PRIVACY POLICY

Effective Date: 2026-02-15

This Privacy Policy describes how Casey Harper trading as Harper Interactive processes personal information in accordance with POPIA.

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1. Information We Collect

1.1 Visitors

• IP address (processed for location estimation only and not stored)
• Analytics data via Google Analytics 4
• Cookie identifiers

1.2 Clients

• Full name
• Email address
• Phone number
• Company name
• Billing details

We do not sell personal information.

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2. Cookies & Analytics

We use:

• Google Analytics 4 (GA4)
• Internal analytics systems

These may process IP addresses and device identifiers.
Data may be processed outside South Africa.

We recommend users enable cookie controls via browser settings.

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3. Lawful Basis (POPIA)

Processing occurs on the basis of:

• Contractual necessity;
• Legitimate business interest;
• Legal compliance;
• Consent (where required).

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4. Payment Processing

Payments are processed via:

• EFT
• Payfast (PCI DSS Level 1 compliant provider)

We do not store card details.

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5. Data Retention

• Client data retained for duration of service.
• Upon termination, data is deleted after 90 days.
• Backup archives may contain residual encrypted copies.

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6. Hosting Clients (Processor Role)

Where we host client websites:

• We act as Data Processor.
• The Client remains responsible for end-user compliance.
• We implement reasonable security safeguards.

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7. Security

We implement reasonable administrative, technical, and physical safeguards, including:

• Encrypted connections;
• Secure hosting infrastructure;
• Restricted administrative access.

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8. International Transfers

Analytics data may be transferred internationally.
We rely on contractual and technical safeguards.

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9. Data Subject Rights

Under POPIA, you may:

• Request access;
• Request correction;
• Object to processing;
• Request deletion (subject to legal limits).

Requests may be submitted using the contact details on our website.

Complaints may be lodged with the Information Regulator (South Africa).

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10. Changes

We reserve the right to update this Privacy Policy.

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By using our services, you acknowledge this Privacy Policy.