INFORMATION_OFFICER]], contactable at [[PRIVACY_EMAIL]] or [[PHONE]].
Use [[PRIVACY_EMAIL]] for privacy questions, requests about your information and complaints about how we handle it. Use [[SAFETY_EMAIL]] to report a safety concern or the conduct of another user. Use [[SUPPORT_EMAIL]] for general support.
Our representative in the United Kingdom, appointed under Article 27 of the UK GDPR, is [[UK_REPRESENTATIVE]]. If you are in the United Kingdom you may raise any matter covered by this policy with the representative instead of with us, and the representative will act on our behalf.
3. What this policy covers
This policy covers the SmartMatchHub mobile app, the call service that supports it, and our website. The app is in early access. The website is live and has two forms. The early-access form collects what you enter to join: an email address, a first name, an age range, a gender and a sexuality. The contact form, headed Get in touch, collects your name, your email address, a subject if you choose to give one, and the message you write, which is free text. Both forms send what you enter to our own service, and it is stored in our own database alongside the app’s records rather than with an outside form service. Your sexuality is special personal information, and section 7 explains the ground we rely on to process it.
4. What we collect, and whether you must supply it
The table below sets out each category of personal information, where it comes from, and whether you must supply it.
| Information | Source | Must you supply it |
|---|---|---|
| First name and last name | You, at sign-up | Mandatory to create an account |
| Email address | You, at sign-up | Mandatory to create an account |
| Phone number | You, at sign-up | Mandatory to create an account |
| Password | You, at sign-up | Mandatory to create an account. We store it only as a bcrypt hash and cannot read it |
| One-time email verification code | Generated by us and sent to you | Needed only if you verify your email address. Verification can be skipped |
| Date of birth | You, at onboarding | Mandatory to complete onboarding |
| Gender, sexuality, who you are interested in, relationship status, what you are looking for, preferred languages, age range | You, at onboarding | Mandatory to complete onboarding |
| Ethnicity, culture, religion | You, at onboarding | Mandatory to complete onboarding. These are special personal information and we process them only with your consent (section 7) |
| Precise location, being your device’s latitude and longitude | Your device, once, if you grant location permission | Voluntary. It is captured once and not read again |
| Personality assessment answers, each with its 1 to 5 value, the date and time it was answered, a sitting identifier, and how long you took to answer it | You, when you take the assessment | You choose whether to take the assessment |
| Trait scores computed from those answers | Generated by us | Generated automatically if you take the assessment |
| Smart Match Card, being your display name and the contact handles you supply for WhatsApp, Instagram, X, TikTok, Facebook and Snapchat | You | Voluntary. Only the handles you supply are exchanged on a Match |
| Call records, being who was on the call, when it took place, how long it lasted, your decision, and whether you would speak to that person again | Generated by us when you take a call | Generated automatically |
| Free-text feedback about the person you spoke to | You, after each call | Mandatory after each call |
| Connection quality readings | Generated during the call | Generated automatically |
| IP addresses | Your device, when it connects | Generated automatically. Section 5 explains which servers see it |
| Push notification token | Your device, if you allow notifications | Voluntary |
| Error reports from the app | Your device, in the released app only | Generated automatically when the app fails |
| Server logs recording endpoints called and events | Generated by our servers | Generated automatically |
| Support and safety correspondence you send us by email | You, when you email one of the addresses in section 2 | Voluntary, but we may be unable to help without it |
| Early-access details, being an email address, a first name, an age range, a gender and a sexuality | You, on the website | Voluntary, and the form cannot be completed without them. The age range, the gender and the sexuality are needed to place you in a cohort; the email address is where we write to you, and the first name is so that our emails can address you by name. We ask for a range rather than a date of birth because a range is all a cohort needs |
| Early-access link codes, being two random codes that identify your early-access record | Generated by us and sent to you in our early-access email | Generated automatically when you join early access. One is what the unsubscribe link uses; the other is what the link to change or remove your details uses. They are not shown to you anywhere else, and knowing one is what lets that link act on your record without you signing in |
| A message you send us through the contact form on our website, being your name, your email address, a subject if you give one, and what you write | You, on the website | Voluntary. The form cannot be sent without your name, your email address and your message; the subject is optional and, if you leave it out, nothing is stored in its place. A subject you do give is used as the subject line of the notification the form sends us, so it is the first thing we see about your message. Your email address is the only way we have to answer you, because the form creates no account and gives us no other way to reach you, and your name is so that a reply can address you by it. The message is free text, so what is in it is what you choose to put in it |
| Theme preference | Written in your browser when you use the light and dark toggle | Voluntary. It stays on your device and is not sent to us |
When you submit either form on our website, your browser sends it to our own server, which sees your device’s IP address in the same way that any web server sees the address of a device connecting to it. We use it to limit how often a form can be submitted from one address, and we hold it in that server’s memory for that purpose alone. When a limit is reached, we write a short scrambled code derived from the address to our server log, so that we can see one device repeating without recording which device it is; the code is meaningless once the server restarts. The address itself is not written to our logs, it is not written to the record that holds your early-access details or to the record that holds your message, and neither record has a field for it. The contact form also carries two checks against automated submission, being a field that is kept out of sight and that a person never fills in, and a check in your browser that the form was not completed faster than a person could complete it; neither of them puts anything in the record of your message. A message that reaches us with that hidden field filled in is discarded: it is not stored and it is not answered. The check in your browser holds a submission back for a moment and never discards one. The address you give us in a message is used to answer it, it does not join our early-access list, and we do not send you marketing because you wrote to us.
We do not collect photographs, images or video at any stage. We do not collect biometric information, face data, identity documents, criminal record information, payment or billing information, advertising identifiers, or analytics or attribution data. We do not offer social sign-in. We do not verify your phone number, your identity or your age.
5. Calls
Blind dates are audio calls of up to four minutes, and you and the other person are anonymous to each other. We do not record, transcribe, listen to or analyse call audio, and we do not moderate the content of calls. The app has no text chat between users.
Audio travels directly between the two devices where the network allows it. Where a direct connection cannot be established, audio is relayed through a server we operate, and that server handles the audio in transit and both participants’ IP addresses. By default the app uses a public STUN server operated by a third party to work out how to connect, and that discloses your device’s IP address to the operator of that server. Our call server records the IP address that connects to it.
6. Why we process your information and our legal grounds
| Purpose | Information used | POPIA section 11 justification | UK GDPR Article 6 basis |
|---|---|---|---|
| Creating and operating your account and signing you in | Name, email address, phone number, password hash | 11(1)(b) performance of our contract with you | 6(1)(b) contract |
| Verifying your email address | Email address, one-time code | 11(1)(b) | 6(1)(b) |
| Placing you in the Mixer queue and connecting blind dates | Account record, availability, call records | 11(1)(b) | 6(1)(b) |
| Connecting the two devices and relaying audio where a direct connection fails | IP addresses, connection quality readings | 11(1)(b) | 6(1)(b) |
| Recording the outcome of a call and applying the more cautious of the two choices | Decisions, whether you would speak again | 11(1)(b) | 6(1)(b) |
| Exchanging Smart Match Cards when two people are both Interested | Display name, contact handles | 11(1)(b) | 6(1)(b) |
| Building the profile that supports matching | Profile fields that are not special personal information | 11(1)(b) | 6(1)(b) |
| Processing the profile fields that are special personal information | Sexuality, ethnicity, culture, religion | 11(1)(a) consent, read with section 27(1)(a) | 6(1)(a) consent, read with Article 9(2)(a) |
| Scoring the personality assessment and computing trait scores daily | Assessment answers, response times, sitting identifiers | 11(1)(a) consent, read with section 27(1)(a) | 6(1)(a) consent, read with Article 9(2)(a) |
| Producing a personality report when you ask for one | Band words only | 11(1)(a) consent | 6(1)(a) |
| Improving future matching, as described in section 10 | One record per call holding the outcome and both people’s trait scores | 11(1)(a) consent | 6(1)(a) |
| Recording your location once | Latitude and longitude | 11(1)(a) consent | 6(1)(a) |
| Keeping the service safe, investigating reports and dealing with abuse | Feedback, call records, safety reports, IP addresses, server logs | 11(1)(d) protection of a legitimate interest of yours, and 11(1)(f) our legitimate interests | 6(1)(f) legitimate interests |
| Diagnosing faults and keeping the service working | Error reports, server logs, connection quality readings | 11(1)(f) our legitimate interests | 6(1)(f) |
| Sending service messages, including verification, call and match notifications | Email address, push token | 11(1)(b) | 6(1)(b) |
| Holding your early-access details, placing you in a cohort in which people can be matched with each other, telling you when your cohort is admitted, and sending you early-access updates | Email address, first name, age range, gender, sexuality | 11(1)(a) consent | 6(1)(a) |
| Reading a message you send us through the contact form on our website, and answering it | Your name, your email address, your subject if you gave one, and your message | 11(1)(f) our legitimate interests, and 11(1)(b) performance of our contract with you where the message is about that contract | 6(1)(f) legitimate interests, and 6(1)(b) contract where the message is about your account or another agreement with us |
| Complying with legal obligations and responding to lawful requests | Whatever the obligation requires | 11(1)(c) compliance with an obligation imposed by law | 6(1)(c) legal obligation |
| Establishing, exercising or defending a legal claim | Records relevant to the claim | 11(1)(f) our legitimate interests | 6(1)(f) |
Where we rely on our legitimate interests, those interests are keeping users safe, preventing abuse of the service, keeping the service running, answering the people who write to us, and protecting our legal position. We do not ask for your consent to answer a message: you wrote to us and asked for an answer, and treating that as consent would mean that withdrawing it had to stop us replying. Where your message is about your account or another agreement with us, answering it is part of performing that agreement, and that is the ground we rely on instead. You may object to that processing under section 18 of this policy.
7. Special personal information
Some of what we collect is special personal information under section 26 of POPIA and special category data under Article 9 of the UK GDPR. This includes your sexuality, which relates to sex life, your ethnicity and culture, which relate to race or ethnic origin, and your religion, which relates to religious belief. Your sexuality is asked for twice and the first time is before you have an account: the early-access form on our website asks for it, because a cohort is only workable if the people in it can be matched with each other. Some items in the personality questionnaires elicit political opinion, religious belief and information about mood and mental health, and answers to those items are health and belief data. The contact form on our website asks for none of this, but its message box is free text, so a message can reach us holding any of it, and it can hold personal information about somebody other than you. We do not ask for it. We use it to answer the message and for nothing else, except where section 6 gives us another ground for it, which is keeping people safe, complying with an obligation imposed by law, or a legal claim. Anyone may report a safety concern to us, and a message that reports one is dealt with under section 10 of our Terms of Use rather than only answered.
Section 26 of POPIA prohibits the processing of special personal information unless an exception in section 27 applies. We rely on section 27(1)(a), which is your consent. Under the UK GDPR we rely on your explicit consent under Article 9(2)(a). That is the ground for the profile fields and the assessment answers, where we ask the question and you answer it.
It is not the ground for whatever a message happens to hold. We do not ask for special personal information in a message, we do not ask you to consent to it, and we do not treat your having written it as consent, for the same reason section 6 gives about answering you at all. So please do not put your own or another person’s special personal information in a message. Where it reaches us anyway, we use it to answer the message and for nothing else, except where section 6 gives us another ground, and we delete it when we delete the message.
You may withdraw that consent at any time by emailing [[PRIVACY_EMAIL]]. Withdrawal does not affect processing carried out before you withdrew. If you withdraw consent we stop processing the affected information, and where we hold no other ground to keep it we delete it, which may mean we can no longer provide matching or personality features to you.
8. The personality assessment and report
The assessment uses two public-domain International Personality Item Pool questionnaires, a 50-item Big Five set and a 300-item set. For each item we store the value you chose from 1 to 5, the date and time, a sitting identifier and how long you took to answer.
Answers that our checks judge to be careless, because they were given too quickly or because the same value was given down a whole trait, are removed from scoring, kept in a separate archive and the question is asked again. Trait scores are recomputed daily.
The personality report is produced only when you ask for it. When you do, we send band words to [[LLM_PROVIDER]], for example “Extraversion: Low”. We do not send your name, phone number, email address, raw scores, identifiers or individual answers. Our own code adds your identity to the text after the provider returns it. We can switch the provider off entirely, in which case reports are not produced.
9. How matching works, and automated decision-making
Only the Mixer path is built. Mixer pairs whoever is available at that moment, first in and first out. It does not filter on gender, sexuality, who you are interested in, age, language, location or personality. After a call, each person chooses Interested, Talk again or Pass, and the more cautious of the two choices is applied automatically. You may have up to three calls with the same person within a two-week window. A Match occurs only when both people choose Interested, and it exchanges Smart Match Cards.
Automated processing is used to apply the more cautious choice, to compute trait scores daily, to flag careless assessment answers, and to order the queue. We do not use automated processing to profile you for advertising, to assess your creditworthiness, or to decide whether you are dangerous or trustworthy.
Section 71 of POPIA and Article 22 of the UK GDPR give you the right not to be subject to a decision based solely on automated processing that has legal effects for you or affects you to a similar significant degree. If you believe a decision in the service has affected you in that way, email [[PRIVACY_EMAIL]] and we will have a person review it, explain the decision and correct it if it is wrong.
10. Using call records to improve matching
We keep one record per call, holding the outcome of the call and both people’s trait scores, and we use those records to improve how future matches are made. You give consent for this by accepting our Terms of Use. A call record is used only while both participants currently consent, so if either person withdraws, the record stops being used.
You may withdraw this consent at any time by emailing [[PRIVACY_EMAIL]]. Withdrawal removes your whole history from the training set immediately. Withdrawal does not affect the lawfulness of processing carried out before you withdrew.
11. Who receives your information
| Recipient | Category | What they receive |
|---|---|---|
| [[HOSTING_PROVIDER]] | Operator, processor | Hosting of the app servers, the database and server logs, in [[HOSTING_REGION]] |
| Resend | Operator, processor | Your email address and the content of transactional email we send you. If you join early access, that includes your first name, because the confirmation email addresses you by it. If you send us a message through the contact form, Resend carries that message to us, so it receives your name, your email address, the subject if you gave one, and everything you wrote |
| [[PUSH_PROVIDER]] | Operator, processor | Your push token and notification content. Delivery reaches Google for Android devices and Apple for iOS devices |
| [[ERROR_TRACKING_PROVIDER]] | Operator, processor | Error reports sent by the released app |
| [[LLM_PROVIDER]] | Operator, processor | Band words only, when you ask for a personality report |
| Our own database | Our own infrastructure | Everything you submit on either form on our website. From the early-access form: an email address, a first name, an age range, a gender and a sexuality. From the contact form: your name, your email address, a subject if you give one, and your message, which we also send by email to one address of our own so that we notice it has arrived. It is stored in the same database as the app’s own records, hosted by [[HOSTING_PROVIDER]], and no form service receives it. The only outside company that sees any of it is Resend, which carries the emails described in its own row above. Your sexuality is special personal information, and holding it is covered by the consent described in section 7 |
| A relay server we operate | Our own infrastructure | Call audio in transit and both participants’ IP addresses, only where a direct connection fails |
| A public STUN server operated by a third party | Independent recipient | Your device’s IP address |
| The other user | Independent recipient | Your Smart Match Card, and only when you and that person both choose Interested |
| Law enforcement, regulators, courts, and our legal and professional advisers | Independent recipients | Information we are required or permitted by law to disclose, or that we need to establish, exercise or defend a legal claim |
| A buyer or successor | Independent recipient | Personal information transferred as part of a sale, merger or restructuring of our business, on the same terms as this policy |
Operators process personal information only on our documented instructions and under a written contract that requires them to keep it secure, as section 21 of POPIA and Article 28 of the UK GDPR require.
We do not sell personal information. We do not share personal information for advertising, and there are no advertising identifiers, advertising partners, analytics software or attribution software in the app or on the website.
12. Sending information outside South Africa and outside the United Kingdom
Our service providers may store or process personal information outside South Africa. Section 72 of POPIA allows a cross-border transfer where the recipient is subject to a binding agreement or law that provides an adequate level of protection with principles for reasonable processing substantially similar to POPIA, where the transfer is necessary to perform our contract with you, or where you have consented to it. We rely on those grounds, and we put written data transfer terms in place with our operators.
If you are in the United Kingdom, note that the United Kingdom has not made an adequacy decision in respect of South Africa. Transfers of your personal information to South Africa, and to any other country without a United Kingdom adequacy decision, therefore rely on an appropriate safeguard under Article 46 of the UK GDPR, which for us is the International Data Transfer Agreement or the United Kingdom Addendum to the European Commission’s standard contractual clauses, supported by a transfer risk assessment. You may request a copy of the safeguard from [[PRIVACY_EMAIL]].
13. How long we keep your information
| Information | Retention period |
|---|---|
| Account and profile, including your Smart Match Card | [[RETENTION_ACCOUNT]] |
| Accounts with no activity | [[RETENTION_INACTIVE]] |
| Call records, decisions, feedback and connection quality readings | [[RETENTION_CALL_METADATA]] |
| Server logs, call server logs and error reports | [[RETENTION_LOGS]] |
| Safety reports and the material gathered to assess them | [[RETENTION_SAFETY]] |
| Support correspondence, including a message you send us through the contact form on our website | [[RETENTION_SUPPORT]] from the day we receive it. We remove a message sooner if you ask us to. Nothing on our side deletes a message automatically when that period ends, so until we build that, the period is the rule we work to and not one the system applies for us |
| Personality assessment answers, including the archive of answers judged careless | For as long as your account exists |
| Early-access details, being the email address, first name, age range, gender and sexuality you submit on the website | Until you remove them or ask us to remove them, or you withdraw the consent described in section 7, which has the same effect because consent is the only ground we hold them on. Our early-access email normally carries a link to a page where you can remove them yourself, and doing so deletes the record immediately and cannot be undone; where that link is not in your email, section 16 explains how to ask us instead. Creating an account does not remove them, and neither does unsubscribing from our early-access email: in both of those cases the record is marked and kept. An outer period, after which early-access details are deleted whether or not anyone asks, is under review and is not yet set |
| Period between a deletion request and deletion completing | [[GRACE_PERIOD]] |
| Backups | Until the backup ages out of the backup cycle |
We set these periods by asking how long the information is needed for the purpose it was collected for, how long the law requires us to keep it, how long a claim could still be brought, and whether it is needed to keep users safe. When a period ends we delete the information or remove the identifiers that link it to you.
14. Deleting your account, and what survives deletion
There is no deletion function in the app. To delete your account, email [[PRIVACY_EMAIL]] from the email address on the account.
Deletion removes your account, your profile, your Smart Match Card, all your personality assessment answers, the archive of answers judged careless, your trait scores and your rewards.
The following survive deletion.
- One record per call, holding the outcome of that call and both people’s trait scores. Your identifier is removed from that record, and the score vector is kept because the record describes a pair of people and the other person’s information is in it.
- Safety reports, and the material gathered to assess them.
- Connection diagnostics.
- Early-access details you gave on the website. They are held against the email address you submitted rather than against your account, so deleting your account does not reach them. You can remove them yourself using the link in our early-access email where that email carries one, or ask us to remove them as well in the same email.
- Messages you sent us through the contact form on our website. They are held against the email address you gave in the message rather than against your account, so deleting your account does not reach them. Ask us to remove them in the same email and we remove them as well.
- Backups, until they age out of the backup cycle.
15. Security and what we do if information is compromised
We take appropriate, reasonable technical and organisational measures to secure personal information, as section 19 of POPIA and Article 32 of the UK GDPR require. Passwords are stored only as bcrypt hashes and cannot be read by us. Call audio is not recorded, so no recording exists to be stored, lost or disclosed. Only band words are sent to [[LLM_PROVIDER]]. We limit access to personal information to the people who need it to do their work, and our operators are bound by contract to keep it secure. No system is completely secure, and we cannot guarantee that a compromise will never occur.
If personal information is accessed or acquired by an unauthorised person, section 22 of POPIA requires us to notify the Information Regulator and each affected person as soon as reasonably possible after we discover the compromise, unless the identity of the affected person cannot be established. The notification will describe what happened, the likely consequences, what we are doing about it, and what you can do to protect yourself. If you are in the United Kingdom we also notify the Information Commissioner’s Office within 72 hours of becoming aware of a breach where it is likely to result in a risk to people’s rights and freedoms, and we notify you directly where the risk is high.
16. Direct marketing
We do not send advertising and we do not share your information with anyone for advertising purposes. Messages we send about your account, a call, a Match, verification or a change to these documents are service messages and not direct marketing.
Section 69 of POPIA prohibits electronic direct marketing to a person who is not our customer unless that person has consented. Under the POPIA Regulations, as amended on 17 April 2025, a failure to opt out does not amount to consent, and consent must be given in the prescribed manner. We ask for consent no more than once, as section 69(2) requires. Where you are already our customer, section 69(3) allows us to market our own similar products or services to you using contact details obtained in the course of that relationship, and every such message gives you a way to object.
If you are in the United Kingdom, regulation 22 of the Privacy and Electronic Communications Regulations applies. We send electronic marketing only with your consent, or under the soft opt-in where we obtained your details in the course of a sale or negotiations for a sale of a similar product or service and gave you the opportunity to refuse at that point and in every message.
Every email we send you about early access carries an unsubscribe link. Opening the link shows a page with a single button, and pressing that button is what unsubscribes you: following the link on its own changes nothing, so a link opened by a mail scanner or a preview pane cannot unsubscribe you by accident. Unsubscribing stops the early-access emails. It does not delete your early-access details, which are kept and marked as unsubscribed.
That email also carries a second link, to a page where you can see the details you gave us, change them, stop the emails, or remove the details altogether. We send that link with every early-access email we can: it is missing only where we joined you before the page existed, or where a setting on our side was wrong when your email went out. The link contains a code that identifies your record, and holding that code is what lets the page act on it, so treat the email as you would any other message that can reach your information. Removing your details there deletes the record immediately and cannot be undone, and every link in every early-access email we have sent you stops working. Opening the page without a valid code shows our page-not-found page. If your email has no such link, or you no longer have the email, write to [[PRIVACY_EMAIL]] and section 18 sets out what happens then. You are not left without a way to reach your details either way.
You may stop marketing at any time by emailing [[PRIVACY_EMAIL]], and we do not charge for that.
17. Children and the age limit
The service is for people aged 18 and over only. Age is self-declared at onboarding, and we do not run identity or age verification.
If we learn that a user is under 18, we suspend the account immediately, delete the account and the personal information in it, and keep only what we must keep to comply with the law, to record the safety decision, or to prevent the person registering again. If you believe a user is under 18, email [[SAFETY_EMAIL]]. If you are a parent or guardian and you believe your child has an account, email [[PRIVACY_EMAIL]] and we will deal with it as an urgent request.
18. Your rights
You have the following rights.
- Access. You may ask us to confirm whether we hold personal information about you and to give you a record of it, together with the identity of third parties who have had access to it. This is section 23 of POPIA and Article 15 of the UK GDPR.
- Correction. You may ask us to correct information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained. This is section 24 of POPIA and Article 16 of the UK GDPR.
- Deletion. You may ask us to delete information we are no longer authorised to keep, and to delete your account. This is section 24 of POPIA and Article 17 of the UK GDPR.
- Objection. You may object, on reasonable grounds, to processing that we base on our legitimate interests or on the protection of your legitimate interests. This is section 11(3) of POPIA and Article 21 of the UK GDPR.
- Direct marketing. You may object to direct marketing at any time. This is section 69 of POPIA and Article 21(2) of the UK GDPR.
- Automated decision-making. You may ask for human review of a decision based solely on automated processing that has legal effects for you or affects you to a similar significant degree. This is section 71 of POPIA and Article 22 of the UK GDPR.
- Withdrawal of consent. Where we rely on your consent, you may withdraw it at any time, and withdrawal does not affect processing carried out before you withdrew. This is section 11(2)(b) of POPIA and Article 7(3) of the UK GDPR.
- Restriction. If you are in the United Kingdom, you may ask us to restrict processing while a dispute about accuracy or about our legitimate interests is resolved. This is Article 18 of the UK GDPR.
- Portability. If you are in the United Kingdom, you may ask for the personal information you gave us that we process by automated means on the basis of consent or contract, in a structured, commonly used and machine-readable format, and you may ask us to send it to another controller where that is technically feasible. This is Article 20 of the UK GDPR.
For your early-access details only, you may not have to write to us: where our early-access email to you carries the link described in section 16, it opens a page where you can correct them, stop the emails, or delete them yourself. Where it does not, or where you no longer have the email, the rest of this section applies as it does to everything else. That page reaches only the details you gave on the website, and nothing in your app account.
To exercise any of these rights, email [[PRIVACY_EMAIL]] and say what you want us to do. We may ask you for enough information to satisfy ourselves that you are the account holder before we act, and we ask for no more than we need for that purpose. We do not charge for making a request or for our response.
We respond as soon as reasonably practicable. If you are in the United Kingdom we respond within one month of receiving your request, and we may extend that by up to two further months where the request is complex or where you have made several requests, in which case we tell you within the first month and explain why. If we cannot do what you ask, we tell you why and how to take it further.
19. Complaints
If you are unhappy with how we handle your personal information, email [[PRIVACY_EMAIL]]. We acknowledge your complaint and respond within [[COMPLAINTS_TURNAROUND]]. You do not have to complain to us before approaching a regulator.
You may complain to the Information Regulator of South Africa. Its offices are at Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191. Its telephone number is 010 023 5200. Complaints are sent to POPIAComplaints@inforegulator.org.za and are made on Form 5 prescribed under the POPIA Regulations, which is available from the Regulator’s website.
If you are in the United Kingdom, you may complain to the Information Commissioner’s Office, which is the United Kingdom’s supervisory authority for data protection, and whose website is ico.org.uk. You may also complain to the Information Regulator of South Africa, and you may take the matter to a court.
20. Changes to this policy
We may change this policy, for example when we build a feature, change a service provider or respond to a change in the law. The date at the top of this document shows when it was last updated.
If a change materially affects your rights or how we process your personal information, we tell you before it takes effect by email to the address on your account, by a notice in the app, or by both. Where a change requires your consent, we ask for it, and we do not rely on your silence as consent. If you do not accept a change, you may stop using the service and ask us to delete your account under section 14.