1. Privacy Policy (POPIA)

This Privacy Policy explains how we collect, use, share, and protect personal information when you visit our Sites, create an account, subscribe, purchase access through the paywall, or otherwise use our Services.

1.1 Definitions

“Personal Information” has the meaning given in the Protection of Personal Information Act 4 of 2013 (“POPIA”). “Processing” has a corresponding meaning. “Operator” means a third party that processes Personal Information for a responsible party, such as PayFast.

1.2 Responsible party and contact

Each Site is operated by the legal entity listed in Annexure A for that Site (“Responsible Party”). Contact details are also listed in Annexure A.

1.3 What information we collect

Depending on how you use the Sites, we may collect:

Identity and contact details (name, surname, email address, phone number, billing address).
Account details (username, password hash, login history).
Subscription and purchase details (plan selected, invoice/receipt information, access status).
Payment-related information handled by PayFast (we do not store full card data on our servers).
Technical and usage data (IP address, device/browser information, pages viewed, referring URLs, cookies).
Communications (support requests, emails, messages).
Where applicable, compliance information required by law or for regulated services (only if requested and necessary).

1.4 How we collect information

Directly from you (forms, account registration, subscriptions, support enquiries).
Automatically (cookies and similar technologies).
From payment processing and fraud-prevention checks via PayFast (transaction status and subscription status).
From service providers we use to host and secure the Sites (logs and security events).

1.5 Why we process Personal Information (purposes and lawful bases)

We process Personal Information for the following purposes, where permitted by POPIA and other applicable law:

To create and manage your account and deliver paywalled access.
To process payments and manage subscriptions and renewals (including through PayFast).
To provide customer support and respond to enquiries.
To send service messages (billing, access, security, policy updates).
To improve the Sites (analytics, debugging, performance, and user experience).
To protect the Sites against fraud, abuse, or security incidents.
To comply with legal obligations and respond to lawful requests.

1.6 Sharing and disclosure

We may share Personal Information with:

PayFast for payment processing, subscription billing, and transaction verification.
Hosting, IT, security, analytics, and email service providers that support Site operations.
Professional advisors (legal, compliance, auditors) where necessary.
Authorities where required by law or to protect our rights.

We do not sell Personal Information to third parties.

1.7 Cross-border transfers

Some of our service providers may process data outside South Africa. Where we transfer Personal Information cross-border, we will take steps required by POPIA to ensure appropriate safeguards are in place.

1.8 Security

We use reasonable technical and organisational measures to protect Personal Information, including access controls, encryption in transit (HTTPS), monitoring, and secure payment processing via PayFast. No system is completely secure, so we cannot guarantee absolute security.

1.9 Retention

We retain Personal Information only as long as necessary for the purposes described in this Privacy Policy, including for legitimate business needs and legal/compliance retention periods (e.g., accounting and tax records).

1.10 Your rights

Subject to POPIA and applicable law, you may request:

Access to Personal Information we hold about you.
Correction or deletion of inaccurate or unlawful information.
Objection to processing in certain circumstances.
Withdrawal of consent where processing is based on consent.
Information about third parties with whom we have shared your Personal Information (where appropriate).

To exercise these rights, contact us using the details in Annexure A.

1.11 Marketing

If we send marketing communications, we will do so in a lawful manner and provide an opt-out mechanism. You can unsubscribe at any time using the link in the message or by contacting us.

1.12 Children

The Sites and paywalled Services are not intended for children under 18. We do not knowingly collect Personal Information from children under 18 without appropriate authorisation.

1.13 Complaints

If you have concerns about our processing of Personal Information, please contact us first. You may also lodge a complaint with the Information Regulator of South Africa if you believe your rights under POPIA have been infringed.

2. Cookie Policy

This Cookie Policy explains how we use cookies and similar technologies on the Sites.

2.1 What cookies are

Cookies are small text files stored on your device when you visit a website. Similar technologies include pixels, local storage, and device identifiers.

2.2 Types of cookies we use

Strictly necessary cookies: required for basic Site functionality, login sessions, and paywall access.
Performance/analytics cookies: help us understand how the Sites are used and improve performance.
Functionality cookies: remember preferences (e.g., language, region).
Security cookies: help prevent fraud and protect accounts.

2.3 Managing cookies

You can manage cookies through your browser settings. If you disable certain cookies, parts of the Sites (including the paywall) may not function properly.

2.4 Third-party cookies

Some cookies may be set by third parties, such as analytics providers or payment-related services. PayFast may set or use cookies within its payment environment according to its own policies.

3. Refund & Cancellation Policy (Subscriptions / Digital Content)

This policy explains cancellation and refunds for subscriptions and paywalled digital content purchased on the Sites.

3.1 Plans and billing

Plans may be monthly, annual, or once-off purchases. Billing details appear at checkout and in your account area.

3.2 Cancelling a subscription

You may cancel at any time using the method described on the Site (e.g., account settings) and/or via PayFast subscription management where available.
Cancellation stops future renewals. You will typically retain access until the end of the current paid billing period unless otherwise stated at checkout.
If recurring payment fails, we may suspend access until payment succeeds.

3.3 Refunds

Unless required by law or expressly stated in an offer, the default approach is:

Once-off digital content purchases are generally non-refundable after access is granted (for example, downloads or immediate access to a report), except where required by law.
Subscription fees are generally non-refundable for the current billing period once the period has started, and we do not provide pro-rata refunds for partial periods, except where required by law.
Where we approve a refund, it will be processed to the original payment method and may be subject to PayFast processing rules and timeframes.

3.4 Exceptions and statutory rights

Nothing in this policy limits rights you may have under South African law (including the Consumer Protection Act and Electronic Communications and Transactions Act), where applicable. Where a statutory cooling-off right applies, we will honour it.

3.5 How to request a refund or support

Contact the relevant Site operator (Annexure A) with:

Your full name and email used for the purchase.
Order reference/PayFast transaction reference.
The reason for the request and any supporting information.

4. Website Disclaimer (General / Financial Services)

This disclaimer applies to all content on the Sites, including paywalled content, unless a separate written agreement states otherwise.

4.1 General information only

Content is provided for general information and educational purposes. It does not constitute legal, tax, accounting, or financial advice, and should not be relied on as such.

4.2 No offer or solicitation

Nothing on the Sites constitutes an offer to sell, a solicitation to buy, or a recommendation of any security, financial product, or strategy, unless expressly stated and lawfully permitted.

4.3 Risk warning

Investments and financial products involve risk. Values can go down as well as up. Past performance is not a reliable indicator of future results. You should seek advice from a suitably qualified and authorised professional before acting.

4.4 Accuracy and external links

We aim to keep information up to date, but do not warrant accuracy, completeness, or timeliness. External links are provided for convenience; we are not responsible for third-party content or policies.

4.5 Limitation of liability

To the maximum extent permitted by law, we are not liable for any loss arising from reliance on Site content, interruptions, errors, or omissions. Where liability cannot be excluded, it will be limited to the maximum extent allowed by law.

4.6 Regulated services (FAIS / FSCA)

If regulated financial advice or intermediary services are provided, they will be provided only by the authorised entity and representatives disclosed in Annexure A (and/or in a written mandate/engagement letter).

5. PAIA Manual (Template for Private Body)

This is a template manual prepared in line with the Promotion of Access to Information Act 2 of 2000 (“PAIA”) for a private body. Replace placeholders and confirm suitability with your compliance/legal advisor.

Note: You may publish separate manuals for each legal entity if Purple Wealth and HI Financial Planning are different entities.

5.1 Company details

Private Body: Purple Wealth and Advisory Pty Ltd
Registration Number: 2022/541733/07
Physical Address: 1096 Hauteford Place, Paarl, 7646
Website: www.purplewealth.co.za
Email: cobus@purplewealth.co.za
Telephone: +27737864484

5.2 Information Officer

Information Officer: JG Kruger
Email: cobus@purplewealth.co.za
Telephone: +27737864484

5.3 Guide on how to use PAIA

A guide on how to use PAIA is available from the Information Regulator. Requests may be submitted to the Information Officer using the process below.

5.4 Records available in terms of other legislation

Records may be kept in terms of (as applicable):

Companies Act; Tax Administration Act; Basic Conditions of Employment Act; Labour Relations Act; Occupational Health and Safety Act;
Financial sector legislation where applicable (including FAIS and related requirements);
POPIA; ECTA; CPA; and other laws relevant to our operations.

5.5 Categories of records held

We may hold records relating to:

Company and governance records (registrations, shareholding, resolutions).
Client/customer records (mandates, onboarding, communications, advice records where applicable).
Financial records (invoices, payments, accounting records).
Human resources records (employees, contractors).
IT, security, and access logs.
Marketing and communications materials.

5.6 Request procedure

To request access to a record under PAIA, submit a written request to the Information Officer containing:

Your full particulars and proof of identity (or authority if acting on behalf of someone else).
A sufficiently detailed description of the record requested.
The form of access required (copy/inspection).
Postal/email address for notices, and contact details.

5.7 Fees

A prescribed request fee and access fee may apply, to the extent permitted by PAIA. We will inform you of any applicable fees before processing the request.

5.8 Grounds for refusal

Access may be refused on grounds set out in PAIA, including protection of personal information, confidentiality, commercial information, and other lawful grounds.

5.9 Remedies

If a request is refused or you are dissatisfied with the outcome, you may apply to a court or pursue any remedy available under PAIA and other applicable law.

Annexure A – Operator Details (per Site)

A1) Purple Wealth (www.purplewealth.co.za)

A2) HI Financial Planning (www.hifinancialplanning.com)

Annexure B – Paywall Offer Schedule (per Site)

B1) HI Financial Planning packages

Package name: Tier 1
Billing frequency: Annual
Price (incl/excl VAT): ZAR 249.00 plus VAT
What is included: Access to digital book
Access period and renewal terms: 1 year and annual
Cancellation rules: Cancellation at any time with no refund
Refund rules (if different from Section 3): None

B2) HI Financial Planning packages

Package name: Tier b2
Billing frequency: Annual
Price (incl/excl VAT): ZAR 499.00 plus VAT
What is included: Access to digital book and video platform
Access period and renewal terms: 1 year and annual
Cancellation rules: Cancellation at any time with no refund
Refund rules (if different from Section 3): None