1. Introduction

Virtual Chelete (Pty) Ltd ("Virtual Chelete", "we", "our", "us") respects your privacy and is committed to protecting your personal information in accordance with the Protection of Personal Information Act, 2013 (POPIA), the Financial Intelligence Centre Act, 2001 (FICA), and applicable regulations issued by the South African Reserve Bank (SARB).

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, website, and services (collectively, the "Platform").

2. Information Officer

In compliance with POPIA, Virtual Chelete has appointed an Information Officer responsible for ensuring compliance with data protection laws.

3. Information We Collect

We may collect and process the following types of personal information:

3.1 Personal Identification Information (KYC)

• Full name
• South African ID number or passport number
• Date of birth
• Contact details (email address, phone number)
• Proof of address

3.2 Financial Information

• Bank account details
• Transaction history
• Wallet balances
• Payment details

3.3 Technical Information

• Device information (model, operating system)
• IP address
• App usage data
• Location data (where required for fraud prevention)

3.4 Biometric Information

• Facial recognition data used strictly for authentication and fraud prevention

4. Purpose of Processing

We process personal information for the following purposes:

• Account creation and management
• Processing payments and transactions
• Identity verification (Know Your Customer - KYC)
• Fraud detection and prevention
• Compliance with Anti-Money Laundering (AML) obligations under FICA
• Communication and notifications
• Service improvement and analytics

5. Legal Basis for Processing

We process personal information based on:

• User consent
• Performance of a contract
• Legal and regulatory obligations (POPIA, FICA, SARB directives)
• Legitimate interests, including fraud prevention and system security

6. Sharing of Personal Information

We may share your information with:

• Licensed banks and Payment Service Providers (PSPs)
• Regulatory authorities (including SARB and the Financial Intelligence Centre)
• Identity verification providers
• Fraud prevention and risk management partners
• Cloud hosting and infrastructure providers
• Law enforcement where required by law

7. Cross-Border Data Transfers

Where personal information is transferred outside South Africa, we ensure that:

• The recipient is subject to a law, binding agreement, or corporate rules that provide adequate protection; or
• You have consented to the transfer; or
• The transfer is necessary for contract performance

8. Data Security Measures

We implement industry-standard security controls, including:

• End-to-end encryption of sensitive data
• Secure APIs and infrastructure
• Multi-factor authentication (OTP and biometrics)
• Continuous monitoring for suspicious activity
• Access control and role-based permissions

9. Data Retention

We retain personal information in accordance with legal and regulatory requirements, including:

• FICA record-keeping requirements (minimum of 5 years)
• Transaction and audit logs for compliance and dispute resolution

After this period, data will be securely deleted or anonymised.

10. Your Rights Under POPIA

You have the right to:

• Access your personal information
• Request correction or deletion
• Object to processing
• Withdraw consent
• Lodge a complaint with the Information Regulator

Requests may be submitted to support@virtualchelete.co.za

11. Automated Decision-Making and Profiling

We may use automated systems to detect fraud and assess transaction risks. These systems do not make final decisions without human oversight where legally required.

12. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Improve user experience
• Analyse platform usage
• Enhance security

13. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors.

14. Breach Notification

In the event of a data breach, we will:

• Notify affected users where required
• Report the breach to the Information Regulator
• Take immediate steps to mitigate risks

15. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Users will be notified of material changes via the Platform or email.

16. Promotion of Access to Information Act (PAIA)

In accordance with the Promotion of Access to Information Act, 2000 (PAIA), Virtual Chelete provides access to records held by the company, subject to applicable legal requirements.

16.1 PAIA Manual

Virtual Chelete will make its PAIA Manual available upon request and, where applicable, on its website. The manual outlines the procedures for requesting access to records.

16.2 Request for Access to Information

Requests for access to information must be made in writing and submitted to the Information Officer at:

The request must include sufficient details to identify the record requested and the identity of the requester.

16.3 Grounds for Refusal

Access to information may be refused in accordance with PAIA where:

• The disclosure would involve unreasonable disclosure of personal information of a third party
• The information is protected for commercial confidentiality
• The request is frivolous or vexatious

17. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

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