Data Handling Policy

1. Who is accountable

Zizi Ventures (Pty) Ltd is the responsible party. The Information Officer is accountable for this policy, for the register of personal information we hold, and for the information audit that opens every two weeks. The team works to this policy day to day, and any uncertainty goes to the Information Officer rather than being decided in the moment.

2. The conditions we apply

• Accountability: one named officer, a written register, and a fortnightly audit that records what was checked.
• Processing limitation: we collect the minimum we need, lawfully, with consent or another ground POPIA allows.
• Purpose specification: every collection point says why the information is needed, and we keep to that purpose.
• Further processing limitation: information collected for one purpose is not quietly reused for another; a new purpose needs a new ground and a notice update.
• Information quality: records must be accurate, complete and up to date, and users can correct their own details in the app.
• Openness: the privacy notice and this policy are published and kept current.
• Security safeguards: technical and organisational measures, listed in section 5.
• Data subject participation: access, correction, deletion and objection requests are handled by the Information Officer within 30 days.

3. Grounds we rely on

• To run an account and a booking: the agreement with the customer.
• To vet an Agent, including identity and police clearance: the applicant's express consent, with the Information Regulator's prior authorisation where the law requires it.
• Safety features, location during a job and panic alerts: the legitimate interest in keeping people safe, met through features the user switches on.
• Tax, accounting and consumer records: legal obligations.
• Marketing: consent only, withdrawn at any time without losing access to the app.

4. Retention and deletion schedule

• Customer account and booking details: While the account is open, and after that only as the financial records rule below requires. Account deletion clears personal details from old bookings.
• Identity, selfie and police clearance (Agents): While the Agent is being vetted and while the profile is live. Deleted on account deletion or when the application ends.
• References (Agents): While the Agent is being vetted and while the profile is live. Deleted with the Agent profile.
• Bank details (Agents): While payouts are owed or payable. Removed with the Agent profile.
• Job records: checklists, photos, check-in times, ratings: While the account is open, then as the financial records rule requires. Job totals are kept, photos and checklists are not.
• Payment, payout, invoice and refund records: As tax and accounting law requires (5 years from the end of the tax year). Deleted once that period passes.
• Safety and incident records: 3 years, then reviewed and deleted. Kept longer only where a claim or criminal case is open.
• Consent and terms acceptances: Until consent is withdrawn, plus proof of the withdrawal. Proof is kept as evidence of compliance.
• Data subject requests and complaints: 3 years after the request is closed. Deleted once that period passes.
• Access and error logs: 12 months. Automatically rotated.

Deletion is real deletion: documents are removed from private storage, not left in a folder. A record past its period is destroyed unless a claim, an investigation or a legal hold is open, and that exception is recorded in the audit register. The schedule is reviewed with our attorney and at each information audit.

5. Security safeguards

• Vetting documents are stored privately and are never public; only approved staff accounts can open them.
• The staff portals are limited to admin accounts, and approval of a vetting step records who signed it off and when.
• Every Agent has their own check-in code, so a job can only be started by the booked Agent.
• Card and payment details are handled by the payment provider; we never store full card numbers.
• Access to the app is by personal login only. Staff never share passwords or accounts.
• Every operator that processes information for us is bound in writing to confidentiality, to our instructions, and to POPIA.

6. If something goes wrong

A suspected breach is reported to the Information Officer immediately. The officer assesses the risk, contains it, notifies the Information Regulator and the people affected as soon as reasonably possible where their information is at risk, tells them what to do to protect themselves, and records the incident and the response in the audit register.

7. Data subject requests

People exercise most of their rights themselves in the app: viewing and correcting details, withdrawing marketing consent, and deleting an account. Requests for access, correction, deletion, objection or complaint that come to the Information Officer are logged, answered within 30 days, and reported at the next audit. Requests are free. Requests for company records that are not personal information are handled under our PAIA manual.

8. Information Officer

9. Review

This policy is reviewed at every information audit and formally at least once a year. When the way we handle information changes, the change is made here first, then in the Privacy Policy, and then in the app.