Data Usage Policy

Jaspa Innovate (Pty) Ltd ("Jaspa", "we", "us") is committed to protecting the personal information of every person who interacts with our business, websites, and digital platforms. This Data Usage Policy explains what personal information we collect, why we collect it, how we use and protect it, and what rights you have in relation to it. This Policy is read together with our POPIA Compliance Statement.

1. Who This Policy Applies To

This Policy applies to:

• Visitors to any Jaspa website (jaspa.co.za and all subdomain platforms)
• Individuals who submit enquiries via contact forms, email, or phone
• Clients who procure Jaspa services or subscribe to Jaspa platforms
• End users of Jaspa platforms (Jaspa One, Jaspa ECD, Jaspa Mail, Jaspa Workplace) acting on behalf of a Client organisation
• Job applicants and suppliers who provide personal information to Jaspa

2. What Personal Information We Collect

Contact & identity information: Full name, job title, company name, email address, phone number, and physical address. Collected when you submit a contact form, request a consultation, or enter into a service agreement with us.

Business information: Industry, company size, operational context, and business challenges. Collected to enable us to provide relevant, tailored services.

Platform usage data: Usernames, login activity, feature usage patterns, and device/browser information. Collected automatically when you use any Jaspa software platform.

Financial information: Invoice and payment records, banking details for EFT processing (collected only for billing purposes and never stored in our web systems).

Communication records: Email correspondence, support tickets, and consultation notes. Retained for service delivery and continuity purposes.

Website analytics: IP address, browser type, pages visited, session duration, and referral source. Collected via Google Analytics and Google Tag Manager for website performance analysis. This data is aggregated and anonymised where possible.

3. How We Collect Your Information

• Directly from you when you complete a form, send an email, or call us
• Automatically via cookies and analytics tools when you visit our websites
• From your organisation when your employer or company procures Jaspa services on your behalf
• From publicly available sources for legitimate business development purposes

4. Why We Process Your Personal Information

We process personal information only for the following lawful purposes:

• Service delivery: To fulfil contracted services, onboard clients, configure platforms, and provide technical support
• Communication: To respond to enquiries, send service updates, and notify you of changes material to your service
• Billing and financial administration: To generate invoices, process payments, and manage accounts
• Legal compliance: To meet our obligations under South African law, including POPIA, the Consumer Protection Act, and tax legislation
• Platform improvement: To analyse usage patterns and improve the functionality and user experience of our platforms (using aggregated, non-identifiable data where possible)
• Marketing: To send relevant updates about Jaspa services, only with your consent or within the bounds of existing business relationships as permitted by POPIA

5. How We Share Your Information

We do not sell, rent, or trade your personal information. We may share it with:

• Service providers: Cloud hosting providers, email platform providers, analytics tools, and payment processors, only to the extent necessary to deliver our services, and subject to data processing agreements
• Professional advisors: Legal counsel, auditors, and accountants under confidentiality obligations
• Regulators and law enforcement: Where we are required to by law or valid legal process

Any third-party service provider processing personal information on our behalf is required to apply equivalent data protection standards to those described in this Policy.

6. Cookies and Tracking Technologies

Our websites use cookies and similar technologies to function correctly, remember your preferences, and analyse traffic. We use Google Analytics and Google Tag Manager. By continuing to use our website, you consent to the use of analytics cookies. You may disable cookies in your browser settings, though this may affect certain site functionality.

We do not use retargeting pixels or behavioural advertising cookies without your explicit consent.

7. Data Retention

We retain personal information only for as long as necessary for the purpose for which it was collected or as required by law:

• Active client data: retained for the duration of the service relationship plus 5 years
• Enquiry records (non-converted): retained for 12 months
• Platform user data: retained for 30 days after account termination, then deleted
• Financial records: retained for 7 years as required by the South African Revenue Service
• Website analytics data: retained for 26 months per Google Analytics default settings

8. Data Security

We implement appropriate technical and organisational measures to protect personal information against unauthorised access, accidental loss, destruction, or disclosure. These measures include encrypted HTTPS connections on all websites, access controls on internal systems, role-based permissions on all platforms, and regular security assessments. While we apply robust safeguards, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

9. Cross-Border Data Transfers

Some of our service providers operate servers outside South Africa (e.g. cloud infrastructure in Europe or the United States). Where personal information is transferred internationally, we ensure that appropriate safeguards are in place consistent with the requirements of POPIA's cross-border transfer provisions.

10. Your Rights

Under POPIA and applicable South African law, you have the right to:

• Request access to the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information (subject to our legal retention obligations)
• Object to the processing of your information for direct marketing purposes
• Lodge a complaint with the Information Regulator of South Africa

To exercise any of these rights, contact our Information Officer at info@jaspa.co.za. We will respond within 30 days.

11. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated via our website or by email to active clients. The "Last updated" date at the top of this page reflects the most recent revision.

12. Contact & Information Officer

Jaspa Innovate (Pty) Ltd
Information Officer: Sibusiso Ndlovu
Email: info@jaspa.co.za
Phone: 087 250 0784
Pretoria, Gauteng, South Africa