Legal

Privacy Policy

1. INTRODUCTION AND IDENTITY OF RESPONSIBLE PARTY

SectionFinder ("the Company", "we", "us", "our") is committed to protecting your privacy and processing your personal information responsibly, lawfully, and transparently.

This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you use the SectionFinder application ("the App").

This Privacy Policy is published in compliance with the Protection of Personal Information Act 4 of 2013 ("POPIA"), the Electronic Communications and Transactions Act 25 of 2002 ("ECTA"), and the Consumer Protection Act 68 of 2008 ("CPA").

Note for future UK users: This policy also addresses compliance with the UK GDPR and Data Protection Act 2018.

Note for future US users: This policy addresses California Consumer Privacy Act (CCPA) rights where applicable.

2. INFORMATION WE COLLECT

2.1 Information You Provide Voluntarily

When you contact us via the in-app feedback form or email, we collect your message content and any contact details you choose to provide, including your email address if voluntarily provided when contacting support.

2.2 Information Collected Automatically

We collect device information including device type, operating system version, and app version for crash reporting and compatibility purposes. We also collect anonymised usage analytics about which features you use, how frequently, and general navigation patterns, as well as crash reports and technical error logs to help us identify and fix bugs. We collect general geographic region at country level only, derived from your country selection within the App. We do not access your device's GPS or precise location.

2.3 Information We Do NOT Collect

We explicitly do not collect your name or surname, your identity number or passport number, financial or payment information, precise GPS location data, biometric information, health or medical information, race, gender, religion, or other special personal information as defined under POPIA, or login credentials as the App does not require account registration.

3. LEGAL BASIS FOR PROCESSING

3.1 South Africa (POPIA)

We process personal information on the following lawful grounds:
- Legitimate interest to improve App functionality, fix bugs, and ensure technical performance
- Consent where you voluntarily submit feedback or contact us
- Legal obligation where required by South African law

3.2 United Kingdom (UK GDPR) - Future

For UK users, processing is based on legitimate interests under Article 6(1)(f) for App improvement and security, and consent under Article 6(1)(a) for voluntary communications.

3.3 United States (CCPA) - Future

For California residents, we process information as necessary to provide our services and as described in this policy.

4. HOW WE USE YOUR INFORMATION

We use collected information solely for the following purposes:
- App performance monitoring and crash fixing - legitimate interest
- Improving App features based on usage patterns - legitimate interest
- Responding to support and feedback requests - consent
- Ensuring App security and preventing abuse - legitimate interest
- Compliance with legal obligations - legal obligation
- Anonymous analytics reporting - legitimate interest

We do not use your information for targeted advertising, selling to third parties, profiling or automated decision making, or marketing communications without consent.

5. ANALYTICS

5.1 The App uses Google Analytics for Firebase to collect anonymised usage data.
5.2 Analytics data is aggregated and cannot be used to identify individual users.
5.3 Analytics data collected includes screen views and navigation paths, feature interaction frequency, session duration, device type and operating system, and country-level geographic data.
5.4 No personally identifiable information is included in analytics data.
5.5 Google's privacy policy applies to data processed through Google Analytics and is available at: https://policies.google.com/privacy
5.6 You may opt out of analytics collection by contacting us at support [at] sectionfinder [dot] com

6. DATA SHARING AND THIRD PARTIES

6.1 We do not sell your personal information.
6.2 We share anonymised or technical data only with the following service providers who are bound by appropriate data processing agreements:
- Supabase - database and backend infrastructure - located in USA (AWS) - supabase.com/privacy
- Google Analytics - anonymised usage analytics - located in USA - policies.google.com/privacy
- Google Play Store - app distribution - located in USA - policies.google.com/privacy
6.3 Some of our service providers are located outside South Africa. Where personal information is transferred internationally, we ensure appropriate safeguards are in place in compliance with POPIA section 72.
6.4 We may disclose personal information if required to do so by law, court order, or lawful request by South African authorities.
6.5 We will never share your personal information with advertisers or marketing companies, data brokers, or any third party for commercial gain.

7. DATA RETENTION

7.1 We retain personal information only for as long as necessary for the purposes described in this policy.
7.2 Specific retention periods are as follows:
- Crash reports and error logs - 12 months
- Support and feedback communications - 24 months
- Anonymised analytics data - 36 months
- Country selection stored locally on device - until the App is uninstalled
7.3 Upon expiry of retention periods, personal information is securely deleted or anonymised.
7.4 You may request early deletion of your personal information at any time - see Section 9.

8. DATA SECURITY

8.1 We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, accidental loss or destruction, unlawful processing, and disclosure to unauthorised parties.
8.2 Security measures include encrypted database connections (SSL/TLS), Row Level Security on database tables, access controls limiting data access to authorised personnel only, and regular security reviews of our infrastructure.
8.3 While we take all reasonable precautions, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.
8.4 In the event of a data breach that poses a risk to your rights and freedoms, we will notify the Information Regulator and affected users as required by POPIA within the prescribed timeframes.

9. YOUR RIGHTS

9.1 Rights Under POPIA (South Africa)

You have the right to:
- Access a copy of personal information we hold about you
- Request correction of inaccurate or incomplete information
- Request deletion of your personal information
- Object to the processing of your personal information
- Withdraw consent where processing is based on consent
- Lodge a complaint with the Information Regulator of South Africa

9.2 Rights Under UK GDPR - Future UK Users

In addition to the above, UK users have the right to data portability to receive your data in a structured machine-readable format, restriction of processing in certain circumstances, and not to be subject to solely automated decisions with significant effects.

9.3 Rights Under CCPA - Future California Users

California residents have the right to know what personal information is collected, know whether personal information is sold or disclosed, opt out of the sale of personal information (we do not sell data), non-discrimination for exercising CCPA rights, and request deletion of personal information.

9.4 How to Exercise Your Rights

To exercise any of the above rights, contact us at support [at] sectionfinder [dot] com with the subject line "Privacy Rights Request". We will respond within 30 days as required by POPIA. We may require verification of your identity before processing requests.

10. COOKIES AND LOCAL STORAGE

10.1 The App stores the following data locally on your device:
- Your country selection preference
- Your acceptance of the Engineering Disclaimer
- App preferences and settings
10.2 This data is stored using your device's local storage and does not transmit personal information to our servers.
10.3 This locally stored data is deleted when you uninstall the App.
10.4 Web version: If you access SectionFinder via a web browser, standard browser local storage is used for the same purposes. No tracking cookies are used.

11. CHILDREN'S PRIVACY

11.1 The App is not directed at or intended for use by children under the age of 18.
11.2 We do not knowingly collect personal information from children under 18.
11.3 If you believe a child under 18 has provided personal information through the App, please contact us immediately at support [at] sectionfinder [dot] com and we will take steps to delete such information.
11.4 For future US users: We comply with the Children's Online Privacy Protection Act (COPPA) and do not knowingly collect information from children under 13.

12. INFORMATION REGULATOR

12.1 You have the right to lodge a complaint with the Information Regulator of South Africa if you believe we have processed your personal information unlawfully.

Information Regulator of South Africa:
- Website: www.inforegulator.org.za
- Email: inforeg@justice.gov.za
- Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
- POPIA Complaints: POPIAComplaints@inforegulator.org.za

12.2 For future UK users: UK users may lodge complaints with the Information Commissioner's Office (ICO) at www.ico.org.uk
12.3 For future US users: California residents may contact the California Attorney General's Office regarding CCPA complaints.

13. CHANGES TO THIS PRIVACY POLICY

13.1 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.
13.2 Material changes will be notified through the App.
13.3 Your continued use of the App after notification of changes constitutes acceptance of the updated Privacy Policy.
13.4 If you do not agree to the updated Privacy Policy, you must cease using the App.

14. CONTACT INFORMATION

SectionFinder Privacy Officer
Email: support [at] sectionfinder [dot] com
Subject line: "Privacy Enquiry"

We are committed to resolving privacy concerns promptly and transparently.

15. DISCLAIMER REGARDING LEGAL ADVICE

This Privacy Policy has been prepared to comply with applicable South African privacy legislation. It does not constitute legal advice. The Company recommends that users with specific legal concerns consult a qualified attorney.

SectionFinder is committed to protecting your personal information and processing it responsibly in accordance with applicable law.