Privacy Policy

1. About us

1. DigiDeeds Limited is a public company registered and operating in accordance with the laws of the Republic of South Africa.

2. About this privacy policy

1. The purpose of this policy ("Privacy Policy") is to communicate how we process personal information relating to identifiable natural persons or existing juristic persons ("Personal Information"), and to share certain information required in terms of the Protection of Personal Information Act 4 of 2013 ("POPIA").
2. This Privacy Policy describes how we process Personal Information in providing digital identity and property verification, mapping, certification, and reporting services (the "Services") through the DigiDeeds mobile application (the "Application") and also applies to the use of our informational website located at https://digideeds.net/ (the "Website").
3. We may update this Privacy Policy from time to time by publishing a revised version on our Website and Application, which shall take effect on the date of publication. Please be sure to keep yourself up to date with our latest Privacy Policy.
4. This Privacy Policy should be read with any agreements, terms, policies and the like published by us in relation to our Services. To the extent that any other binding document may conflict with our Privacy Policy, the former shall prevail.
5. Should you have any questions about this Privacy Policy or how we process your Personal Information, please contact us at [email protected] (the "Privacy Mailbox").

3. The types of Personal Information we process and how we obtain it

1. Please refer to Annexure A for a detailed description of the categories of Personal Information we process, including the purposes for which it is collected and the legal basis for such processing.
2. Your supply of Personal Information to us is entirely voluntary and you are not compelled to do so under any law. We do however require certain information from you in order to render the Services to you, as set out under Annexure A.

4. Your right to update, correct, or delete your information

1. You can update, correct, or delete Personal Information relating to your account with us by logging into your account on the Application at any time.
2. If you wish to update, correct, or delete other Personal Information that you cannot update, correct, or delete on your account on the Application, you may contact us at our Privacy Mailbox.

5. Your right to object to the processing of your Personal Information

1. You have the right to object to the processing of your Personal Information where we are relying on your legitimate interests, our legitimate interests, or those of a third party to process the Personal Information.
2. You may also object generally to the processing of your Personal Information on reasonable grounds relating to your particular situation, for instance, where such processing negatively impacts your fundamental rights and freedoms.
3. If you wish to object to the processing of your Personal Information as described under this heading, kindly contact us at our Privacy Mailbox.

6. Storage and security of your Personal Information

1. We implement technical and organisational measures, in compliance with the requirements of applicable law, to ensure that the Personal Information in our possession remains confidential and secure against unauthorised or unlawful processing, and against accidental loss, destruction, or damage. Such measures include:
   1. restricting access to Personal Information to authorised personnel only, based on a need-to-know basis;
   2. the use of password protection and access controls on systems that process or store Personal Information;
   3. encrypting Personal Information during transmission over public networks;
   4. regular backups of Personal Information to prevent data loss;
   5. the use of reputable third-party hosting and infrastructure providers who implement industry-standard security controls;
   6. maintaining firewalls and antivirus or endpoint protection software on systems used in our operations;
   7. logging and monitoring of system access to detect and respond to security events; and
   8. ensuring that staff with access to Personal Information are bound by confidentiality obligations and receive basic data protection training.
2. You acknowledge and agree however that there are inherent risks to the security of data in the use of electronic services. We accordingly do not guarantee that your data cannot ever be compromised, and you accept this risk by using our Application.
3. You are responsible for keeping your PIN, password and other credentials required to access the Application confidential. Please do not share your password with anyone.
4. We will keep your Personal Information for only a reasonable amount of time, to enable us to use it for the purposes described in this Privacy Policy and in accordance with applicable law.

7. How we share your Personal Information

1. Subject to compliance with the Protection of Personal Information Act, 4 of 2013 ("POPIA"), you hereby expressly consent to the collection, processing, verification, use and disclosure of your Personal Information by us and our authorised service providers, agents and partners, to the extent reasonably necessary to render the Services to you, including disclosure to:
   1. municipalities and government partners for purposes of service delivery, recognising property ownership and proof of address;
   2. cloud infrastructure and hosting providers for secure data storage and operational hosting of the Application;
   3. third-party service providers in order to validate and supplement location data;
   4. credit bureaus, banks, insurers, financial institutions and other authorised third parties, including but not limited to Absa Bank Limited, Nedbank Limited, Investec Bank Limited, African Bank Limited, Discovery Bank, Tyme Bank Limited, Capitec Bank Limited, Standard Bank of South Africa Limited, FirstRand Bank Limited, Experian, MyData, TransUnion, or any other current or future registered Financial Service Providers, for purposes of identity verification, due diligence, risk assessment, affordability assessments, fraud prevention, credit profiling and related verification services;
   5. community members (neighbours) involved in the address verification process, who will be shown your photograph and a photograph of your property to confirm its location
   6. third party service providers in order to try to supply you with products and services.
2. Some of our service providers may be located outside of South Africa, and accordingly your Personal Information may be transferred outside of South Africa. We will only do so in accordance with the requirements for the lawful transfer of Personal Information outside of South Africa, as set out in POPIA.
3. We use a cloud hosting and data storage provider located within the European Economic Area ("EEA"). Information processed within the EEA is subject to the level of protection provided by the General Data Protection Regulation ("GDPR").

8. Disclosures

1. On rare occasions, we may be required to disclose your Personal Information because of legal or regulatory requirements. In such instances, we may disclose your Personal Information as required in order to comply with our legal obligations, including complying with court orders, warrants, subpoenas, service-of-process requirements, and/or discovery requests.
2. We may also disclose information about our users to law enforcement officers or others, in the good faith belief that such disclosure is reasonably necessary to enforce our terms of use or this Privacy Policy, or respond to legal claims that any content violates the rights of third parties, or to protect our intellectual property rights or our personal safety or the personal safety of our users or the general public.

9. How to contact the Information Regulator

1. Section 74(1) of POPIA provides that any person may submit a complaint to the Regulator in the prescribed manner and form alleging interference with the protection of the Personal Information of a data subject.
2. Contact information of the Information Regulator:
    

   Information Officer Appointment in progress
     

   Postal address
   JD House
   27 Stiemens Street
   Braamfontein
   Johannesburg
   2001

   Telephone number +27 (0) 10 023 5200
   Fax number 086 500 3351
   Email address [email protected]
   Website https://eservices.inforegulator.org.za/

Annexure A: Categories of Personal Information and processing purposes

1. Information we collect directly from our members

2. Information we collect about non-members (neighbours)