Template - not yet legally reviewed. This document is a draft placeholder and must be reviewed and completed by a qualified legal practitioner before CentraPoint is offered to the public. Items in [square brackets] need to be filled in.

Privacy policy

Last updated: [date]

1. Who we are

CentraPoint is a payments platform operated by Global Software Services [registered company name and registration number] ("GSS", "we", "us"). We are the responsible party for personal information processed through this website and, where applicable, an operator on behalf of merchants who use the CentraPoint platform.

2. Protection of Personal Information Act (POPIA)

We process personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") of the Republic of South Africa and, where applicable, other data protection laws in the countries in which our services are used.

3. Information we collect

Contact details you submit through our contact form (name, email, company, phone, message).
Account information for users of the CentraPoint application.
Payment and transaction records processed on behalf of merchants (for example payer names, references, amounts and statuses).
Technical information needed to operate and secure the service (for example IP addresses in server logs).

This marketing website does not use advertising or analytics tracking cookies. [Update if this changes.]

4. How we use information

To respond to enquiries and provide the services you request.
To process payments, invoices, debit orders and reconciliation on behalf of merchants.
To secure our systems, prevent fraud and meet legal obligations.

5. Sharing information

We share information with payment gateways and banks selected by the merchant, with service providers (operators) that host or support the platform, and where required by law. [List categories of operators and any cross-border transfers, and the safeguards in place.]

6. Security

We apply appropriate technical and organisational measures, including encryption of gateway credentials at rest. See our security page.

7. Retention

[State retention periods for each category of information, including statutory record-keeping requirements.]

8. Your rights

Under POPIA you may request access to, correction of, or deletion of your personal information, object to processing, and lodge a complaint with the Information Regulator of South Africa.

9. Information Officer

[Name, email and physical address of the Information Officer.]

10. Changes

We may update this policy from time to time. The latest version will always be published on this page.