Who we are

Our website address is: https://www.supasub.app.

About our services

Registration: You must create a user account to register for our services through the app, providing accurate information, including your current mobile phone number or email, and, if you change it, inform us so we may deregister the old account. You agree to receive text messages with codes to register for our services. We will use your personal information provided for registration and use of the services in connection with these terms, including the privacy policy.

Age: If you live in a country other than South Africa, you may only use our services if you are the minimum required age in your jurisdiction to sign up for and use the services (unless with consent of your guardian or parent). If you are a South African consumer, you must be 18 years old to use the services and agree to the terms, or do so with the consent of your guardian or parent.

Devices And Software: You will need certain device requirements, software, and data connections to use our services. You will also be required from time to time to manually or automatically download and install updates to our services to enjoy continued use. You consent to us sending you notifications via SUPAsub from time to time, as necessary to provide our services to you.

Fees And Taxes: You are responsible for all carrier data plans, Internet fees, and other fees and taxes associated with your use of our services.

Acceptable use of our services

Our Terms and Privacy Policy: You may only use our services according to these terms, our policies as implemented from time to time and communicated to you, and in accordance with applicable laws. If you violate any of these and it comes to our knowledge, we may take action with respect to your account, including disabling or suspending your account temporarily or permanently and, if we do, you may not create another account without our permission.

Lawful and acceptable use: You must access and use our services only for lawful, authorized, and acceptable purposes. You agree not to use (or assist others in using) our services in ways that: (a) violate, misappropriate, or infringe the rights of SUPAsub, our users, or others, including privacy, publicity, intellectual property, or other proprietary rights; (b) are illegal, obscene, defamatory, threatening, intimidating, harassing, hateful, racially or ethnically offensive, or instigate or encourage conduct that would be illegal or otherwise inappropriate, including promoting violent crimes; (c) involve publishing falsehoods, misrepresentations, or misleading statements; (d) impersonate someone; (e) involve sending illegal or impermissible communications, including but not limited to bulk messaging, auto-messaging, and the like; or (f) involve any non-personal use of our services.

Harm to SUPAsub or our users: You may not (or assist others to) directly, indirectly, through automated or other means access, use, copy, adapt, modify, prepare derivative works based upon, distribute, license, sublicense, transfer, display, perform, or otherwise exploit our services in impermissible or unauthorized manners, or in ways that burden, impair, or harm us, our services, systems, our users, or others, including that you must not directly or through automated means: (a) reverse engineer, alter, modify, create derivative works from, decompile, or extract code from our services; (b) send, store, or transmit viruses or other harmful computer code through or onto our services; (c) gain or attempt to gain unauthorized access to our services or systems; (d) interfere with or disrupt the safety, security, or performance of our services; (e) create accounts for our services through unauthorized or automated means; (f) collect the information of or about our users in any impermissible or unauthorized manner; (g) sell, resell, rent, license, or charge for our services in an unauthorized manner; (h) distribute or make our services available over a network where they could be used by multiple devices at the same time, except as authorized through tools we have expressly provided via our services; or (i) create software or APIs that function substantially the same as our services and offer them for use by third parties in an unauthorized manner. Keeping your account and information secure: You are solely responsible for keeping your device and your SUPAsub account safe and secure, and you must notify us promptly of any unauthorized use or security breach of your account or our services. Also note that you should carefully consider what personal information you post through the app, as users will access it and, despite their obligation not to, may use it for purposes other than intended by you.

Licenses and Intellectual Property

Our Intellectual Property: All the intellectual property included in the services, website and app belongs to us or our licensors, and you will not acquire any rights to that intellectual property. Your Rights: SUPAsub does not claim ownership of the information that you submit for your SUPAsub account or through our services and you accept full responsibility for all information and content shared with us or through the services. You must have the necessary authorisation and right to share information that you submit for your SUPAsub account or through our services and you grant us the rights and license to use information in the way intended through our services and as set out in our terms. You expressly grant SUPAsub a free of charge, worldwide, non-exclusive, royalty-free, sublicensable, and transferable license to use, reproduce, distribute, create derivative works of, display, and perform the information (including the content) that you upload, submit, store, send, or receive on or through our services. Your License: you have a limited, revocable, non-exclusive and non-transferable license to use our services on these terms only.

Indemnity

If anyone brings a claim (“Third Party Claim”) against us related to your actions, use of the services, information shared, or content on SUPAsub, you indemnify and hold SUPAsub (including our shareholders, directors and employees) harmless from and against all liabilities, damages, losses, and expenses of any kind (including reasonable legal fees and costs) relating to, arising out of, or in any way in connection with any of the following: (a) your access to or use of our services, including information provided in connection therewith; (b) your breach of our terms or of applicable law; or (c) any misrepresentation made by you. You will cooperate as fully as required by us in the defence or settlement of any claim by any third party.

Exclusion of liability

All information provided is publicly accessible and reasonably accurate to the best of our knowledge. You agree to use any data accessed through the app at your own risk, we take no responsibility for any inaccuracies or errors. We will use reasonable skill and care in providing our services to you and in keeping it a safe, secure, and error-free environment, but we do not guarantee that SUPAsub will always function without disruptions, delays, or imperfections. You use our services at your own risk and subject to the disclaimers set out in these terms. We are providing our services on an “as is” basis without any express or implied warranties, including, but not limited to, warranties of merchantability, fitness for a particular purpose, title, non-infringement, and freedom from computer virus or other harmful code. We do not warrant that any information provided by us is accurate, complete, or useful, that our services will be operational, error free, secure, or safe, or that our services will function without disruptions, delays, or imperfections. We do not control and are not responsible for, controlling how or when our users use our services or the features, services, and interfaces our services provide. We are not responsible for and are not obligated to control the actions or information (including content) of our users or other third parties. We (including our subsidiaries, affiliates, and our and their directors, officers, employees, partners, and agents (together, the “SUPAsub parties”)) exclude any liability from any loss, claim, complaint, or cause of action, and all damages, relating to, arising out of, or in any way connected with your use of the services.

Availability and termination of our services

Availability of our services: We are always trying to improve our services. That means we may add or remove our services, features, functionalities, and the support of certain devices and platforms. Our services may be interrupted, including for maintenance, repairs, upgrades, or network or equipment failures. We may discontinue some or all of our services, including certain features and the support for certain devices and platforms, at any time without notice. Events beyond our control may also affect our services, such as events in nature and other force majeure events. Termination: Although we hope you remain a SUPAsub user, you can terminate your relationship with SUPAsub anytime for any reason by deleting your account. Please contact us to request account deletion. We may also modify, suspend, or terminate your access to or use of our services anytime for actual or suspected unlawful conduct, including for fraud, or if we reasonably believe you violate or are about to violate our terms or applicable laws, or may create harm, risk, or possible legal exposure for us, our users, or others. The following provisions will survive any termination of your relationship with SUPAsub: “Licenses”, “Exclusion of Liability”, “Indemnity”, “Other”, and “Availability and Termination of our Services”. If you believe your account’s termination or suspension was in error, please contact us. We may at any time and for any reason decide to terminate any or all parts of the services.

Third party products or services

We may allow third party product and service suppliers to advertise products or services through our app. We are not the supplier of these products or services and do not take responsibility for the performance by these third parties. If you access and use any third party products or services, or enter into any agreements for the supply of third party products or services, you do that solely at your own risk and subject to the terms of the third party product or service provider.

Account and Personal Information deletion

You can request deletion of your account and personal information (meaning personal information or data as defined by applicable laws such as the Protection of Personal Act (“POPI”) or the GDPR), by contacting us at legal@supasub.app, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers – where applicable – to delete) your personal information from our records, unless an exception applies. We may refuse your deletion request if the law allows or requires retention and retaining the information is necessary to: complete the transaction for which we collected the personal information; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or report or assist authorities to prosecute those responsible for such activities; debug products to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; comply with a legal obligation; make other internal and lawful uses of that information that are compatible with the context in which you provided it. Also note that we do not control the deletion of information by other users with whom you may have engaged through our services and their use of your information previously provided, is out of our control.

Other

Unless a mutually executed agreement between you and us states otherwise, these terms make up the entire agreement between you and us regarding SUPAsub and our services, and supersede any prior agreements. We reserve the right to designate in the future that certain of our services are governed by separate terms (where, as applicable, you may be required to separately agree to such terms).Our services are not intended for distribution to or use in any country where such distribution or use would violate local law or would subject us to any regulations in another country. We reserve the right to limit our services in any country. Any amendment to or waiver of our terms requires our express consent. You have the right to terminate your relationship with SUPAsub at any time by requesting us to delete your account. We may assign our rights and obligations to any of our affiliates or in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new owner. In the event of such an assignment, these terms will continue to govern your relationship with such third party. We hope you will continue using SUPAsub, but if you do not agree to such an assignment, you must stop using our services by requesting us to delete your account.

Nothing in our terms will prevent us from complying with the law. Except as contemplated herein, our terms do not give any third-party beneficiary rights. If we fail to enforce any of our terms, it will not be considered a waiver. We always appreciate your feedback or other suggestions about SUPAsub and our services, but you understand that you have no obligation to provide feedback or suggestions and that we may use your feedback or suggestions without any obligation to compensate you for them.

Privacy Policy

Introduction

This policy informs visitors and users of our website and app regarding our policies in respect of the collection, use, sharing and disclosure of personal information (“personal information” as defined in POPI). We are committed to privacy practices in compliance with POPI Information collection and useIn order to use our service, we may require you to provide us with certain personally identifiable information, and personal information, including but not limited to: name, mobile number, email address. We may also collect information through your social media accounts such as Facebook, Google and Apple accounts. If you use the Nearby location functionality, we collect your geolocation. If you use our AskMyStreetfunctionality, we collect your geolocation. The information that we collect will be retained by us and used as described in this privacy policy and our terms.

We collect information directly from you when you provide information on registration or otherwise communicate with us or from your interaction with our services or when you use any features or resources available on or through our website or app.If a user of our services, provides information through the app about you (as a third party), our platform collects the information from our user. Our user is however contractually bound to only share third party information with consent. All processing of personal information relates to the services we offer and enhancing your experience. Processing therefore includes any required use relating to your application, account, use of the services, analysing and monitoring use, product development, working with authorities or other relevant parties, reporting abuse or misconduct, and marketing. We do not sell personal information. Log DataWe want to inform you that whenever you use our service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our service, the time and date of your use of the service, and other statistics.

Cookies

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device’s internal memory.

The service does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of our service.

Service Providers

We may employ third-party companies and individuals for the following reasons: to facilitate our service; to provide the service on our behalf; to perform services related to our service; or to assist us in analysing how our service is used and provide other support services to us. These third parties have access to your personal information for the sole purpose to perform services to us or on our behalf. However, they are obligated in law not to disclose or use the information for any other purpose and they only process the information in terms of a contract with us

Disclosure of Personal information

Other than disclosure to service providers, we may disclose information if the law allows or requires it from us, including for example sharing with authorities, business partners in respect of our business or the services. If our service providers or business partners are located cross border, we may share the information cross border, but at all times in compliance with the POPI requirements for cross border sharing of information.

Information We Collect

It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information about your use of our services such as access logs, as well as information from third parties, like when you access our services through your social media account or when you upload information from your social media account to complete your profile. If you want additional info, we go into more detail below.

Information you give us

You choose to give us certain information when using our services. This includes:

When you create an account, you provide us with at least your phone number and email address, as well as some basic details necessary for the service to work, such as your gender, date of birth, and who you’d like to connect with.
When you complete your profile, you have the option to share your sexual orientation with us. Where you provide such elements to us, you consent to us using it for the purposes identified and as laid out in this Privacy Policy. You can also share additional information with us, such as details on your bio and your interests, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album.
When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us with information related to the purchases you make and our payment processors with information such as your debit or credit card number or other financial information.
When you participate in surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials.
When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
If you contact our customer care team, we collect the information you give us during the interaction.
If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf in order to complete your request.
Of course, we also process your chats with other members as well as the content you publish to operate and secure the services, and to keep our community safe.

Information we receive from others

In addition to the information you may provide us directly, we receive information about you from others, including:

Members: Members may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.
Social Media: You may decide to share information with us through your social media account, for instance if you decide to create and log into your account via your social media or other account (e.g., Facebook, Google or Apple) or to upload onto our services information such as photos from one of your social media accounts (e.g., Instagram or Spotify).
Affiliates: Your information can be shared with us to allow us to take necessary actions, including closing your account or preventing you from creating an account on our services.
Other Partners: We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our members’ safety and security.

Information generated or automatically collected when you use our services

When you use our services, this generates technical data about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details.

Usage Information: Using the services generates data about your activity on our services, for instance how you use them (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages address and ads that you interacted with) and your interactions with other members (e.g., members you connect and interact with, and when you matched and exchanged messages with them).
Device information: We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’ settings and, in some cases, disable entirely), and identifiers associated with cookies or other technologies that may uniquely identify a device or browser.
Information collected by cookies and similar technologies: We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels, SDKs) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them and how you can better control their use. Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including ours, do not currently respond to DNT signals.
Other information with your consent:
- Precise geolocation data: If you give us your consent, we can collect your precise geolocation (latitude and longitude) from your device. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your precise geolocation, we will not collect it, and our services that rely on precise geolocation may not be available to you.
- Photo Verification data: If you choose to participate in our Photo Verification feature, we collect your face geometry data, which may be considered biometric data in some jurisdictions, to verify that you’re the real you. You can learn more about Photo Verification and how we process your face geometry data.
- Other information: We may collect other information with your permission, such as photos and videos (for instance, if you want to publish a photo or video or participate in streaming features on our services).

How We Use Information

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you and our community safe, and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.

A. To administer your account and provide our services to you

Create and manage your account
Provide you with customer support and respond to your requests
Communicate with you about our services
Personalize pricing, offer discounts and other promotions, and complete your transactions
Administer sweepstakes and contests

B. To help you connect with other users

Recommend you to other members and recommend other members to you
Show members’ profiles to one another
Enable members to search for and connect with members

C. To provide new SUPAsub services to you

Register you and display your profile on new SUPAsub features and apps
Administer your account on these new features and apps

D. To provide offers and operate advertising and marketing campaigns

Perform and measure the effectiveness of advertising campaigns on our services and marketing our services off our platform
Communicate with you about products or services that we believe may interest you

E. To improve our services and develop new ones

Administer focus groups, market studies and surveys
Review interactions with customer care teams to improve our quality of service
Understand how members typically use the services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how members react to it)
Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from members)

F. To prevent, detect and fight fraud and other illegal or unauthorized activities

Find and address ongoing, suspected or alleged violations of our Terms of Use, notably through the review of reports and interactions between members
Better understand and design countermeasures against violations of our Terms of Use
Retain data related to violations of our Terms of Use to address the violation and prevent against recurrences
Enforce or exercise our rights, for example our rights set out in our Terms of Use
Communicate to individuals who submit a report, including what we’ve done as a result of their submission

G. To ensure legal compliance

Comply with legal requirements
Assist law enforcement

For information on how we process personal information through profiling and automated decision-making, please see our FAQ.

To process your information as described in this Privacy Policy, we rely on the following legal bases:

Provide our service to you: The reason we process your information for purposes A, B and C above is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, make it viewable to other members and recommend other members to you and to otherwise provide our free and paid features to you and other members.
Legitimate interests: We process your information for purposes D, E and F above, based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our members safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
Comply with applicable laws and regulations: We process your information for purpose G above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents members give us and decisions they may have taken to opt-out of a given feature or processing.
Consent: If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, such as your sexual orientation, you’re consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your precise geolocation or use your information for certain specific reasons. In some cases, you may withdraw your consent by adapting your settings (for instance in relation to the collection of our precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered “special” or “sensitive”). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

How We Share Information

Since our goal is to help you make meaningful connections, the main sharing of members’ information is, of course, with other members. We also share some types of members’ information with service providers and partners who assist us in operating the services, with other companies for specified reasons as laid out below and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

With other members. You share information with other members when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings. If someone submits a report involving you (such as a claim you violated our Terms of Use), we may communicate to the reporter actions, if any, we took as a result of their report.
With our service providers and partners. We use vendors to help us operate, distribute, market and improve our services, such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We also share information with vendors who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising vendors.

We follow a strict vetting process prior to engaging any vendor or working with any partner. Our vendors and partners must agree to strict confidentiality obligations.

With our affiliates. We share your information with affiliates for limited legitimate purposes as laid out below:
- To make all platforms safer and enable us to address (e.g., ban) bad actors found on one platform also on the others
- For them to assist us in data processing operations, as processors / service providers, upon our instructions and on our behalf. Their assistance may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, analytics, finance and accounting assistance, improving our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings
- We may also share information with other companies for other legitimate business purposes including corporate audit, analysis and consolidated reporting, where and as allowed under applicable law
Sharing functionalityYou may choose to share other members’ profiles and they may share yours with people outside of our services, using the sharing functionality.
For corporate transactionsWe may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
With law enforcement / when required by lawWe may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
To enforce legal rightsWe may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our members, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your requestWe may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, location in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy

Cross-Border Data Transfers

Sharing of information laid out in Section 5 involves cross-border data transfers to the United States of America and other jurisdictions that may have different laws about data processing. When we transfer personal information outside of the EEA, the United Kingdom, Switzerland or other countries which data protection laws have been deemed adequate by the European Commission or other competent governmental body, we use standard contract clauses (standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data) or other appropriate transfer mechanism. We are currently in the process of reviewing transfers to our vendors and associated legal basis further to the recent Court of Justice for the European Union’s ruling on transfers of personal data to the USA.

Your Rights and Choices

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

Access / Update tools in the service. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please contact our customer care team for help.
Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality.
Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.
Account closure. You can close your account by using the corresponding functionality directly on the service.

We also want you to be aware of your privacy rights. Depending on where you live, you may have the right to:

Access/know. You may have the right to request a copy of the information we keep about you, and in certain circumstances to receive this in a portable format. You can exercise your right to access directly within the service by putting in a request.
Delete/erase. You may request that we delete the personal information we keep about you. You can exercise your right to delete by submitting a request .
Correct/rectify/update. You can correct most information you provided to us by editing your profile directly in the service. If you believe the information we hold about you is inaccurate, you may contact us to rectify it.
Object/restrict. You may also have the right to object to or request that we restrict certain processing. To do so, please contact us.

For your protection and the protection of all of our members, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, such as a copy of any messages you received from them through our service, the other member will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request. Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and thus cannot ensure that you are 18 years of age or older.

If you are a resident of South Africa, if we deny your privacy request, you may be able to appeal by contacting us, and explicitly referencing “Privacy Request Appeal.”

In certain countries, including in the European Economic Area and the United Kingdom, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. You can find information about your data protection regulator in the European Economic Area here, and in the United Kingdom here. The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work or where an alleged infringement took place.

How Long We Retain Your Information

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 4) and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other members. Note that we will close your account automatically if you are inactive for a period of two years. After your account is closed, we will delete your personal information, as laid out below:

To protect the safety and security of our members, we implement a safety retention window of three months following account closure, or one year following an account ban. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
- a) We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents members give us for five years to evidence our compliance with applicable law.
- b) We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase for five years to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defence of legal claims, and data necessary to prevent members who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our members.
- c) Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).

Security

We value your trust in providing us your personal information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security. We implement appropriate technical and organisational security measures in accordance with POPI, designed to protect personal information against accidental or unlawful destruction, loss, alteration, disclosure, access and other unlawful or unauthorised forms of processing.

Links to Other Sites or Apps

This service may contain advertisements of third party products or services or links to other sites. If you click on a third-party link, you will be directed to that site or app. Note that these external sites or apps are not operated or controlled by us. Therefore, we strongly advise you to review the privacy policies of these websites or apps before using it. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites, apps or services and how they process your personal information.

Children’s Privacy

Our services are not aimed at minors and we do not knowingly collect personally identifiable information from minors. All personal information of minors provided to us, must be provided with the consent of a guardian or parent.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

User Generated Content Policy

Non-compliance to these policies will lead to the takedown of content, and potential account suspension and/or termination. We utilise a combination of automated moderation and user generated reporting to moderate content on the SUPAsub platform.

Retention of information

We take reasonable steps to ensure that we only process personal information for the period necessary for the purposes set out in this policy, including any period necessary to establish, exercise or defend any legal rights.

We therefore retain personal information in accordance with the required retention periods in terms of any laws that require specific retention periods, or otherwise in terms of POPI or for legitimate business purposes. We may retain information indefinitely in a de-identified format for research and statistical purposes, which may include for example statistics of how you use the website, app and services.

Security breach

We will report any security breach to the applicable regulatory authority in terms of POPI and to the data subjects whose personal information is involved in the breach. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your personal information, please send an email to legal@esp.info.Lodging a complaint

If you want to raise any objection or have any queries about our privacy practices, you can contact our information officer on legal@supasub.app. You also have the right to formally lodge a complaint as follows:

Law	Regulatory authority name	Contact details
POPI	The Information Regulator	Website: https://inforegulator.org.za/ Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001Postal address: P.O. Box 31533, Braamfontein, Johannesburg, 2017Complaints (complete form 5)POPI: POPIAComplaints@inforegulator.org.za PAIA: PAIAComplaints@inforegulator.org.za General enquiries: enquiries@inforegulator.org.za

Useful Content

SUPAsub aims to provide a platform to create useful content for the users and limit the use of the app

Useful content: you may not share content that is offensive, “spammy” or adds no value to the users on the platform, considering the purpose of the services to predominantly provide information in respect of load shedding and related matters. Advertising: Advertising and other paid promotional material should not exceed your independent, editorial content. We do not allow content that conceals or misrepresents sponsored content as independent, editorial content. Sponsorship, including, but not limited to, ownership or affiliate interest, payment, or material support, should be disclosed to users. The subject of sponsored content should not focus on the sponsor without clear disclosure.

Personal or confidential Information: you may not add or share any personal or confidential information of third parties without their express consent. Intellectual Property: you may not infringe anyone’s intellectual property rights and must respond to clear notices of alleged copyright infringement. Adult content: you may not share content that features sexual imagery. SUPAsub is not a platform for adult content. Violent and other hateful content: you may not share content that incites or glorifies violence, any hateful or harassing activity, including based on any of the discrimination grounds set out in our Constitution or presents a threat to another person or group of persons.

Although we do not have any obligation to monitor user content, we have the right to do so and any meaningless or offensive content as determined in our sole discretion, may be taken down without notice and the user account may be terminated immediately and without notice.

Law and Jurisdiction

These terms and all obligations connected to them or arising from them will be governed and interpreted in terms of the laws of the Republic of South Africa. All users submit to the jurisdiction of the South African courts.

Contact Us

If you have any questions or suggestions about our terms & Privacy Policy, please contact us at legal@supasub.app.