Important notice. This Privacy Policy forms part of your agreement with CommunityPulse when you create an account, access our website, mobile applications, or otherwise use services we operate (collectively, the “Services”).
By registering for, accessing, or using the Services, you acknowledge that you have read, understood and agree to this Privacy Policy. If you do not agree, you must not use the Services.
This Policy is intended to meet transparency obligations under applicable law, including the Protection of Personal Information Act 4 of 2013 (“POPIA”) and other applicable data-protection rules. It does not constitute legal advice to you, and it is not a product specification or description of all Service functionality.
1. Who we are
“CommunityPulse”, “we”, “us” or “our” means the operator of the CommunityPulse Services, including the website https://www.communitypulse.co.za and related mobile applications made available under the CommunityPulse brand.
Privacy enquiries: privacy@communitypulse.co.za. General operational enquiries: admin.requests@communitypulse.co.za.
2. Scope
This Policy applies to personal information and related data processed in connection with use of the Services, whether via website, mobile application, or other channels we operate. Depending on the activity, CommunityPulse generally acts as a responsible party (controller) under POPIA. Third parties that provide hosting, authentication, communications, analytics or similar infrastructure may act as operators (processors) on our instructions, or as independent responsible parties for their own services.
The Services enable community-oriented digital interaction. This Policy describes data practices only. It does not list, catalogue or fully describe every function, workflow, role or commercial arrangement available in the product.
3. Definitions
- Personal information / personally identifiable information (PII) means information relating to an identifiable person as contemplated in POPIA (and analogous laws), such as name, contact details, address-related information, account identifiers, and similar data that identifies or can reasonably identify an individual.
- Processing means any operation concerning personal information, including collection, storage, use, analysis, disclosure, retention and destruction.
- User content means information, text, files, images, responses, messages and other materials that you upload, submit, enter or otherwise provide through the Services.
- Non-personal data means data that does not identify you and is not reasonably capable of identifying you, including aggregated, de-identified or anonymised information.
4. Categories of information we process
Depending on how you use the Services, we may process some or all of the following categories of information:
- Account and authentication data — for example email address, credentials (stored in secure hashed form by our authentication provider), and session or security-related metadata.
- Identity and contact data — for example name and contact particulars you choose to provide in your profile or forms.
- Location-related descriptors — for example area, suburb, postal code or similar locality information you provide for community association (we do not require continuous GPS tracking for ordinary use).
- User content and records — information you voluntarily submit while using the Services, including free text, structured form fields, files or media you choose to upload, and records generated by your interactions.
- Technical and operational data — limited device, log, diagnostic and security data reasonably required to operate, secure and improve the Services.
- Communications — messages you send to our support or operational addresses, and service-related notices we send to you.
We process only those categories that are relevant to the interaction you initiate or that are necessary for security, compliance or service delivery. Exact fields collected in any given screen or form are presented in-product at the point of collection.
5. Purposes of processing
We process information for one or more of the following high-level purposes:
- to create, authenticate and administer user accounts;
- to provide, maintain, personalise and improve the Services you request;
- to enable community-related coordination and authorised operational administration within the platform;
- to communicate with you about the Services (including verification, security and service messages);
- to protect the security, integrity and lawful use of the Services;
- to analyse usage and performance in order to develop and improve our offerings;
- to generate non-personal insights and, where permitted under section 11, to use non-personal data for legitimate business purposes;
- to comply with law and lawful requests; and
- to establish, exercise or defend legal claims.
Where POPIA requires a lawful basis, processing is typically based on one or more of: your consent; performance of a contract with you; legitimate interests that are not overridden by your rights (for example security and service improvement); and/or legal obligations.
6. Information you submit to the platform
Default platform permission. By uploading, inserting, submitting, posting or otherwise providing User Content to the Services, you grant CommunityPulse a non-exclusive, worldwide, royalty-free right and licence to host, store, reproduce, process, display, transmit, analyse and otherwise use that User Content as reasonably necessary to operate, secure, moderate, improve and provide the Services, and as otherwise described in this Policy.
You acknowledge that such submission constitutes permission by default for CommunityPulse (and its authorised personnel, authorised platform operators, and technical processors acting on its behalf) to have shared access to read and/or analyse the data you provide, subject to this Policy, access controls and applicable law.
You represent that you have the rights necessary to submit User Content and that your submissions are lawful. You remain responsible for the content you provide. Some content may be visible to other authenticated users or authorised operators where that is inherent in the function you use; visibility is governed by platform rules and your choices, not by unrestricted public disclosure of all data.
7. Cloud hosting, operators and security
The Services are delivered using cloud computing and third-party technology providers for functions such as hosting, databases, file storage, authentication, email delivery and related infrastructure. We select reputable providers and apply technical and organisational measures designed to protect personal information, which may include:
- encryption of data in transit (for example TLS/HTTPS);
- access controls and authentication;
- role-based and least-privilege operational practices;
- segregation of sensitive materials where configured; and
- ongoing security and product improvements.
No method of electronic transmission or storage is completely secure. Absolute security cannot be guaranteed.
8. Third-party infrastructure and limitation of liability
Service-provider environments. You acknowledge that personal information and User Content may be stored or processed on systems controlled by independent cloud and technology service providers. CommunityPulse will take all precautions reasonably possible and appropriate to safeguard user and personal information within its control.
To the maximum extent permitted by applicable law, CommunityPulse shall not be liable for loss, damage, unauthorised access, disclosure, alteration or destruction of data arising from a security incident, outage, vulnerability, misconfiguration or failure of security measures that are controlled exclusively by a third-party service provider (including cloud hosts, authentication providers, storage providers, email providers or network operators), provided that CommunityPulse has not failed to implement reasonable contractual, technical or organisational measures within its own control in relation to such provider.
Nothing in this section excludes or limits liability that cannot lawfully be excluded, including where mandatory law prohibits limitation for gross negligence or wilful misconduct.
9. Sharing of personal information
Personal information is not freely shared. We will not sell, rent or otherwise share your personal information with an unrelated third party for that third party’s independent purposes unless you have given permission, or where we are required or authorised to do so by law.
Without limiting the foregoing, we may disclose personal information where directed or compelled by a court order, warrant, subpoena or other lawful process, or where disclosure is otherwise required or permitted under applicable legislation (including to regulators or law enforcement, or to protect rights, safety or vital interests).
We may also share personal information with:
- Operators / processors who process data on our behalf solely to host and operate the Services;
- Authorised platform users or operators where sharing is necessary for a function you use or for legitimate platform administration under access controls;
- Professional advisers under confidentiality obligations; and
- A successor entity in a merger, acquisition or restructuring, subject to continued protection consistent with this Policy or notice where required.
10. Voluntary disclosures you authorise
From time to time the Services may offer optional opportunities to share information with a named external party (for example a programme, partner or campaign). Where you actively opt in and submit information for that purpose, you instruct us to share the relevant submitted data with that party as described at the point of collection. You should review any additional terms shown before opting in. You may contact us to request withdrawal of consent where technically and legally feasible; withdrawal does not affect processing already lawfully completed.
11. Non-personal and aggregated data
Use of non-personal data. CommunityPulse may collect, analyse, commercialise and otherwise use data derived from polls, surveys, questionnaires, research instruments, data-collection forms, platform metrics and similar methods, provided that such data does not contain personal information, or has been aggregated, de-identified or anonymised so that it no longer identifies you and is not reasonably re-identifiable in the circumstances.
By using the Services, you grant CommunityPulse permission to use such non-personal data for analytics, research, product development, reporting, commercial partnerships and other legitimate business purposes, without further compensation to you, to the extent permitted by law.
We will not re-identify anonymised datasets for the purpose of targeting you as an individual, except where required for security, fraud prevention or legal compliance, or with your consent.
12. Device permissions
The mobile application may request access to certain device capabilities (for example camera or file/photo access) only when needed for a function you choose to use. You may deny or revoke permissions in your device settings; some features may then be unavailable. We do not use device permissions for unrelated background surveillance.
13. Retention
We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to:
- provide the Services while your account remains active;
- meet legal, accounting or reporting requirements;
- resolve disputes and enforce agreements; and
- maintain security and operational records for a reasonable period.
When information is no longer required, we will delete or de-identify it where reasonably practicable. Backups and security logs may persist for a limited additional period.
14. Your rights
Subject to POPIA and applicable law, you may have the right to:
- be informed that personal information about you is collected;
- request access to personal information we hold about you;
- request correction or deletion of inaccurate, irrelevant, excessive or outdated personal information;
- object to processing in certain circumstances;
- withdraw consent where processing is consent-based (without affecting prior lawful processing); and
- lodge a complaint with the Information Regulator (South Africa).
To exercise these rights, contact privacy@communitypulse.co.za. We may need to verify your identity before responding, and will reply within timeframes required by law.
Account closure. You may request closure of your account and deletion of associated personal information by contacting us (or via any in-product control we make available for that purpose). Some information may be retained where we are legally required or permitted to do so.
15. Children
The Services are directed at persons who can lawfully form a binding agreement. We do not knowingly collect personal information from children under 18 without competent person consent where required by law. If you believe a child has provided personal information to us unlawfully, please contact us so we can take appropriate steps.
16. Cross-border processing
Cloud and technology providers may process data in facilities inside or outside the Republic of South Africa. Where personal information is transferred outside South Africa, we will take steps required under applicable transfer rules (including POPIA Chapter 9 where applicable) so far as reasonably practicable given the nature of modern cloud infrastructure.
17. Website technologies
Our website may use essential cookies or similar technologies for session management, security and basic functionality. You can control cookies through your browser; disabling essential cookies may break parts of the website. We do not use website technologies to sell your personal information.
18. Changes
We may update this Privacy Policy from time to time. The “Last updated” date will change when we do. Material changes will be reflected on this page and, where appropriate, by reasonable notice. Continued use of the Services after the effective date of changes constitutes acceptance of the updated Policy, except where mandatory law requires a different form of consent.
19. Contact and complaints
Privacy contact:
privacy@communitypulse.co.za
Website:
https://www.communitypulse.co.za
If you are not satisfied with our response, you may lodge a complaint with the Information Regulator (South Africa) (see the Regulator’s official channels for current contact details).
Key principles (summary only):
- Data may be processed in the cloud with reasonable safeguards; liability for pure third-party infrastructure failures is limited to the extent allowed by law.
- Content and data you submit may be read and analysed by CommunityPulse to operate and improve the Services.
- Personal information is not shared with third parties for their independent purposes without your permission, except under court order or other legal compulsion or permission.
- Non-personal or aggregated data (including from polls, surveys and similar instruments) may be used and monetised by CommunityPulse.