1. Introduction

This Privacy Policy sets out how SALUFA, a livestock marketplace platform operated by Amaqhawe SA Technologies (Pty) Ltd (trading as AMQ Digital) ("we", "us", or "our"), collects, uses, stores, discloses, and protects your personal information in accordance with the Protection of Personal Information Act (POPI Act, Act 4 of 2013) of South Africa.

By accessing or using the SALUFA platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal information as described herein.

2. Information We Collect

2.1 Personal Information

• Full name and contact details (email address, phone number)
• South African ID number (required for seller verification)
• Physical address and location information
• Profile photographs and user-generated content

2.2 Verification Documents

• Identity documents (South African ID, passport, or driver's licence)
• Proof of address documentation
• Business registration certificates (where applicable)
• Animal health certificates and vaccination records
• Livestock breed registration documents
• Photographs and videos of livestock

2.3 Transaction Information

• Purchase history and transaction records
• Communications between buyers and sellers conducted via the platform
• Reviews, ratings, and dispute submissions
• Negotiation offers and counter-offers

2.4 Technical Information

• IP address and device identifiers
• Browser type and operating system
• Platform usage data, session identifiers, and analytics

3. Legal Basis for Processing

We process your personal information only where a lawful basis exists under the POPI Act. The applicable bases are:

• Consent: You have given explicit consent by registering on and using the SALUFA platform.
• Contractual necessity: Processing is required to fulfil the agreement between you and SALUFA, including facilitating transactions and verifying seller eligibility.
• Legal obligation: We are required to retain certain records to comply with South African law, including the Income Tax Act and the Financial Intelligence Centre Act (FICA).
• Legitimate interest: We process limited data to detect fraud, ensure platform security, and improve our services, provided these interests do not override your fundamental rights.

4. How We Use Your Information

• Account Management: To create, maintain, and secure your user account.
• Seller Verification: To verify seller identities and ensure the integrity of the platform.
• Transaction Facilitation: To process purchases, coordinate payments, and confirm cash sales.
• Communications: To send transactional notifications, alerts, and platform updates.
• Legal Compliance: To meet statutory obligations and cooperate with lawful investigations.
• Platform Improvement: To analyse usage patterns and enhance the user experience.
• Dispute Resolution: To investigate and resolve disputes between buyers and sellers.

5. Document Storage and Security

5.1 Storage

All uploaded documents are stored on encrypted cloud infrastructure. Access is strictly limited to authorised personnel who require it for verification and compliance purposes.

5.2 Retention

• Verification documents are retained for the duration of an active account.
• Upon account closure, documents are securely deleted within 30 days.
• Transaction records are retained for a minimum of 7 years in compliance with South African legal requirements.

5.3 Limitations on Use

Documents submitted for verification are used solely for that purpose. We do not:

• Share your documents with third parties without your explicit consent, except where required by law.
• Use your documents for marketing or profiling purposes.
• Retain copies of rejected or expired documents beyond the period necessary for the original purpose.

6. Information Sharing

6.1 With Other Users

• Buyers may view a seller's name, city, phone number, and verification status.
• Sellers may view a buyer's email address, purchase quantity, and messages.
• A seller's full address is only disclosed to a buyer after a conversation has been initiated.

6.2 With TradeSafe (Payment Processing)

All online payments are processed through TradeSafe, a licensed South African escrow and payment platform. SALUFA does not collect, store, or process any banking or payment card details directly. All financial credentials are submitted directly to and held exclusively by TradeSafe.

The following information is shared with TradeSafe solely to facilitate transactions:

• Full name and email address of the buyer and seller
• Transaction amount and listing reference
• Seller banking details (submitted by the seller directly to TradeSafe for payout purposes)

TradeSafe acts as an independent data controller in respect of all payment and banking data. Their processing is governed by their own Privacy Policy and is subject to the oversight of the Financial Sector Conduct Authority (FSCA) and applicable South African financial legislation. SALUFA has no visibility into or control over the banking details submitted to TradeSafe.

6.3 With Other Service Providers

• Cloud infrastructure providers (for secure storage and platform operation)
• Email service providers (for transactional notifications)

All third-party service providers are engaged under data processing agreements that require them to handle your information in accordance with applicable privacy legislation.

6.4 Legal Disclosure

We may disclose personal information where required by law, court order, or a lawful request from a competent authority, or where necessary to protect the rights, property, or safety of SALUFA, its users, or the public.

7. Cookies and Tracking Technologies

SALUFA uses cookies and similar technologies (including local storage and session storage) to operate the platform and improve your experience. These technologies are described in our full Cookie Policy. A summary is provided below.

• Essential cookies: Required for authentication, session management, and platform security. These cannot be disabled without preventing access to core features.
• Functional cookies: Used to remember your preferences, such as theme settings and navigation state.
• Analytics: Anonymised, aggregated usage data is collected to understand how users interact with the platform. This data is not linked to individual identities.

We do not use advertising or retargeting cookies, and we do not share tracking data with third-party advertisers.

8. Your Rights Under the POPI Act

As a data subject, you are entitled to the following rights under the POPI Act:

• Right to Access: You may request a copy of the personal information we hold about you.
• Right to Correction: You may request the correction of inaccurate, incomplete, or outdated information.
• Right to Deletion: You may request the deletion of your personal information, subject to our legal retention obligations.
• Right to Object: You may object to the processing of your personal information in certain circumstances.
• Right to Restrict Processing: You may request that we limit how we use your information pending the resolution of a concern.
• Right to Data Portability: You may request that your information be provided in a structured, commonly used format.

To exercise any of the above rights, please contact us at privacy@amqdigital.com.

9. Data Deletion

9.1 How to Request Deletion

You have the right to request the deletion of your personal information from the SALUFA platform. To submit a deletion request, please contact us at privacy@amqdigital.com with the subject line "Data Deletion Request" and include your registered email address and full name. We will process your request within 30 days of verification.

9.2 In-App Account Deletion

You may also initiate account deletion directly from within the app by navigating to Settings → Delete Account. Once confirmed, your profile, listings, and personal data will be scheduled for permanent deletion within 30 days.

9.3 What Gets Deleted

• Your account profile, personal details, and contact information
• Uploaded verification documents and photographs
• Active listings and saved favourites
• Messages and conversation history

9.4 What Cannot Be Deleted (Legal Retention)

Certain records must be retained by law even after a deletion request, including:

• Transaction records, payment history, and escrow data — retained for 7 years in compliance with South African tax and financial legislation (Income Tax Act, FICA)
• Dispute records and related evidence where a legal process is active or pending
• Fraud investigation records required by law enforcement

These retained records will be isolated, not used for any other purpose, and permanently deleted once the applicable legal retention period has expired.

10. Data Security

We implement industry-standard technical and organisational measures to protect your personal information against unauthorised access, loss, alteration, or disclosure. These measures include:

• Encryption of data in transit and at rest
• Secure authentication protocols and access controls
• Regular security monitoring and infrastructure reviews
• Staff awareness and data protection practices

While we take all reasonable precautions, no system can guarantee absolute security. In the event of a data breach that poses a risk to your rights, we will notify you and the Information Regulator in accordance with our obligations under the POPI Act.

11. International Data Transfers

SALUFA currently operates on cloud-based infrastructure provided by third-party technology service providers. As a result, your personal information may be processed or stored on servers located outside of the Republic of South Africa. Where such transfers occur, we take reasonable steps to ensure that appropriate safeguards are in place, consistent with the requirements of the POPI Act. We remain committed to transitioning to South African-hosted infrastructure as the platform scales.

12. Children's Privacy

The SALUFA platform is intended for users who are 18 years of age or older. We do not knowingly collect personal information from minors. Should we become aware that a minor has submitted personal information without appropriate parental or guardian consent, such information will be deleted promptly.

13. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy from time to time to reflect changes in our practices or applicable legislation. Material changes will be communicated to users via email or an in-platform notification. Continued use of the platform following such notification constitutes acceptance of the revised policy.

14. Contact Us

15. Complaints to the Information Regulator

If you believe that we have not handled your personal information in accordance with the POPI Act, you have the right to lodge a complaint with the Information Regulator of South Africa: