Platform Privacy Policy

VulaCheck (Pty) Ltd as Responsible Party

Version 1.0 · Effective 27 June 2026 · Last updated 27 June 2026

This Privacy Policy explains how VulaCheck (Pty) Ltd processes personal information for which VulaCheck is itself the Responsible Party, in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”).

1. Who we are

VulaCheck (Pty) Ltd, registration number 2026/307850/07, of The Circle Business Center, Douglas Crowe Drive, Durban, KwaZulu-Natal, 4420, is the Responsible Party for the personal information described in this policy. Our Information Officer is Fidel Okillah, who can be reached at fidel@vulacheck.com.

2. Scope of this policy

2.1 This policy covers personal information VulaCheck controls in its own right: prospective and current lender clients and their personnel, website visitors, billing contacts, and people who contact our support.

2.2 It does not cover the personal information of a lender’s applicants and borrowers processed through the Platform. For that information the lender is the Responsible Party and VulaCheck acts as its Operator under the Data Processing Agreement. How a lender uses borrower information is governed by that lender’s own privacy notice.

3. Information we collect

3.1 Account and signup information: company/trading name, NCR registration number, company registration number, and the name, ID number, email and phone number of the person who registers and other authorised users.

3.2 Verification documents you upload at signup (such as NCR certificate, CIPC registration and the owner’s ID).

3.3 Billing information processed via our payment provider (we do not store full card details).

3.4 Usage and technical data: log data, device and browser information, and actions taken on the Platform.

3.5 Communications: support requests and correspondence with us.

4. Why we process it and our lawful basis

4.1 To create and administer your account and provide the Platform (performance of our contract with you).

4.2 To verify prospective lenders and prevent fraud and misuse (legitimate interest; legal obligation where applicable).

4.3 To bill you and keep financial records (performance of contract; legal obligation).

4.4 To secure, support and improve the Platform (legitimate interest).

4.5 To send service messages, and, where you have opted in, marketing (consent for marketing, which you may withdraw at any time).

5. Who we share it with

5.1 We share personal information with the service providers that help us run the Platform, listed below, under appropriate agreements.

5.2 We may also disclose personal information where required by law or to protect our rights.

6. Cross-border transfers

6.1 Some processing takes place outside South Africa — in particular hosting in the European Union (Ireland) and AI-assisted processing in the United States. We rely on the bases permitted by section 72 of POPIA, including that the recipient is subject to a law or binding agreement providing an adequate level of protection, that the transfer is necessary to perform our contract with you, or your consent.

7. How long we keep it

7.1 We keep account and billing records for as long as you are a client and thereafter as required for legal, tax and audit purposes. Verification and signup records are retained to evidence onboarding and compliance. We delete or de-identify personal information when it is no longer needed for these purposes.

8. How we protect it

8.1 We apply appropriate, reasonable technical and organisational measures, including encryption in transit and at rest, role-based access control, audit logging, encrypted backups, and security monitoring, and we review these measures over time.

9. Your rights

9.1 Subject to POPIA, you may request access to, or correction or deletion of, your personal information, object to processing, or withdraw consent to marketing. To exercise a right, contact our Information Officer at fidel@vulacheck.com.

9.2 You have the right to lodge a complaint with the Information Regulator (South Africa): inforegulator.org.za; complaints.IR@inforegulator.org.za.

10. Cookies

10.1 Our website and Platform use cookies and similar technologies that are necessary to operate the service and, with your consent where required, to understand usage. You can control non-essential cookies through your browser or our cookie controls.

11. Changes to this policy

11.1 We may update this policy. Material changes will be published with a new version number and effective date.

12. Contact

12.1 Information Officer: Fidel Okillah, fidel@vulacheck.com, VulaCheck (Pty) Ltd, The Circle Business Center, Douglas Crowe Drive, Durban, KwaZulu-Natal, 4420.