Legal
Privacy Policy
Effective date: 1 May 2026
1. Who We Are
EmergiFund (Pty) Ltd (registration number [Registration Number]) is the responsible party for your personal information as defined under POPIA.
Information Officer: [Information Officer Name]
Contact: [privacy@emergifund.co.za] | 066 266 3848
2. Personal Information We Collect
We collect the following categories of personal information:
Identity information
Full name, ID number, date of birth, nationality, a copy of your identity document or passport.
Contact information
Mobile phone number (WhatsApp-enabled), email address, residential address.
Financial information
Bank account details, bank name, account number, branch code, debit order mandate information, income details, payslips or bank statements.
Transaction information
Records of fuel or electricity access events, repayment history, subscription status.
Technical information
IP address, browser type, device information, and usage data collected when you visit our website.
3. Why We Collect Your Information
We process your personal information for the following purposes:
- To assess and process your subscription application
- To provide you with access to fuel and electricity resources
- To administer your subscription and repayment schedule
- To collect subscription fees and repayment instalments via debit order
- To communicate with you about your account via WhatsApp, SMS, or email
- To comply with applicable legal and regulatory obligations
- To detect, prevent, and investigate fraud or misuse of our services
- To improve our website and services
4. Legal Basis for Processing
We process your personal information on the following grounds under POPIA:
- Contract: Processing necessary to fulfil our service agreement with you
- Legal obligation: Processing required to comply with applicable laws
- Legitimate interest: Processing for fraud prevention and service improvement
- Consent: Where we have obtained your specific consent
5. Sharing Your Information
We may share your personal information with:
- Payment and collection service providers — to process debit orders and collect repayments
- Fuel and electricity suppliers — to facilitate access to resources on your behalf
- Identity verification providers — to verify your identity documents
- Cloud service providers — our infrastructure and data is hosted on Supabase (US-based servers)
- Legal and regulatory authorities — where required by law or court order
We do not sell your personal information to third parties for marketing purposes.
6. Cross-Border Transfers
Your personal information may be stored on servers located outside South Africa (including in the United States) through our cloud service provider, Supabase. We ensure that appropriate safeguards are in place to protect your information in line with POPIA requirements for cross-border transfers.
7. Data Retention
We retain your personal information for as long as necessary to fulfil the purposes set out in this policy, or as required by applicable law. In practice:
- Active subscriber records: retained for the duration of your subscription plus 5 years
- Financial transaction records: retained for a minimum of 5 years in compliance with applicable financial regulations
- Identity documents: retained for the duration of the relationship plus 5 years
- Website usage data: retained for up to 12 months
8. Your Rights Under POPIA
As a data subject under POPIA, you have the right to:
- Access: Request a copy of the personal information we hold about you
- Correction: Request correction of inaccurate or incomplete personal information
- Deletion: Request deletion of your personal information (subject to legal retention obligations)
- Objection: Object to the processing of your personal information
- Withdraw consent: Withdraw any consent previously given
- Lodge a complaint: Lodge a complaint with the Information Regulator of South Africa
To exercise any of these rights, contact our Information Officer at [privacy@emergifund.co.za].
Information Regulator contact details:
Website: www.inforegulator.org.za
Email: inforeg@justice.gov.za
9. Security
We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. These measures include:
- Encrypted data storage and transmission (HTTPS/TLS)
- Row-level security controls on our database
- Access controls limiting who can view personal data
- Regular security reviews
No system is completely secure. If you suspect a security incident involving your data, contact us immediately.
10. Cookies and Website Tracking
Our website uses essential cookies required for the site to function (including authentication session cookies). We do not currently use advertising or tracking cookies.
You can control cookie settings through your browser. Disabling essential cookies may affect your ability to use certain features of the site.
11. Changes to This Policy
We may update this privacy policy from time to time. We will notify you of material changes via WhatsApp or email at least 30 days before they take effect. The current version will always be available on our website.
12. Contact Us
For privacy-related queries, requests, or complaints:
- Information Officer: [Information Officer Name]
- Email: [privacy@emergifund.co.za]
- WhatsApp / Phone: 066 266 3848
⚠️ This document is a working draft and must be reviewed and approved by a qualified South African attorney before publication. Placeholder fields marked in [brackets] must be completed before going live.