Privacy Policy

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information processed through the JaNee mobile application, the JaNee website and related JaNee services operated by Platinum Milling (Pty) Ltd.

JaNee is intended to be available internationally. Privacy and data-protection rights differ between countries and regions. Where applicable law provides rights or protections in addition to those described in this Privacy Policy, we will process personal information in accordance with those applicable requirements.

2. What JaNee Does

JaNee helps individuals and businesses organise and monitor assets, requirements, renewals, expiry dates and related information.

Depending on your account, subscription and available features, JaNee may provide asset and requirement management, renewal history, expiry reminders, cloud synchronisation and functionality for storing supporting documents and photographs.

3. Personal Information We Process

The personal information we process depends on how you use JaNee, the features available to you and the information you choose to provide.

Account and profile information

This may include:

• your full name;
• email address;
• account and user identifiers;
• your selected personal or business workspace type;
• business name, where applicable;
• a profile photograph or business logo that you choose to upload;
• authentication and account-security information; and
• communications relating to your account or support requests.

Authentication is provided through our authentication infrastructure. We do not need to know or display your plain-text password.

Information you store in JaNee

You may choose to provide information including:

• personal or business assets and categories;
• requirements and descriptions;
• renewal and expiry dates;
• notes;
• renewal history;
• information relating to vehicles, companies, employees, properties, equipment, insurance, contracts or other personal or business matters;
• documents, photographs, file names, file types and related attachment information where attachment functionality is available;
• information concerning other people that you choose to enter into JaNee; and
• other information you voluntarily provide through the service.

Subscription and transaction information

If you purchase a paid JaNee subscription, the applicable application marketplace, such as Apple App Store, Google Play or Huawei AppGallery, processes the purchase and payment.

We may receive and process information necessary to verify and administer your subscription, such as the subscription product, billing period, marketplace or provider, transaction or subscription identifiers, subscription status and applicable subscription period information.

We do not receive or store your complete payment-card number merely because you purchase a JaNee subscription through an application marketplace. Payment information provided directly to a marketplace is processed according to that marketplace's own terms and privacy practices.

Technical and security information

We and our service providers may process technical information reasonably necessary to provide, secure and troubleshoot JaNee. Depending on the service and circumstances, this may include authentication events, network requests, timestamps, application or device information, security information, server logs and technical error information.

4. Device Permissions and User-Selected Files

Certain JaNee features require access to functionality provided by your device.

If you choose to add a profile image, business logo or photo attachment, JaNee may request permission to access photographs or media on your device. JaNee accesses the image you select for the purpose of providing the requested feature.

If you choose to add a document, JaNee uses the device's file or document selection functionality to allow you to select the file you wish to upload.

JaNee does not require you to provide photo or document access unless you choose to use a feature that requires that access. Device permissions can be managed through your device settings, subject to the controls provided by your operating system.

5. Documents, Photographs and Sensitive Content

Documents, photographs, notes and other information that you choose to store in JaNee may contain personal, confidential, commercially sensitive or other sensitive information.

You are responsible for deciding what information to upload and for ensuring that you are entitled to store and process that information through JaNee.

You should avoid storing information that is unnecessary for the purpose for which you use JaNee and should take particular care before uploading highly sensitive information.

6. Information About Other People

JaNee may allow you to record information relating to employees, contractors, customers, contacts, family members or other individuals.

If you provide personal information about another person, you are responsible for ensuring that you have an appropriate lawful basis, authority or permission to process that information and that your use of it complies with applicable privacy, employment and other laws.

Where an organisation uses JaNee to manage personal information for its own purposes, that organisation may be the controller, responsible party or equivalent entity in relation to that information under applicable law. In such circumstances, Platinum Milling (Pty) Ltd may process that information on the organisation's behalf to provide JaNee.

7. How and Why We Use Personal Information

We may process personal information to:

• create and administer JaNee accounts;
• authenticate users and protect accounts;
• provide and operate JaNee's features;
• store and synchronise user records;
• display assets, requirements, renewal dates and expiry dates;
• provide renewal history;
• provide reminders and notifications;
• store and retrieve user-selected attachments;
• verify and administer subscriptions and entitlements;
• send verification, password-reset, security and other transactional communications;
• respond to support and privacy requests;
• maintain, secure and troubleshoot the service;
• prevent, detect or investigate fraud, abuse and security incidents;
• establish, exercise or defend legal rights;
• comply with applicable legal obligations; and
• improve the reliability and operation of JaNee.

8. Legal Bases for Processing

The legal basis on which we process personal information depends on the information, purpose and law that applies to the processing.

Where laws such as the GDPR or UK GDPR require us to identify a legal basis, we may rely on one or more of the following, as appropriate:

• Performance of a contract — where processing is necessary to create your account or provide the JaNee service and features you request;
• Legitimate interests — where processing is necessary for legitimate operational, security, fraud prevention, support or service-improvement interests, provided those interests are not overridden by applicable rights and interests;
• Legal obligations — where processing is necessary to comply with applicable law;
• Consent — where applicable law requires consent or where we specifically ask you to consent to a particular activity; and
• another lawful basis recognised by applicable law where appropriate.

Where processing is based on consent, you may withdraw that consent as permitted by applicable law. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

9. Notifications and Reminders

If you enable notifications, JaNee may schedule reminders on your device relating to assets, requirements and dates that you record in the service.

Notification content may include information such as the name of an asset or requirement. You should consider the privacy of information displayed on your device's lock screen and configure your device notification settings appropriately.

Notification permissions can be controlled through JaNee and/or your device settings, depending on your device and operating system.

Notifications and reminders are convenience features and should not be relied upon as the sole method of monitoring legal, regulatory, contractual, financial, personal or business deadlines.

10. Local Storage and Cloud Synchronisation

JaNee may store certain information locally on your device to maintain your session, remember settings and provide application functionality.

Account and JaNee record information may also be synchronised with our cloud infrastructure so that information can be stored and retrieved as part of the service.

Temporary copies of files may be created on your device when you select, download, open or share an attachment. Such copies may remain temporarily in application or operating-system cache storage and are subject to device and operating-system behaviour.

11. Service Providers and Application Marketplaces

We use third-party providers to operate, secure and support JaNee. These providers may process information where necessary to provide their services to us or to you.

Providers and categories of providers may include:

• Supabase — authentication, database, backend infrastructure and cloud file storage;
• Resend — transactional email delivery, including verification and password-reset communications;
• website, hosting, infrastructure and security providers used to operate JaNee and its website;
• Apple — where you obtain or use JaNee through Apple services or purchase an Apple App Store subscription;
• Google — where you obtain or use JaNee through Google Play or purchase a Google Play subscription; and
• Huawei — where you obtain or use JaNee through Huawei AppGallery or purchase an applicable Huawei subscription.

Application marketplaces and certain platform providers may process information independently under their own privacy policies and terms.

Our providers may use their own subprocessors where permitted under their arrangements with us and applicable law.

12. Disclosure of Personal Information

We may disclose personal information where reasonably necessary:

• to service providers processing information on our behalf;
• to application marketplaces and platform providers;
• at your direction, authorisation or with your consent;
• to comply with applicable law, court orders or lawful legal process;
• to protect the rights, property, security or safety of JaNee, Platinum Milling (Pty) Ltd, our users or others;
• to prevent or investigate fraud, abuse or security incidents;
• to professional advisers where reasonably necessary and subject to appropriate obligations; or
• as part of a lawful merger, acquisition, restructuring, financing, sale or transfer of all or part of the relevant business or assets, subject to applicable legal requirements.

We do not sell your personal information.

JaNee does not currently use personal information for third-party targeted advertising.

13. International Processing and Transfers

JaNee is operated from South Africa and uses technology and service providers that may operate in multiple countries. Accordingly, personal information may be processed in a country different from the country in which you live.

Where applicable data-protection law restricts international transfers of personal information, we take steps designed to ensure that a lawful transfer mechanism or other permitted basis is used where required. Depending on the applicable law and circumstances, this may include transfers to jurisdictions recognised as providing adequate protection, contractual safeguards, other legally recognised safeguards, or an applicable statutory exception.

The protections and government-access rules that apply to information may differ between countries.

You may contact us using the details below if you have questions regarding the international processing of your personal information.

14. Information Security

We use reasonable technical and organisational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, misuse or access.

Measures may include authentication, access controls, restricted cloud-storage access, encrypted network communications and security controls provided by our infrastructure providers.

No internet-based service, device or electronic storage system can be guaranteed to be completely secure. You are responsible for maintaining the security of your device and account credentials and should contact us if you suspect unauthorised access to your account.

15. Security Incidents

If we become aware of a personal-information security compromise, we will investigate it and take steps required by applicable law. Where legally required, this may include notifying affected individuals, regulators or other competent authorities.

16. Data Retention

We retain personal information for no longer than reasonably necessary for the purposes for which it is processed, subject to applicable legal, regulatory, accounting, security, dispute resolution and record-keeping requirements.

Retention periods vary depending on the nature of the information, why it is processed, whether an account remains active, applicable legal requirements and whether the information is reasonably required to establish, exercise or defend legal claims.

Information that is no longer required may be deleted, anonymised or de-identified, as appropriate.

17. Account and Data Deletion

JaNee provides functionality to permanently delete your account from within the application. Account deletion is permanent and may result in deletion of the personal or business records, attachments, profile information and other information associated with your account.

If you cannot access the JaNee application, you may also request account deletion through our Delete Account page.

Before deleting your account, you should retain copies of information that you are legally, personally or operationally required to keep.

Following a valid deletion request, account-associated information will be deleted or de-identified as appropriate, except where retention is required or permitted by applicable law or is reasonably necessary for matters such as security, fraud prevention, regulatory compliance, dispute resolution or the establishment, exercise or defence of legal claims.

Residual information may remain temporarily in backups, caches or system logs until those records are overwritten, deleted or expire through ordinary retention processes.

Subscriptions and account deletion

Deleting your JaNee account does not necessarily cancel a paid subscription purchased through an application marketplace.

If you have an active subscription through Apple App Store, Google Play, Huawei AppGallery or another marketplace, you should manage or cancel that subscription through the applicable marketplace. Marketplace billing may continue until the subscription is cancelled in accordance with that provider's terms.

18. Your Privacy Rights

Depending on where you live and the law applicable to the processing, you may have rights concerning your personal information. These may include the right to:

• ask whether we process personal information about you;
• request access to your personal information;
• request correction of inaccurate or incomplete information;
• request deletion or erasure in circumstances provided by law;
• request restriction of certain processing where applicable;
• object to certain processing where applicable;
• receive certain personal information in a portable format where a right to data portability applies;
• withdraw consent where processing is based on consent, subject to applicable law;
• object to or opt out of certain direct marketing;
• lodge a complaint with an applicable privacy or data-protection authority; and
• exercise other privacy rights provided by the laws applicable to you.

These rights are not absolute and may be subject to conditions, limitations and exceptions under applicable law.

We may take reasonable steps to verify your identity before responding to a privacy request and may request information reasonably necessary to locate the relevant records.

Where applicable law permits an authorised agent to submit a request on your behalf, we may require appropriate evidence of that authority.

19. South Africa — POPIA

Platinum Milling (Pty) Ltd is based in South Africa and processes personal information subject to the Protection of Personal Information Act 4 of 2013 ("POPIA") where POPIA applies.

For processing in which Platinum Milling (Pty) Ltd determines the purpose and means of processing, it may act as the "responsible party" as that term is used in POPIA.

Subject to POPIA, data subjects may have rights including access, correction, deletion or destruction in applicable circumstances, objection to certain processing, withdrawal of consent where applicable and the right to complain to the Information Regulator (South Africa).

20. European Economic Area

Where the European Union General Data Protection Regulation ("GDPR") applies to our processing, individuals in the European Economic Area may have the rights provided under the GDPR, subject to applicable conditions and exceptions.

These may include rights of access, rectification, erasure, restriction, objection and data portability, as well as the right to withdraw consent where consent is relied upon.

You may also have the right to lodge a complaint with the competent data-protection supervisory authority in the country where you live, work or where you believe an infringement occurred.

21. United Kingdom

Where United Kingdom data-protection law applies to our processing, individuals may have applicable rights under the UK GDPR and Data Protection Act 2018, as amended from time to time.

You may also have the right to complain to the United Kingdom Information Commissioner's Office or another competent authority, as applicable.

22. Other Countries and Regions

Privacy laws in other countries and regions may provide additional rights concerning access, correction, deletion, consent, objection, portability, use or disclosure of personal information.

Where such laws apply to our processing, we will handle valid privacy requests in accordance with the applicable legal requirements.

Nothing in this Privacy Policy is intended to limit rights that cannot lawfully be limited or waived under applicable data-protection or consumer law.

23. Direct Marketing

Transactional communications necessary for your account or service, such as verification, password-reset, security, subscription-related or important operational communications, are not promotional marketing merely because they are sent electronically.

If JaNee introduces promotional electronic communications, we will provide notices, consent mechanisms and opt-out choices as required by applicable law.

24. Advertising, Sale of Data and Tracking

JaNee does not currently operate an advertising-supported service and does not currently use personal information for third-party targeted advertising.

We do not sell personal information for monetary consideration. If our practices materially change, this Privacy Policy and any legally required choices or notices will be updated before or when required by applicable law.

25. Cookies and Website Technologies

The JaNee website does not currently use non-essential cookies, advertising cookies or similar tracking technologies for analytics or targeted advertising.

Certain essential technical functionality provided by our hosting, security or infrastructure providers may involve technologies necessary to deliver, protect or operate the website.

If we introduce analytics, advertising or other non-essential cookies or similar technologies in the future, we will update this Privacy Policy and provide any notice, consent mechanism or other choices required by applicable law.

26. Automated Decision-Making

JaNee does not currently make decisions producing legal or similarly significant effects about users solely through automated processing or profiling.

Features such as expiry status calculations and reminders are organisational tools based on information entered into JaNee and are not intended to constitute automated legal, financial, employment, insurance or regulatory decisions.

27. Children

JaNee is intended for adults managing personal or business information and is not designed or directed for independent use by children.

We do not knowingly offer JaNee accounts directly to children where parental or guardian authorisation would be required by applicable law.

If you believe a child has provided personal information to JaNee contrary to applicable requirements, please contact us so that we can investigate and take appropriate action.

28. Changes to This Privacy Policy

We may update this Privacy Policy when JaNee's functionality, subscription model, service providers, legal requirements or information-handling practices change.

The effective date at the top of this policy identifies when the current version became effective.

Where required or appropriate, we may provide additional notice of material changes through JaNee, our website, email or another suitable method.

29. Complaints

If you believe your personal information has been handled improperly, you may contact us using the details below so that we can investigate your concern.

Depending on your location and applicable law, you may also have the right to complain to the privacy, information or data-protection regulator responsible for your jurisdiction.

South African data subjects may, where applicable, lodge a complaint with the Information Regulator (South Africa).