Website Privacy & Data Protection Policy

1.1 This privacy and data protection policy (“DP Policy”) sets out a framework for Mere Simplicity (Pty) Ltd (“we”, “us”, “our”, or “Service Provider”) to comply with POPIA’s conditions in the processing of your personal information (“PI”).

1.2 Where reference is made to the “processing” of PI, this has the meaning ascribed thereto in Section 1 of POPIA and includes any activity or operation concerning personal information, from the time that the PI is collected, through its storage, usage, merging, linking, restriction, or dissemination, up to the time that the PI is destroyed or de-identified.

1.3 By accessing our website (https://meresimplicity.com), completing Intelligence Discovery, interacting with our workspace, registering for services, submitting enquiries, or booking consultations, you agree that we may process your PI as explained in this DP Policy.

2.1 Depending on the type of business we conduct with you or the relationship you have with us, we may process your PI, including the following: name, business name, race or ethnic origin (solely for employment equity purposes or as otherwise required by applicable law), gender, marital status, nationality, age, language preference, date of birth, information relating to education, financial, criminal or employment history of a person (such as during recruitment or contractor vetting), identifying numbers such as identity or passport numbers, tax identification or tax reference numbers, email address, physical address, and telephone or WhatsApp numbers.

2.2 We undertake to comply with POPIA at all relevant times and to process your PI lawfully and reasonably, so as not to infringe unnecessarily on your privacy.

2.3 We undertake to process your PI only for the purpose for which it is intended, to enable us to conduct our business, affairs, software engineering, intelligence discovery, and digital services, as may inter alia be contractually determined.

2.4 Whenever necessary, we shall obtain the voluntary, specific, and informed consent as defined in POPIA (“Consent”) from you to process your PI.

2.5 Where we do not expressly seek your Consent, the processing of your PI may be done in terms of another legitimate ground under POPIA, such as a legal obligation placed on us, to perform obligations under a contract to which you are party, to protect a legitimate interest that requires protection, or to pursue our legitimate business interests.

2.6 We shall stop processing your PI as soon as the required Consent to do so is withdrawn by you or if a legitimate objection thereto is raised by you, subject to applicable contractual obligations or statutory retention requirements.

2.7 We shall collect PI directly from you, unless: the PI is of public record, you have Consented to the collection of your PI from an Affiliate or partner, the PI to be collected is necessary for the maintenance of law and order or national security, the PI is being collected to comply with a legal obligation (including obligations to the South African Revenue Service), the PI collected is required for the conduct of proceedings in any court or tribunal, or the PI is required to maintain our legitimate interests.

2.8 We shall retain records of your PI that we have collected for the minimum period required by law unless you have given your Consent or instructed us to retain the records for a longer period.

2.9 We shall destroy or delete records of your PI (so as to de-identify your PI) as soon as reasonably possible after the time period for which we are entitled to hold the records has expired or you withdraw your Consent.

2.10 We undertake to ensure that your PI which we collect and process is complete, accurate, not misleading, and up to date.

2.11 Where relevant, we undertake to take special care with your bank account details, and are not entitled to obtain or disclose or procure the disclosure of such banking details unless we have your specific Consent or are legally obliged to disclose it.

3.1 In cases where your Consent is required to process your PI, this Consent may be withdrawn by you at any time (otherwise than where there is an existing legal obligation or contractual basis to process it).

3.2 You are entitled to lodge a complaint regarding our application of POPIA to your PI with the Information Regulator (“IR”).

3.3 The prescribed forms for the exercise of these rights are attached to the 2018 regulations passed in terms of POPIA (“Regulations”) and can be obtained from our duly appointed Information Officer (“IO”) or directly from the Information Regulator’s website.

4.1 On production of proof of identity, you are entitled to request that we confirm, free of charge, whether or not we hold any PI relating to you in our records.

4.2 If we indeed hold such PI, on request, and upon payment of the statutory fee (prescribed in accordance with PAIA and POPIA regulations), we shall provide you with the record, or a description of the PI, including information about the identity of all third parties or categories of third parties who have or have had access to the PI. We shall do this within a reasonable period of time, in a reasonable manner, and in an understandable form.

5.1 You are entitled to require us to correct or delete PI that we have, which is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or which has been obtained unlawfully.

5.2 You are also entitled to require us to destroy or delete records of your PI that we are no longer authorised to retain.

5.3 Any such request must be made on the prescribed form (Form 2 of the Regulations), obtainable from our IO or the Information Regulator.

5.4 We undertake, upon receipt of such a lawful request, to comply as soon as reasonably practicable.

5.5 In the event that a dispute arises regarding your rights to have your PI corrected, and in the event that you so require, we shall attach to your PI, in a way that it will always be read with your PI, an indication that the correction of your PI has been requested but has not been made.

5.6 We shall notify you of the action that we have taken as a result of such request.

6.1 Special statutory rules apply to the collection and use of PI relating to a person’s religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric information, or criminal behaviour.

6.2 We shall not process any of your special PI as defined in POPIA (“Special PI”) without your Consent, unless such processing is necessary for the establishment, exercise, or defence of a right or obligation in law, or is otherwise permitted under Part B of Chapter 3 of POPIA.

10.1 We may contact you from time to time to inform you of our additional services, platform features, or products in accordance with Section 69 of POPIA.

10.2 We may also provide you with newsletters, industry insights, and updates as part of our value-added client experience.

10.3 We may share your PI with our Affiliates (subject to applicable law and your indicated marketing preferences) so that they may offer you their complementary services.

10.4 You may at any time object to us processing your PI for direct marketing purposes. You can unsubscribe from direct marketing by clicking the unsubscribe link in communications you receive or by contacting our Information Officer.

10.5 All direct marketing communications will disclose our identity and contain an address or other contact details to which you may send a request that such communications cease.

11.1 The prescribed Forms in terms of POPIA (such as Form 1 for objection to processing, and Form 2 for correction or deletion of personal information) are available on the website of the Information Regulator: https://inforegulator.org.za (or https://www.justice.gov.za/inforeg/docs.html).

11.2 The official contact details of the Information Regulator of South Africa are as follows:

12.1 “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. We use cookies on certain pages of our website to, among other things, analyse our web page flow, measure promotional effectiveness, maintain secure user authentication sessions, track visits from our affiliates and partners, and support interactive platform workspaces. You are always free to decline our cookies if your browser permits, although by declining the use of cookies you may not be able to use certain features on our website.

12.2 Data Collection Devices: In some instances, Mere Simplicity may collect non-personal data through cookies, web logs, and other monitoring technologies to ensure platform stability, prevent abuse, and optimize digital performance.

13.1 Discovery Briefs: Intelligence Discovery collects your business objective, systems, available information, history, access, success measures, and contact details. Drafts are saved on your current device when browser storage is available. Completed answers are saved to your authenticated account when you submit with consent. Your discovery brief is shared with the Mere Simplicity team for follow-up, and Resend delivers a confirmation to your verified account email. Account access uses Firebase Authentication; saved discovery and aggregate reports use Firestore.

13.2 Transaction Ingestion Privacy: The transaction summary processes supported CSV files on our server. Users must supply only pseudonymous customer identifiers, dates, amounts, currency, and optional product or branch codes. You must have authority to process those records and must remove all direct personal identifiers (such as customer names, ID numbers, phone numbers, or credit card numbers) before uploading. Raw rows are not persisted by the import endpoint, logged in application code, or sent to any external AI training models.

13.3 Aggregate Metrics: Only aggregate measurements, validation counts, limited rejection reasons, the reporting period, calculation version, analysis timestamp, and a source-file fingerprint are saved. Each successful import replaces the saved summary. You can download or remove that summary in the workspace. No cross-business customer profiles or probabilistic identity matching are created by this feature.