OpenItem Access
Privacy Policy

1. About this policy

1.1 Who we are

Wyobi Software Solutions (Pty) Ltd, registration number 2024/780470/07 (“Wyobi”, “we”, “us” or “our”), is a South African private company with its registered office in Pretoria, Gauteng. We develop and operate OpenItem Access, a platform for access control, visitor management and security.

This policy explains how personal information is collected, used, shared and protected when OpenItem Access is used, and the rights you have. It is written to meet the requirements of the Protection of Personal Information Act 4 of 2013 (“POPIA”).

1.2 What this policy covers

This policy applies to OpenItem Access (the “Services”), which includes:

• the OpenItem Access resident and member mobile applications, including every version published under the name or brand of an estate, complex, property manager, security company, Reseller or other partner;
• the OpenItem Access Guard app and the other applications used by security personnel;
• the OpenItem Access web portals, websites, visitor and registration pages, forms, application programming interfaces (APIs) and back-end systems; and
• the devices, kiosks and GPS trackers used with OpenItem Access, its integrations, the identity-verification and facial-recognition services it uses, and any other part of OpenItem Access that displays or links to this policy.

This policy does not cover how we process personal information in running our own business outside the Services, for example about our employees, suppliers and website enquiries. Our Information Privacy Policy, available at www.wyobi.com, covers that processing.

1.3 Who this policy applies to

This policy applies to everyone whose personal information is processed through the Services, including:

• residents, owners, tenants, members and their household members;
• people who work for or provide services to residents, such as domestic workers, gardeners and contractors;
• visitors, guests, and delivery and service personnel;
• security officers, guards, supervisors and controllers;
• administrators, managing agents, trustees and staff of our Clients; and
• our Clients’ representatives and our other business contacts.

1.4 Features differ between sites

The Services can be configured. Many features are optional, and a Client switches them on only for its own site. Some features are available only on certain devices or versions of an app. This policy describes everything the Services can do, so not every part of it will apply to you.

1.5 Key terms

Words defined in POPIA have the same meaning in this policy. In particular:

• “biometric information” means information used to identify a person from their physical characteristics, such as facial images and facial-recognition templates, liveness checks and fingerprint templates;
• “child” means a person under 18;
• “Client” means the organisation that manages your site and gives you access to the Services there. It may be an estate, homeowners’ association, body corporate, property owner or managing agent, business or institution;
• “competent person” means someone legally able to consent on a child’s behalf, such as a parent or guardian;
• “consent” means a voluntary, specific and informed expression of your agreement to the processing of your personal information;
• “de-identify” means to remove anything from personal information that identifies a person, or that could be used or combined with other information to identify them;
• “Guard app” means the OpenItem Access application used by security personnel to verify people and vehicles, record activity and manage access at a site;
• “Information Officer” means the person responsible for a responsible party’s compliance with POPIA and for handling requests from data subjects;
• “operator” means someone who processes personal information on behalf of a responsible party;
• “PAIA” means the Promotion of Access to Information Act 2 of 2000;
• “personal information” means information about an identifiable, living natural person and, where applicable, an identifiable, existing juristic person;
• “personal information of children” means personal information about a child. POPIA protects it separately from special personal information;
• “POPIA” means the Protection of Personal Information Act 4 of 2013;
• “processing” means anything done with personal information, such as collecting, storing, using, sharing or deleting it;
• “Reseller” means one of our authorised resellers, usually a security or access-control service provider, from which a Client obtains the Services;
• “responsible party” means the person or organisation that decides why and how personal information is processed;
• “security personnel” means the security officers, guards, supervisors and controllers who use the Services at a site, whether employed by the Client or by a security service provider;
• “Services” means OpenItem Access, as described in section 1.2;
• “site” means an estate, complex, building, workplace or other premises where a Client uses the Services to manage access and security;
• “special personal information” includes biometric information, health information, information about race or ethnic origin, and information about criminal behaviour;
• “sub-operator” means an operator that processes personal information for another operator, on the instructions of that operator and the responsible party; and
• “Wyobi”, “we”, “us” and “our” mean Wyobi Software Solutions (Pty) Ltd, registration number 2024/780470/07.

We do not contract with Clients directly. A Client obtains the Services from one of our authorised resellers, usually a security or access-control service provider (a “Reseller”). We provide the Services to Resellers under a written reseller agreement and data processing agreement.

2. Our role, and the roles of Clients and Resellers

2.1 When we act for our Clients

Most personal information processed through the Services forms part of a Client’s records. Examples are resident and visitor records, access logs, identity verification results, biometric enrolments and security incident records. For that information, the Client is the responsible party: it decides what is collected, why and, within the limits in section 9, for how long.

The Client’s Reseller is the Client’s operator: it provides the Services to the Client and processes that information on the Client’s behalf. We are a sub-operator: we process the information for the Reseller, under our written reseller agreement and data processing agreement with it. We process it only with the Client’s knowledge or authorisation, and only on the instructions of the Reseller and the Client, including the settings that the Client, or the Reseller on its behalf, chooses for the Client’s site. We use it only to provide, support and maintain the Services for the Reseller and the Client. As POPIA requires, we treat it as confidential, keep it secure and report any security compromise to the Reseller as section 10 describes.

2.2 When we are the responsible party

We are the responsible party for personal information we process for our own purposes, which are:

• managing our relationships with Resellers, Clients and their representatives;
• operating, securing, supporting, maintaining and improving the Services, including diagnostics, crash reporting and usage analytics;
• operating a central directory of people registered at sites that use the Services, so that our support staff and Resellers can support users and you can sign in to every site where you are registered (see section 7);
• operating shared identity-verification and facial-recognition resources that help sites using the Services verify people (see sections 5 and 7);
• answering enquiries and requests sent to us;
• meeting our legal obligations; and
• establishing, exercising or defending our legal rights.

We are not the responsible party for the personal information of people at our Clients’ sites. The processing we do to operate, secure, support and maintain the Services, including diagnostics, crash reporting, usage analytics, the central directory of registered users and cross-site verification, is done as a sub-operator to provide the Services to Resellers and Clients.

2.3 What this means for you

For Mount Edgecombe Country Club Estate, your Client’s contact details are:

Some questions are about information your Client keeps, for example why your access was refused or what your site’s access records contain. Your Client is usually best placed to answer these. You may still contact us at any time.

Where we are the responsible party, we will deal with your request ourselves. Where we are not, we will refer it to the Client concerned and its Reseller, and help them respond.

2.4 Our Clients’ responsibilities

Each Client is responsible for:

• having a lawful basis for the processing it instructs;
• informing people at its site about that processing, as section 18 of POPIA requires, including signage for cameras, number-plate recognition and biometric readers;
• obtaining any consent that is required, including consent for biometric enrolment and the consent of a competent person for children;
• making sure the information it loads into the Services is accurate;
• having an Information Officer and a procedure for dealing with security compromises; and
• the conduct of its personnel and service providers who use the Services, such as administrators and security officers.

3. Personal information we process

Depending on your relationship with the Client and the features it has enabled, the Services may process the categories of personal information below. We aim to process only information that is adequate, relevant and not excessive for the purpose.

3.1 Identity and contact details

• Your name and surname, mobile and other telephone numbers, and email address.
• Your identity, passport or other identification number, and your date of birth, gender and nationality.
• Photographs.
• Your unit, stand or property address.
• Your residency, membership or employment status, and your role (for example owner, tenant, household member, staff member or officer).
• Your employer or company, and your language and communication preferences.

3.2 Account and security credentials

• Account identifiers.
• One-time PINs (OTPs) and verification codes.
• Passkeys and authentication tokens.
• Access PINs, QR codes, barcodes, cards, tags and remote-control credentials.
• Session details and account settings.
• Choices you make, for example to receive notifications by WhatsApp.

3.3 Information about other people that you give us

This is information that you or the Client provide about household members, staff, contractors, regular visitors, guests and deliveries. It can include:

• names, telephone numbers, email addresses and identity numbers;
• photographs, including facial images where facial enrolment is used;
• vehicle details;
• visit dates, times and purposes;
• the number of adults and minors in a group;
• schedules; and
• attachments.

3.4 Pets and registered items

• Details and photographs of pets, and the owner’s contact details. Pet photographs may be analysed to suggest the pet’s breed. Where a Client enables it, its pet register (pet details, photographs and the owner’s name and number) is shared with a pet-identification service.
• Details of other items registered at a site, such as golf carts, boats or mobility aids.

These are collected only if they are provided by you or the Client or, in the case of goods removal, by security personnel to verify that the correct items were removed.

3.5 Vehicle information

• Registration number, make, model, colour, and VIN or chassis number.
• Vehicle licence disc information.
• Photographs of vehicles and number plates, and the results of number-plate recognition.
• Tags, transponders and remotes linked to a vehicle.
• At commercial and industrial sites that use these features: weighbridge records (vehicle and trailer registration, driver, transporter, product, gross, tare and net mass, and ticket and order references), and records of loads, collections and deliveries.
• The results of checks of vehicles against police or other databases, for example for vehicles reported stolen.

3.6 Access, security and activity records

• Entry and exit events: the date, time, location, gate or access point, direction, and method used. Methods include PIN, QR code, card, tag, remote, Bluetooth, NFC, and facial, fingerprint or number-plate recognition.
• Access approvals and refusals.
• Booking and invitation histories, scans performed at access points, and signatures captured there.
• Actions, notes and reports captured by security personnel, and declarations made at access points, such as firearm declarations.
• Incident, occurrence and emergency reports, and panic and SOS alerts.
• Patrol and checkpoint records.
• Lists of people or vehicles that a Client has restricted or banned, with the reasons recorded. Where a Client uses a third-party vehicle-check service, a vehicle reported stolen or wanted can be flagged automatically.
• Time and attendance records, such as clock-in and clock-out times.
• Messages, notices, polls and responses, including messages exchanged with your Client through channels such as WhatsApp.
• Support tickets and their attachments.

3.7 Identity documents and verification

• Images or scans of identity documents, driver’s licences, vehicle licences, passports and permits.
• Information read from a document’s barcode or machine-readable zone. This can include your photograph, identity number, names, date of birth, gender and licence details.
• The results of identity verification, document authenticity and fraud-prevention checks, carried out against official databases (such as the national population register) or through authorised verification and fraud-prevention services. A result can show whether an identity number is valid and belongs to the person presenting it, and can include your photograph. A check can also flag a document that may not be genuine. Where a verification service returns other details, such as citizenship or marital status, we do not keep or display them unless the Client needs them for a stated purpose.

3.8 Biometric information

Where a Client uses facial or fingerprint recognition, this includes:

• facial images and the facial recognition templates derived from them, including liveness checks that confirm a real person is present;
• selfies taken during online registration or event check-in, which may be compared with another photograph of you; and
• fingerprint templates, which may be stored on readers or smart locks at the site.

Biometric information is special personal information. Section 5.3 explains how it is handled.

3.9 Health and other special personal information, and children’s information

Only where a Client enables the relevant features and the law permits it, this includes:

• medical scheme details you choose to add, which can be shared with responders when you raise a medical emergency, and medical conditions where a site’s induction asks for them;
• vaccination certificates, where a site asks for them;
• body temperature, where a site measures it at the access point (for example with a thermometer or a facial-recognition terminal), and alcohol (breathalyser) test results;
• information that can reveal health or disability, such as driving-licence restriction codes (for example, the need to wear glasses) or registered mobility aids;
• information about alleged offences or security incidents; and
• information about children, such as household members or visitors under 18. Children’s information is not special personal information, but POPIA gives it separate protection (see sections 5.3 and 13).

3.10 Location information

• The precise or approximate location of your device, from GPS, Wi-Fi, mobile networks or Bluetooth, when you allow it.
• The location of access points, and your registered property address.
• While you allow location access, an app may attach your device’s location to the requests it sends to the Services.
• For features that need it, an app may also use your location in the background. It does so only where the feature is enabled, your device settings allow it and the app has explained it. Examples are automatic gate triggering, live location sharing and SOS.
• Where a Client switches on live location sharing, the app sends your device’s location at set intervals, including in the background. The Guard app records the device’s location, including direction of travel and speed, with each scan and transaction.
• Where a Client uses vehicle tracking for deliveries, a GPS tracker is linked to the delivery vehicle at the gate. The vehicle registration, the driver’s mobile number and company, and the delivery stops (each unit’s address and location, the resident’s contact number and the visit PIN) are shared with a vehicle-tracking service. That service records the vehicle’s location while it is on site, and the driver is sent a tracking link.
• We may also work out your approximate location from your IP address.

3.11 Audio, video, images and communications

• Audio and video recordings and live streams made when you use emergency or SOS features.
• Intercom, voice and video calls between visitors, residents and security personnel, and related call information such as numbers, times and duration.
• Recordings of calls made through the Services, for example when security personnel call a resident to approve a visitor.
• Photos, videos and files you upload.
• Images captured at access points, including camera snapshots and number-plate images from systems the Client has connected to the Services.
• Screen recordings and screenshots of the Guard app taken during transactions, which can include images of the documents, people and vehicles being processed.

3.12 Device, technical and usage information

• Device and installation identifiers, and push-notification tokens.
• On devices running the Guard app: hardware and network identifiers such as IMEI, serial number, MAC address, SIM or phone number, and Wi-Fi network name.
• Device make, model and name; operating system and app version; language and time zone.
• IP address, network type and mobile carrier.
• App settings and the status of permissions.
• Identifiers of access hardware, such as Bluetooth receivers and NFC tags, and the names and signal strength of Bluetooth devices detected nearby while an app searches for gate receivers.
• Log files, diagnostic and crash reports, and performance data, including load times and the addresses and timing of requests.
• Usage events, such as the screens you view and the features you use.
• Details of the browser you use on our web portals.

Diagnostic and usage information is linked to you, for example through your mobile number or name, and diagnostic records can include your identity number. This lets us investigate problems that you report or that affect you. Usage analytics can include your device’s approximate location (to within about 100 metres) when you allow location access. Diagnostic and crash reports may also contain personal information that was being processed when a problem occurred.

3.13 Assistant and feedback

Some apps offer an assistant that a Client can switch on. It runs on your device, using your device’s built-in AI capabilities and the content already in your app.

We do not receive your questions or the assistant’s answers, unless you rate an answer or send feedback. In that case, the question, the answer and any comment you add are shared with us so that we can improve the feature.

3.14 Information you choose to share from your device

• Contacts you pick from your address book. Only the contacts you select are sent to the Services.
• Calendar entries you ask the app to create.
• Photos and files you select.
• Passes you add to your device’s wallet.

We do not upload your whole address book.

3.15 Payments

Where a Client offers payment-related features, we process transaction details, such as bookings that require payment and the payment status. Card payments are captured and processed by the payment service provider. We do not store full card numbers or security codes. We may keep limited card details returned by the provider, such as the cardholder name, card type, first and last digits and expiry date, to identify the payment.

3.16 Client personnel and business contacts

• The names, contact details, job titles, login details, and activity and audit logs of administrators, managing agents, officers, supervisors and controllers.
• Information about how officers use their devices and the Services, such as their activity and the location of their scans and transactions.

4. How we collect personal information

We collect personal information:

• directly from you, for example when you register, complete your profile, invite visitors, present a code or document for scanning, fill in a form or contact support;
• from your Client and its personnel, for example resident and unit lists, access rules, officer records and incident records;
• from other users. Examples are a resident who invites you, a household member who adds you, or an officer who scans your document or photographs you or your vehicle at an access point;
• automatically, from your device and our systems: device and technical information, location (if you allow it), logs, and cookies or similar technologies;
• from access-control and security systems that the Client uses, such as gates, readers, biometric terminals, intercoms, cameras, number-plate recognition, and estate or property management systems; and
• from third parties, such as identity verification services and official databases, communications providers, app stores, our service providers, and public sources where this is lawful.

5. Why we process personal information

5.1 Purposes and lawful grounds

We process personal information only where section 11 of POPIA allows it. Special personal information and children’s information need an additional ground under sections 27 to 35 of POPIA, as shown in the last column below. The table sets out the main purposes and the grounds that we and our Clients rely on.

We may also process personal information for a further purpose that is compatible with the purpose it was collected for, as POPIA allows. We may also create de-identified or aggregated information that no longer identifies anyone, and use it for statistics, reports and improvements.

5.2 Withdrawing consent and objecting

Where processing relies on your consent, you may withdraw it at any time. Withdrawing consent does not affect processing that took place before you withdrew it.

Where processing relies on legitimate interests, you may object to it on reasonable grounds relating to your particular situation, unless the law provides for that processing.

If you withdraw consent or object, some features may no longer be available to you. For example, you may need to use a PIN, card or manual verification instead of biometric access.

5.3 Special personal information

Special personal information includes biometric information, health information, information about race or ethnic origin and information about criminal behaviour. We and our Clients process it only where POPIA permits, for example:

• with your consent;
• where it is necessary to establish, exercise or defend a right or obligation in law; or
• where another authorisation in POPIA applies.

Where biometric access is offered, it is offered by the Client. Your participation is based on your consent unless another lawful ground applies. Biometric information is used to verify or identify people for access control and security. We only process facial biometric information if you have given biometric consent. Your Client is responsible for obtaining that consent, which you give yourself in the app, in text that the Client configures. A resident cannot give it on behalf of a visitor.

We process children’s personal information only with the consent of a competent person, such as a parent or guardian, or as otherwise permitted by section 35 of POPIA. Facial biometric enrolment of a child requires that consent. See section 13.

5.4 Automated decisions

Some decisions in the Services are made automatically, using rules set by your Client. For example, a gate opens when a valid credential, face or number plate is recognised, and access is refused when it is not. These decisions work by comparing what is presented at the access point (a code, card, tag, face, fingerprint or number plate) with the credentials, enrolments and access rules the Client has set up for its site, including times, dates, restricted lists and the people you have invited. If they match, access is granted. If they do not, access is refused.

Where a document check or facial comparison flags a possible mismatch or fraud, the result is shown to a person, such as a security officer or administrator, who decides what to do.

You may ask your Client’s security personnel to review a decision and to consider your representations. We do not use automated processing to profile you in ways that have legal consequences for you or affect you to a substantial degree, except as section 71 of POPIA permits.

Some information is needed for the Services to work. For example, a site cannot admit you without your name and an access credential, and the Client may require your identity number or a document scan as a condition of entry. If you do not provide information that the site requires, you may not be able to register, use the Services or enter the site. The Client may offer an alternative, such as manual verification by security personnel.

Other information is optional. Examples are biometric enrolment, pets, medical scheme details, contacts you choose to share, and location access. You can use the Services without it, but some features will not be available.

5.5 Laws that require or authorise collection

Some information is collected because a law requires or authorises it, depending on the site and the features it uses. Examples are:

• the Firearms Control Act 60 of 2000, for firearm declarations at access points;
• the Occupational Health and Safety Act 85 of 1993 and the Mine Health and Safety Act 29 of 1996, for health and safety checks such as breathalyser tests at workplaces;
• the Private Security Industry Regulation Act 56 of 2001, for records kept by security service providers; and
• tax and company laws, including the Tax Administration Act 28 of 2011 and the Companies Act 71 of 2008, for our own business records.

6. Permissions on your device

Our apps ask for your permission before using certain device features. You can refuse or withdraw a permission at any time in your device settings, but some features may not work without it.

7. Who we share personal information with

We share personal information only as needed for the purposes in this policy. We share it with:

• your Client, its Reseller and their authorised personnel, such as administrators, managing agents, trustees and directors, security service providers, officers, supervisors and controllers;
• our support staff and Resellers, across sites. We keep a central directory of the people registered at each site, with their contact details, identity numbers and whether a site has restricted their access. Our support staff can search it across all sites, and a Reseller’s authorised staff across the sites that Reseller supports. When you sign in, we also use your mobile number to find the sites where you are registered. This information is restricted and accessed only by staff who need it to support the site;
• other users, where a feature needs it. For example:
  • visitors receive an invitation and PIN that include your name and the address they are visiting;
  • officers see the details they need to admit or refuse a visitor;
  • residents are told when their visitors arrive;
  • security teams, emergency contacts and responders receive SOS alerts, locations and recordings; and
  • anyone you share a link or stream with can see it;
• our service providers (operators), who provide:
  • hosting, data centres and cloud infrastructure;
  • network security and content delivery;
  • communications: SMS, WhatsApp, email, and push notifications through Apple, Google and Huawei services;
  • emergency alerting, dispatch and team-messaging services;
  • payment processing;
  • maps, location and IP-geolocation services;
  • analytics, diagnostics, crash reporting and performance monitoring;
  • identity verification, fraud prevention and access to official databases;
  • document recognition and image processing;
  • artificial-intelligence and machine-learning services;
  • biometric recognition;
  • video streaming; and
  • link management and support tools;
• providers of software components built into our apps, such as scanning, mapping and messaging components. They may receive limited technical information, such as your device type and usage counts;
• providers of systems that a Client chooses to connect to the Services, but only as far as the connection needs. These include:
  • access-control hardware and software, and biometric terminals;
  • cameras, CCTV and number-plate recognition;
  • intercoms, telephony and smart locks;
  • estate, property, club, golf, hospitality, school-administration, human-resources, booking, form, electronic-signature and visitor-management systems; and
  • device-management systems;
• other Clients that use the Services, where this is needed for identity verification, fraud prevention or security. For example, the result of an identity check, or a facial-recognition enrolment, may be used when you visit another site that uses the Services, and a facial-recognition match can show that site’s staff the other sites where you are enrolled;
• app stores and platform providers, such as Apple, Google and Huawei. They process information under their own privacy policies when you download or use our apps;
• our professional advisers, auditors, insurers and banks, who are bound to keep it confidential;
• law enforcement agencies, regulators, courts and other public bodies, where the law requires it, or where we believe in good faith that disclosure is necessary to:
  • protect someone’s life, health or safety;
  • investigate a crime or security incident; or
  • protect the rights, property or safety of Wyobi, our Clients, users or the public;
• a successor or acquirer, if all or part of our business is merged, acquired, restructured or sold. The information remains subject to this policy; and
• anyone else, with your consent or at your direction. For example, you may send an invitation through WhatsApp, SMS, email or another app using your device’s share function. That app’s own privacy policy then applies.

Our operators may process personal information only on our or the Client’s instructions. They must keep it confidential and protect it with appropriate security measures. Where we act for a Client, we use only service providers approved under our agreements with Resellers, and we tell Resellers before we add a new one. A list of the categories of providers we use, and the countries they process information in, is available on request.

We do not sell personal information, and we do not share it with third parties for their own marketing or advertising.

8. Transfers outside South Africa

The main servers for the Services are in South Africa. Some of our service providers store or process information in other countries, including the United States, member states of the European Union, the United Kingdom, Canada and Brazil, and on global content-delivery and security networks. These include providers of content-delivery and security, communications and push notifications, analytics and crash reporting, maps, document recognition, artificial-intelligence, video and platform services, and systems that Clients choose to connect to the Services.

Where a Client has sites outside South Africa, the Client and its personnel use the Services, and see the information about those sites, from those countries.

We transfer personal information outside South Africa only where section 72 of POPIA permits it and, where we act for a Client, only as authorised under our agreement with the Reseller. Our main basis is section 72(1)(a): each provider is bound by a binding agreement, its data processing terms, that gives the information a level of protection substantially similar to that under POPIA.

Where that basis does not apply, to information we process as the responsible party, we rely on another ground in section 72, for example where:

• you have consented to the transfer;
• the transfer is necessary to perform a contract with you, or a contract concluded in your interest; or
• the transfer is for your benefit, and it is not reasonably practicable to obtain your consent.

We do not transfer biometric or other special personal information, or children’s information, to a country without an adequate level of protection unless the Information Regulator has authorised it.

9. How long we keep personal information

We keep personal information only for as long as we need it for the purpose it was collected for, and for no longer than the periods below. A Client may set shorter periods for its site. We keep information for longer only where the law requires it, or where it is needed for an investigation, an insurance claim or legal proceedings that are under way.

• Our own records. Records of our dealings with Resellers and Clients are kept for the periods that tax and company laws require.
• Backups. Deleted information may remain in secure backups until those backups are overwritten or deleted in the normal cycle.
• When a Client stops using the Services. We return or delete the Client’s information as its Reseller directs, and confirm this in writing.
• Guard app devices. So that access control keeps working when the network is down, devices running the Guard app may hold an offline copy of the information needed to verify people and vehicles at the site. That copy is updated when the device synchronises.
• Your device. Information an app stores on your device stays there until you sign out, clear it or uninstall the app. Some cached content and files are removed only when you uninstall the app. If your device backs up app data to a cloud account, that backup is held under your provider’s terms.

When personal information is no longer needed, we delete or destroy it, or de-identify it so that it cannot be reconstructed in an intelligible form.

10. How we protect personal information

We use appropriate, reasonable technical and organisational measures to protect personal information against loss, damage and unauthorised destruction, and against unlawful access or processing. They include:

• encryption (HTTPS/TLS) of information in transit between our apps, web portals and servers. Current versions of our apps also check our servers’ certificates (certificate pinning) on their main connections;
• encryption of the main on-device database in our resident apps, with the key protected by the device’s secure key storage;
• user accounts and roles that control access to our web portals;
• sign-in with one-time PINs sent to your phone, or with a username and password on our web portals and, depending on how a site is set up, access tokens and multi-factor authentication;
• hosting of our main servers in South Africa by a professional hosting provider, with network firewalls and availability monitoring;
• logs of sign-ins to our web portals and of changes to key records;
• regular backups, with recovery procedures that we test at least once a year;
• confidentiality obligations for our staff;
• written agreements with our operators; and
• security reviews of each app release, and independent security testing.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

You can help protect your information:

• use a screen lock on your device and keep your apps up to date;
• never share OTPs, PINs, codes or links, except with the visitor they are meant for; and
• tell your Client or us straight away if your device is lost or you suspect misuse.

If there are reasonable grounds to believe that an unauthorised person has accessed or acquired personal information, we follow our information incident management process. Where we are the responsible party, our Information Officer notifies the Information Regulator in writing, and the people affected, as soon as reasonably possible and as section 22 of POPIA requires. Where we act for a Client, we notify the Reseller and the Client immediately, without undue delay and within 24 hours (section 21(2) of POPIA), so that the Client can meet its obligations.

11. Your rights

Under POPIA, you have the right to:

• be told that your personal information is being collected, and why;
• be told if your personal information has been accessed or acquired by an unauthorised person;
• ask whether we hold personal information about you, and request access to it. Requests for records are handled under the Promotion of Access to Information Act 2 of 2000 (PAIA), as described in our PAIA Manual, and a prescribed fee may apply;
• ask us to correct or delete personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully;
• ask us to destroy or delete a record we are no longer authorised to keep;
• ask us to restrict processing, for example while we check whether information you have challenged is accurate, or where you would rather it is restricted than deleted;
• object to processing based on legitimate interests, and to direct marketing at any time;
• withdraw your consent where processing relies on it;
• not be subject to certain decisions based solely on automated processing, and make representations about them;
• lodge a complaint with the Information Regulator; and
• institute civil proceedings about an alleged interference with the protection of your personal information.

To exercise your rights:

• contact your Client about information it keeps, or email us at support@wyobi.com with the subject “POPIA request” (to delete your account, see section 12);
• you may use the forms prescribed under the POPIA Regulations (Form 1 to object, and Form 2 to ask for correction or deletion), available on the Information Regulator’s website or from us, but an email is enough;
• there is no charge for objecting or for asking us to correct or delete information;
• be ready to prove your identity, because we may ask you to before we act on a request; and
• expect a response within a reasonable time, and within any period the law sets.

In some cases, the law allows or requires us to refuse a request or to keep certain information, for example where a request would affect someone else’s privacy or the security of a site, or where we need records for a legal claim. If that happens, we will tell you why.

12. Deleting your account and information

You can ask for your account and personal information to be deleted at any time, in either of these ways:

• by email, to support@wyobi.com with the subject “Data deletion request”. Include the mobile number or email address linked to your account, and the name of your estate, site or app; or
• through your Client, by asking your Client’s administrator to remove you.

Our Information Officer handles deletion requests. We acknowledge a request within 5 business days and complete it within 30 days. We may first confirm that the request comes from you, for example by contacting you on your registered number.

Your account and most of your information form part of your Client’s records (see section 2), so we coordinate the deletion with your Client and its Reseller. We then delete or de-identify your account and personal information on the Client’s instructions, or confirm that the Client has done so, and let you know when this has been done. Deletion includes your facial and fingerprint templates and enrolment photographs, unless a Client must keep them under section 9.

Signing out of an app or uninstalling it does not delete your account.

After deletion, some information may be kept where the law allows it. Examples are access and incident records that a Client must keep for security or legal reasons, information needed for legal claims or obligations, and information in backups until they are overwritten. That information is kept securely and used only for those purposes.

You can also ask us to delete information that someone else entered about you, for example as their visitor. We will handle the request together with the Client concerned and its Reseller.

13. Children

The Services are intended for adults. Anyone under 18 may use them only with the consent and supervision of a parent or guardian, and only where the Client allows it.

We process children’s personal information, for example about household members or visitors who are minors, only with the consent of a parent or guardian or as otherwise permitted by POPIA. A child’s face is enrolled for facial recognition only with that consent. Where a person’s age is not known when a face is enrolled, the Client is responsible for confirming that the person is an adult or that consent has been given.

If you believe we hold a child’s personal information without proper authorisation, contact us and we will delete it.

14. Direct marketing

We do not use the Services to send you unsolicited electronic direct marketing. Service messages are not direct marketing. These include OTPs, security alerts, visitor notifications and notices from your Client.

If we send our business customers marketing about our own products, we do so only as section 69 of POPIA permits, and every message lets you opt out.

15. Cookies and similar technologies

Our websites and web portals use the cookies and similar technologies they need to work. They use them to:

• keep you signed in and secure your session;
• protect against cross-site request forgery and other attacks;
• balance load; and
• remember preferences, such as your language.

Our apps use similar technologies, such as local storage and app identifiers, for the same purposes and for diagnostics and analytics.

Some pages load content from third parties, such as fonts, maps or social-media components. Those third parties may receive your IP address and set their own cookies under their own policies.

We do not use cookies for advertising. You can block or delete cookies in your browser settings, but some parts of the portals may then stop working.

16. Third-party content and websites

The Services may display or link to content, forms and websites run by your Client or others, such as estate information pages, documents, videos and payment pages. That content is governed by its operator’s privacy policy, and we are not responsible for their practices.

When you open such content inside one of our apps, its operator may receive technical information about your device. Where a page needs them to work, the operator may also receive identifiers linked to your account.

17. Your responsibilities

When you use the Services, you agree to:

• give accurate and complete information, and keep it up to date;
• add other people, such as visitors, household members or staff, only when you are entitled to and they need access. By adding someone, you confirm that you have told them their information will be processed as this policy describes. You may not consent to biometric enrolment on another adult’s behalf;
• keep your credentials, OTPs, PINs and codes secure. You are responsible for activity carried out with credentials you share; and
• use the Services lawfully and in line with your Client’s rules.

We take reasonable steps to keep personal information accurate and up to date, and you can update your profile in the app or ask your Client or us to correct it.

18. Officers, guards and Client personnel

If you use the Services as an officer, guard, supervisor, controller or administrator, your employer and the Client process information about your use of them. This applies whether you use your own device or one provided by your employer or the Client. The information includes:

• your identity and login details;
• the device you use and its identifiers;
• the location of your device when you perform scans and transactions;
• the actions you perform, such as scans, entries, notes and calls;
• screen recordings and screenshots of the app taken while you process transactions;
• time and attendance records; and
• audit logs.

It is used to:

• manage security operations;
• verify activity;
• investigate incidents; and
• meet contractual and legal obligations.

Company-managed devices may be configured and monitored by your employer or the Client, for example through mobile device management. Your employer’s own policies also apply to you.

19. Changes to this policy

We may update this policy from time to time, for example when we change the Services or when the law changes. The latest version is always published at this address, with the date it was last updated.

If we make significant changes, we will take reasonable steps to let you know, for example through the apps, your Client or by email. To the extent the law permits, the updated policy applies from the date it is published.

20. Contact us and the Information Regulator

For questions about information your site keeps, contact Mount Edgecombe Country Club Estate:

To contact Wyobi:

If you are not satisfied with how we have handled your personal information, you may complain to the Information Regulator. We would appreciate the chance to address your concern first.

21. Governing law

This policy is governed by the laws of the Republic of South Africa.

Nothing in this policy limits any right you have that cannot lawfully be limited.