1. Responsible Party

Neptune Design Pty Ltd is the Responsible Party for the personal information processed through the Service.

• Email: [email protected]
• Information Officer: Devon Thomas
• Information Officer email: [email protected]

The Information Officer is registered with the Information Regulator as required by POPIA and is responsible for ensuring our compliance with the Act.

 

2. Personal Information We Collect

We collect the following categories of personal information:

Personal Data you provide directly, which may include:

• Email address
• First name and last name
• Phone number
• Address, province, postal code, city

Automatically collected data (Usage Data), including:

• IP address
• Browser type and version
• Pages visited, time and date of visit, time spent on pages
• Unique device identifiers and other diagnostic data

Cookies and similar tracking technologies — see Section 6 below.

We only collect personal information that is adequate, relevant, and not excessive for the purposes described in this Policy, in line with POPIA’s minimality principle.

 

3. Lawful Basis and Purpose of Processing

Under POPIA, we may only process personal information where a lawful justification exists. We rely on the following grounds, as applicable:

• Your consent (e.g., subscribing to a newsletter, using non-essential cookies)
• Performance of a contract with you (e.g., delivering a service you requested)
• Compliance with a legal obligation
• Our legitimate interests, provided these do not override your rights and interests (e.g., securing our Service, improving functionality)

We use the personal information we collect to:

• Provide, operate, and maintain the Service
• Notify you about changes to the Service
• Enable your participation in interactive features
• Provide customer care and support
• Analyse usage to improve the Service
• Detect, prevent, and address technical or security issues
• Comply with our legal obligations

We do not process personal information for purposes incompatible with those described above without first informing you and, where required, obtaining your consent.

 

4. Direct Marketing

In accordance with Section 69 of POPIA, we will only send you direct marketing communications (such as newsletters or promotional emails) if:

• You have given your consent to receive them, or
• You are an existing customer and the communication relates to similar products or services, and you were given a reasonable opportunity to opt out at the time your details were collected and with each subsequent communication.

You may withdraw your consent or opt out of direct marketing at any time by contacting us at [email protected] or using the unsubscribe link in any marketing communication.

 

5. Data Subject Rights

Under POPIA, you have the right to:

• Be informed that your personal information is being collected and why
• Access the personal information we hold about you
• Request correction or deletion of inaccurate, irrelevant, excessive, out of date, incomplete, or unlawfully obtained personal information
• Object to the processing of your personal information, including for direct marketing purposes
• Withdraw consent at any time, where processing is based on consent
• Not be subject to a decision based solely on automated processing which affects you significantly
• Lodge a complaint with the Information Regulator if you believe your rights under POPIA have been infringed

To exercise any of these rights, contact us at [email protected]. We will respond within a reasonable time and in accordance with POPIA’s requirements.

Information Regulator (South Africa) contact details:

• Website: https://www.justice.gov.za/inforeg/
• Email: [email protected]
• Complaints: [email protected]

 

6. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to operate and improve the Service. Cookies are small data files stored on your device.

Types of cookies we use:

• Session Cookies — to operate our Service
• Preference Cookies — to remember your settings and preferences
• Security Cookies — for security purposes

You can configure your browser to refuse cookies or alert you when cookies are being used. Note that some parts of the Service may not function properly without cookies. Where required by law, we will request your consent before placing non-essential cookies.

 

7. Sharing and Disclosure of Personal Information

We may share personal information with:

Service Providers (“Operators” under POPIA) — third parties who process personal information on our behalf under a written agreement, and only for the purposes we specify. They are contractually prohibited from using your information for any other purpose and must maintain equivalent security safeguards.

Google Analytics — we use Google Analytics to monitor and analyse use of the Service. Google may use collected data to contextualise and personalise its own advertising. You can opt out via the Google Analytics opt-out browser add-on. See Google’s privacy practices: https://policies.google.com/privacy?hl=en

Legal and safety disclosures — we may disclose personal information where necessary to:

• Comply with a legal obligation or court order
• Protect and defend our rights or property
• Prevent or investigate suspected wrongdoing connected with the Service
• Protect the personal safety of users or the public
• Protect against legal liability

We do not sell your personal information.

 

8. Cross-Border Transfers

Your personal information may be transferred to, and processed in, countries other than South Africa, where data protection laws may differ.

Where we transfer personal information outside South Africa, we do so in accordance with Section 72 of POPIA, ensuring that:

• The recipient is subject to a law, binding corporate rules, or binding agreement that provides an adequate level of protection substantially similar to POPIA, or
• You have consented to the transfer, or
• The transfer is necessary for the performance of a contract with you, or for the conclusion or performance of a contract entered into in your interest.

 

9. Data Security

We take reasonable technical and organisational measures to protect personal information against loss, unauthorised access, interference, modification, destruction, or disclosure, as required by Section 19 of POPIA. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

In the event of a security compromise where there are reasonable grounds to believe your personal information has been accessed or acquired by an unauthorised person, we will notify the Information Regulator and affected data subjects as soon as reasonably possible, in accordance with Section 22 of POPIA.

 

10. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law, after which it is deleted, destroyed, or de-identified in a manner that prevents its reconstruction.

 

11. Links to Other Sites

Our Service may contain links to third-party sites not operated by us. We are not responsible for the content, privacy policies, or practices of any third-party sites. We recommend reviewing the privacy policy of every site you visit.

 

12. Children’s Privacy

Our Service is not directed at persons under the age of 18. We do not knowingly collect personal information from children without the consent of a competent person (such as a parent or guardian), as required under Section 35 of POPIA.

If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us so we can take steps to remove it.

 

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated Policy on this page and updating the “effective date” above, and where appropriate by email or a prominent notice on the Service, prior to the change taking effect.

We encourage you to review this Policy periodically.

 

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights under POPIA, please contact us:

• By email: [email protected]
• Information Officer: Devon Thomas — [email protected]

If you are not satisfied with our response, you may lodge a complaint with the Information Regulator (contact details in Section 5).

 

Private Policy last updated 21July 2026