POPIA Privacy Policy

How we collect, use, store, share and protect your personal information

Last Updated: 18 September 2026

BuddyApp (Pty) Ltd ("BuddyApp", "we", "us", "our") is committed to protecting personal information and complying with the Protection of Personal Information Act, 2013 (POPIA).

This Privacy Policy explains how we collect, use, store, share and protect personal information in accordance with POPIA and the Conditions for Lawful Processing under Chapter 3 of the Act.

This Policy applies to:

  • • All users of the BuddyApp platform (Clients and Buddies)
  • • Visitors to our website
  • • Users of our mobile applications
  • • Anyone who interacts with BuddyApp electronically

By using the Platform, you acknowledge and consent to the processing of your personal information in accordance with this Policy.

1The Responsible Party

BuddyApp (Pty) Ltd is the Responsible Party under POPIA. We determine the purpose and means for processing personal information.

Company

BuddyApp (Pty) Ltd

Location

Pretoria, Gauteng, South Africa

2Definitions (POPIA)

"Personal Information"

Any information relating to an identifiable, living natural person or existing juristic person.

"Data Subject"

The person to whom the personal information relates (Clients and Buddies).

"Processing"

Includes collecting, recording, storing, updating, destroying, transmitting or using personal information.

"Operator"

A third-party service provider who processes information on our behalf.

"Responsible Party"

BuddyApp (Pty) Ltd.

3What Personal Information We Collect

In line with POPIA, we collect only the information necessary for providing our services.

3.1 Information Provided by You

  • • Names and surnames
  • • Phone numbers
  • • Email address
  • • Residential or job location
  • • Identity verification details (ID/passport)
  • • Bank account details (for Buddy payouts)
  • • Payment and transaction details
  • • Profile photos (optional)
  • • Job descriptions and notes

3.2 Information Collected Automatically

  • • Device information
  • • IP address
  • • Location data (if permission granted)
  • • App usage data
  • • Cookies and analytics tracking

3.3 Information from Third Parties

We may receive information from verification partners, payment processors, and fraud prevention partners.

We do not collect unnecessary or excessive personal information (POPIA: Condition 3 – Purpose Limitation).

3.4Face Data and the TrueDepth API

BuddyApp uses the Smile ID identity-verification SDK. On supported Apple devices, the SDK may use Apple's TrueDepth camera and ARKit while a user takes a verification selfie. The information processed during this flow may include a selfie, liveness images, facial geometry, facial-feature positions, facial expressions or blend shapes, and head position or orientation. BuddyApp does not access Face ID enrolment information or biometric credentials stored in Apple's Secure Enclave.

This information is used only to confirm that the person completing verification is physically present, detect spoofing or impersonation, compare the captured selfie with the photograph on the submitted identity document, verify identity, and prevent fraud. It is not used for advertising, marketing, tracking, or unrelated profiling.

TrueDepth and ARKit facial geometry, expression, and head-position information is processed during the verification session for liveness detection. BuddyApp does not independently retain that TrueDepth-derived geometry on the device or in its own database. The required selfie, liveness images, identity-document images, and verification metadata are transmitted securely to Smile ID to perform identity verification and fraud-prevention checks.

Smile ID processes and stores verification material on its protected systems and may use approved infrastructure providers, subprocessors, and identity-data sources as described in its privacy and data-retention policies. BuddyApp stores only the verification job identifier, status, result code, result description, and limited decision-related audit information in its Supabase-hosted database. BuddyApp does not sell face data or disclose it to advertisers.

TrueDepth-derived geometry is not retained by BuddyApp after the live verification session. Smile ID retains submitted verification material only for as long as necessary to provide identity verification, authentication, and fraud-prevention services, or as required or permitted by applicable law. BuddyApp retains its limited verification record while the account is active and afterwards only where necessary for fraud prevention, dispute resolution, legal claims, or legal compliance. When those purposes no longer apply, the information is securely deleted or de-identified.

Users may request deletion through the in-app account-deletion feature, at buddyapp.co.za/delete-account, or by emailing support@buddyapp.co.za. BuddyApp coordinates applicable deletion requests with Smile ID. Some records may be retained where required by law, necessary for an unresolved dispute or legal claim, or necessary to prevent or detect unlawful conduct.

Smile ID's privacy and retention terms are available at usesmileid.com/legal.

4Purpose of Processing

POPIA Condition 2 – Purpose Specification

We process personal information strictly for the following lawful purposes:

4.1 Core Platform Functions

  • • Creating and managing user accounts
  • • Matching Clients with Buddies
  • • Facilitating communication
  • • Processing bookings, payments and payouts

4.2 Safety, Security & Verification

  • • Identity verification
  • • Fraud detection and prevention
  • • Handling complaints, disputes and safety reports

4.3 Platform Improvement

  • • Analytics and performance monitoring
  • • Feature updates and system improvements

4.4 Legal Requirements

  • • Record keeping
  • • Compliance with applicable laws

We will not use your information for purposes unrelated to BuddyApp unless required by law or with your explicit consent.

5Lawful Basis for Processing

POPIA Condition 1 – Accountability

BuddyApp processes personal information using the following lawful grounds:

✓

Consent

When you create an account or use the app.

✓

Contractual Necessity

To deliver services through the platform.

✓

Legal Obligation

Compliance with POPIA, tax laws, financial regulations.

✓

Legitimate Interest

Fraud prevention, platform security, improving functionality.

We ensure compliance with all 8 POPIA Conditions for Lawful Processing.

6Sharing of Personal Information

POPIA Condition 7 – Security Safeguards

We do NOT sell your personal information.

We may share information only with:

• Payment processors
• Identity verification providers
• Cloud hosting providers
• Communication service providers (SMS, email, WhatsApp)
• Law enforcement (only when legally required)
• Buddies or Clients as needed for bookings

Every Operator is contractually required to comply with POPIA.

7Security of Personal Information

Security Safeguards

BuddyApp implements appropriate, reasonable technical and organisational safeguards, including:

✓ Encryption
✓ Secure servers
✓ Access controls
✓ Authentication procedures
✓ Regular security audits

While no system is completely risk-free, we take all steps required by POPIA to protect information.

8Cross-Border Transfers

POPIA Chapter 9

If personal information is stored or processed outside South Africa:

  • •We ensure the foreign country has adequate protection, or
  • •We use POPIA-compliant contractual safeguards.

9Data Retention

POPIA Condition 3 – Retention & Restriction

Personal information is kept only as long as:

  • • Required to provide services
  • • Required by law
  • • Needed to resolve disputes

Deletion may be requested.

10Your POPIA Rights

You have the right to:

Access your information
✎Request correction
Request deletion (where lawful)
✋Object to processing
↩Withdraw consent
📝Lodge a complaint

11Cookies & Tracking

We use cookies for essential functions and analytics. For more details, see our Cookie Policy.

12Marketing Communication

Users may opt out of marketing communications at any time via account settings or unsubscribe links.

13Children's Personal Information

BuddyApp is intended for users aged 18 and over. We do not knowingly collect personal information from children.

14Changes to This Policy

Updated versions of this Privacy Policy will be posted on the Platform with a new "Last Updated" date. Continued use of the Platform constitutes acceptance of any changes.

15Contact Information

Company

BuddyApp (Pty) Ltd

Location

Pretoria, Gauteng, South Africa