Privacy Policy

1.1[COMPANY NAME] is the responsible party, as that term is used in the Protection of Personal Information Act 4 of 2013 ('POPIA'), for the personal information described in this Policy.

1.2Our Information Officer can be reached at [INFORMATION OFFICER EMAIL] for any question about this Policy, and for any request to exercise the rights described in Section 8.

1.3For general support that does not concern personal information, please contact us at [SUPPORT EMAIL].

2.1We process personal information in accordance with POPIA. Where the Electronic Communications and Transactions Act 25 of 2002 or the Consumer Protection Act 68 of 2008 applies to our dealings with you, we comply with those Acts as well.

2.2We rely on the following grounds for processing your personal information: your consent, given when you create an account and when you choose to share financial or other information with the Platform; the performance of our agreement with you, being the Terms and Conditions of Use; compliance with our legal obligations; and our legitimate interests in operating, securing, and improving the Platform, where those interests are not overridden by your rights.

2.3You are never obliged to share any particular piece of information with INVESTA. Sharing less will reduce how useful the Platform's educational content is to you, but it will not prevent you from using it.

3.1Account information: the name, email address, and authentication details you provide when you register, together with the record of which subscription tier your account holds.

3.2Onboarding information: the answers you give during the introductory conversation that runs before chat is available, which we use to understand your situation well enough to be useful to you.

3.3Your money story: the answers you choose to give to the sixteen questions in the Understand section of the app. Every one of these is optional and each can be skipped, changed, or removed by you at any time.

3.4Conversation content: the messages you send to INVESTA and the responses generated for you. This may include financial information you choose to share, such as income, expenses, debts, goals, or account balances.

3.5Memories: short summaries derived automatically from your conversations, such as a goal you mentioned or a commitment you made, which allow INVESTA to remember your circumstances between conversations rather than starting fresh each time. You can view, edit, and delete these in the app.

3.6Technical information: device type, operating system version, app version, approximate region, crash reports, and similar diagnostic data generated when you use the Platform.

3.7We do not collect your full payment card details. Subscription payments are handled by the app stores and our subscription management provider, and we receive only the status of your subscription, not your card information.

3.8We do not connect to your bank accounts and we do not read your bank statements or transaction feeds. Anything we know about your money is something you have told us.

4.1To provide the Platform: to authenticate you, to maintain your account, and to make the features you have subscribed to available.

4.2To generate educational Content for you: your onboarding answers, money story answers, conversation history, and memories are supplied to the artificial intelligence models that produce INVESTA's responses, so that the educational content you receive reflects your circumstances rather than being generic.

4.3To remember and follow up: to recall what you have told us in earlier conversations, and to send you check-ins and reminders about goals and commitments you have shared, where you have not turned those notifications off.

4.4To operate and improve the Platform: to diagnose faults, monitor performance and reliability, understand which features are used, and improve the quality of the service.

4.5To keep the Platform safe: to detect, investigate, and prevent fraud, abuse, and breaches of our Terms and Conditions of Use.

4.6To comply with the law: to meet our legal, regulatory, and record-keeping obligations, and to establish, exercise, or defend legal claims.

4.7We do not sell your personal information. We do not share it with advertisers, and we do not use your conversations to target advertising at you.

6.1We share personal information with operators who process it on our behalf, under written agreements that require them to process it only on our instructions and to keep it secure. We share it by category of service, as follows.

6.2Artificial intelligence providers, to generate the coaching responses and educational content described in Section 5.

6.3An authentication provider, which manages account creation, sign-in, and credential security on our behalf.

6.4Subscription and payment providers, including the app stores, which process your payment and tell us whether your subscription is active. They do not share your full payment details with us.

6.5Hosting, database, and infrastructure providers, which store the Platform's data and run the services that deliver it to you.

6.6Analytics, monitoring, and error-reporting providers, which help us understand faults and reliability problems.

6.7We may also disclose personal information where we are required to do so by law, by a court order, or by a competent regulator, or where disclosure is necessary to protect our rights, your safety, or the safety of others.

6.8If our business is sold, merged, or otherwise transferred, personal information may transfer as part of that transaction. We will inform you before your information becomes subject to a materially different privacy policy.

7.1Some of the operators described in Section 6, in particular our artificial intelligence, authentication, and hosting providers, process personal information outside the Republic of South Africa.

7.2Where we transfer personal information across a border, we do so in accordance with section 72 of POPIA, relying on the agreements we have in place with those operators, which impose data protection obligations substantially similar to those under POPIA, and on your consent where that is the applicable ground.

7.3You may ask our Information Officer for further detail about the safeguards applied to a particular transfer.

8.1Under POPIA you have the right to be told what personal information we hold about you and to be given access to it; to ask us to correct or delete information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully; to object, on reasonable grounds, to our processing of your personal information; to withdraw a consent you have given, without affecting the lawfulness of processing carried out before the withdrawal; and to complain to the Information Regulator.

8.2You can exercise several of these rights directly in the app: your money story answers can be changed or cleared in the Understand section, your memories can be edited or deleted in the Memories section, and your account can be closed from your account settings.

8.3For anything else, contact our Information Officer at [INFORMATION OFFICER EMAIL]. We will respond within a reasonable period and in any event within the period required by POPIA. We may ask you to verify your identity before we act on a request.

8.4You may lodge a complaint with the Information Regulator of South Africa. Its contact details are published at inforegulator.org.za. We would appreciate the chance to resolve your concern first.

9.1We keep your account information, money story answers, conversations, and memories for as long as your account is open, because the value of the Platform to you depends on it remembering what you have told it.

9.2When you close your account, we delete or anonymise your personal information within a reasonable period, except where we are required to retain certain records by law, or where we need to retain limited information to resolve a dispute or enforce our agreements.

9.3Backups are retained on a rolling cycle and are overwritten in the ordinary course. Information deleted from the live service may persist in backups for a limited period before it is overwritten.

10.1We take appropriate, reasonable technical and organisational measures to protect personal information against loss, damage, and unlawful access, as required by section 19 of POPIA. These include encryption of data in transit, access controls limiting who on our side can reach production data, and the use of established infrastructure providers.

10.2No online service can promise perfect security, and we do not make that promise. What we can commit to is taking security seriously and being honest with you when something goes wrong.

10.3If a security compromise affects your personal information, we will notify you and the Information Regulator as required by section 22 of POPIA.

10.4You are responsible for keeping your account credentials confidential. Please tell us at [SUPPORT EMAIL] immediately if you suspect that someone else has accessed your account.

11.1INVESTA is built for young adults and is not directed at children under the age of eighteen. Where a child uses the Platform, POPIA requires the consent of a competent person, ordinarily a parent or guardian, and the eligibility requirements in our Terms and Conditions of Use apply.

11.2If you believe that a child has provided personal information to us without the necessary consent, please contact our Information Officer at [INFORMATION OFFICER EMAIL] and we will delete it.

12.1This website is an informational site. It has no login, no account area, and no chat. It does not set advertising or tracking cookies, and it does not build a profile of you.

12.2The mobile application uses local device storage to keep you signed in and to remember your preferences between sessions. This is not shared with third parties for advertising purposes.

12.3If we introduce analytics on this website in future, we will update this Policy and, where the law requires it, ask for your consent before setting any non-essential cookie.

13.1We may update this Policy to reflect changes to the Platform, to the operators we use, or to legal and regulatory requirements. Where a change is material, we will give you reasonable notice by email or through an in-app notification before it takes effect.

13.2The version in force at any time will be published here together with its effective date.

If you have any questions about this Policy, or wish to exercise any of the rights described in Section 8, please contact us at:

[COMPANY NAME]

[PHYSICAL ADDRESS]

Email: [SUPPORT EMAIL]

Information Officer (POPIA queries): [INFORMATION OFFICER EMAIL]