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Privacy Policy

South Easter Agency (Pty) Ltd (“South Easter”, “we”, “us” or “our”) respects the privacy of our clients, their customers, website visitors and other individuals whose personal information we may process.

This Privacy Policy explains what information we collect, why we collect it, how it may be processed, the service providers involved, how we protect it, and the rights available to individuals under applicable privacy laws, including South Africa’s Protection of Personal Information Act, 4 of 2013 (“POPIA”).

1. Our Privacy Commitment

South Easter does not sell personal information, client information or customer conversation data.

We do not disclose personal information to unrelated third parties for their own advertising or marketing purposes.

Information may be processed or shared only where reasonably necessary to provide our agreed services, where authorised by the relevant client or individual, where required for legitimate business operations, or where required by law.

Where South Easter processes personal information on behalf of a business client, we aim to process that information only for the purpose of providing the services requested by that client and in accordance with the client’s instructions and applicable law.

2. Information We May Collect

Depending on the services being used, South Easter may process information including:

Contact and identification information, such as names, telephone numbers, email addresses, business names and physical or business addresses.

Business information and assets, such as company information, products, services, pricing information supplied by the client, brand guidelines, logos, website content, images, operating hours, FAQs, internal business rules and sales information.

Technical and account information, including information required to connect or administer websites, social platforms, WhatsApp Business accounts, advertising platforms, automation systems or other services.

Customer enquiry and messaging information, which may include names, phone numbers, message content, conversation history, enquiry details, requested products or services, location information voluntarily provided during a conversation and information relating to potential sales leads.

Website and technical information, such as IP addresses, browser information, device information and website usage information where these are collected by our website or service providers.

We aim to collect only information that is reasonably necessary for the relevant purpose.

3. How We Use Information

We may use personal and business information to:

  • provide and maintain services requested by our clients;

  • design, build and operate websites;

  • provide marketing and advertising services;

  • communicate with clients regarding projects, support, invoices and services;

  • configure and operate WhatsApp AI assistants;

  • respond to customer enquiries;

  • provide answers based on information supplied or approved by the relevant business;

  • maintain appropriate conversation context;

  • identify and qualify potential sales leads;

  • route enquiries to the appropriate business or team member;

  • notify clients when human follow-up or escalation is required;

  • prevent duplicate processing, misuse or technical errors;

  • maintain service security and reliability;

  • comply with applicable legal, accounting and regulatory obligations; and

  • investigate or respond to security incidents or unlawful activity.

We do not use a client’s customer conversations for unrelated advertising or marketing purposes.

4. WhatsApp AI Assistant

South Easter provides AI-powered WhatsApp sales and customer-service solutions to businesses.

When a client connects or authorises its WhatsApp Business account for use with our service, South Easter may receive and process information associated with customer conversations.

This may include the customer’s WhatsApp number, name where available, message content, conversation history and information voluntarily provided during the enquiry.

The service may use this information to:

  • respond to customer questions;

  • provide information about the client’s products and services;

  • maintain conversation context;

  • determine the nature of an enquiry;

  • identify or qualify potential leads;

  • record relevant lead information;

  • provide the client with a summary of an enquiry;

  • escalate conversations where human intervention is appropriate; and

  • notify the client of enquiries requiring follow-up.

The relevant business remains responsible for the underlying relationship with its customers and for ensuring that its collection and use of customer information complies with applicable law.

South Easter acts as a service provider or operator in circumstances where we process personal information on behalf of a client.

5. Artificial Intelligence Processing

Certain South Easter services use artificial intelligence systems to analyse enquiries and generate responses.

Information submitted to these systems may include customer messages and relevant business information required to provide an accurate response.

We aim to limit information sent to AI systems to information reasonably necessary for the service being performed.

AI-generated responses may be subject to business rules, approved knowledge, safeguards and escalation requirements established for the relevant client.

Customers should not submit highly sensitive information through a WhatsApp conversation unless it is reasonably necessary for the relevant enquiry.

6. Third-Party Service Providers

South Easter uses trusted technology and infrastructure providers to deliver its services.

Depending on the service, these may include:

  • Meta and WhatsApp;

  • website hosting and website-building providers;

  • cloud infrastructure providers;

  • automation platforms;

  • database and data-storage providers;

  • artificial intelligence service providers;

  • email and communication providers;

  • analytics providers;

  • payment or billing platforms; and

  • advertising platforms such as Meta and Google.

These providers may process information only to the extent required to provide their respective services.

South Easter does not permit third-party service providers to use client information for unrelated purposes merely because they process it on our behalf.

Where required, appropriate contractual and security arrangements should apply to organisations processing personal information on behalf of South Easter or our clients. POPIA specifically requires responsible parties to ensure operators processing information on their behalf maintain appropriate security safeguards.

7. International Processing and Data Transfers

Some of South Easter’s technology providers may operate infrastructure or process information outside South Africa.

Where personal information is processed internationally, we seek to use reputable service providers and appropriate safeguards consistent with applicable data-protection requirements.

Clients acknowledge that providing cloud-based, WhatsApp, automation and AI services may involve lawful cross-border processing of information.

8. Data Security

South Easter implements commercially reasonable technical and organisational measures designed to protect personal information from loss, misuse, unauthorised access, alteration, disclosure or destruction.

These measures may include appropriate access controls, restricted administrative access, secure credentials, reputable cloud infrastructure and other reasonable safeguards appropriate to the nature of the information being processed.

No internet-based system can be guaranteed to be completely secure. We therefore continually consider and improve safeguards as our services and risks evolve.

POPIA requires responsible parties to take appropriate and reasonable measures to protect the integrity and confidentiality of personal information and to identify, maintain and update safeguards against reasonably foreseeable risks.

9. Security Incidents

Where South Easter becomes aware of a suspected or confirmed unauthorised access to personal information, we will investigate the incident and take reasonable steps to contain and address it.

Where South Easter acts as an operator for a client, we will notify the relevant client where required.

Where South Easter is responsible for the affected information, notifications to affected individuals or the Information Regulator will be made where required by applicable law.

POPIA contains specific obligations relating to security compromises and notification to the Information Regulator and affected data subjects.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, to provide our services, maintain legitimate business records, resolve disputes, comply with legal requirements or protect our legitimate business interests.

WhatsApp conversation and lead information may be retained for the period reasonably necessary to maintain conversation context, provide the service, maintain relevant client records and support customer follow-up.

Where information is no longer reasonably required and no legal obligation requires continued retention, it may be deleted, anonymised or securely disposed of.

Clients may request deletion of information held on their behalf, subject to legal, contractual or legitimate record-keeping requirements.

11. Client Account Access and Credentials

Where clients provide South Easter with administrative or technical access to websites, Meta accounts, WhatsApp Business accounts, advertising platforms or other systems, such access is used only to perform the agreed services.

Clients should use secure account-management practices and should avoid sharing passwords where platform-based user access, delegated permissions or authorised connections are available.

When services terminate, access may be removed or transferred as appropriate.

12. Your Rights

Subject to applicable law, individuals may have the right to:

  • ask whether South Easter holds personal information about them;

  • request access to their personal information;

  • request correction or updating of inaccurate information;

  • request deletion or destruction of information where legally appropriate;

  • object to certain processing;

  • withdraw consent where processing relies on consent;

  • request information about how their personal information is being processed; and

  • lodge a complaint with South Africa’s Information Regulator.

POPIA provides a framework for lawful processing and data-subject rights, while the Information Regulator is responsible for monitoring and enforcing compliance.

13. Client Responsibilities

Clients using South Easter services are responsible for ensuring that information supplied to us has been collected lawfully and that appropriate notices, permissions or consents have been obtained where required.

Clients using the WhatsApp AI Assistant are responsible for ensuring their business’s customer-data practices, messaging practices and use of WhatsApp comply with applicable laws and platform requirements.

South Easter should not be instructed to collect or process information unlawfully.

14. Children and Special Personal Information

South Easter’s services are primarily designed for businesses and general commercial customer enquiries.

Clients should not intentionally use our services to collect children’s information or special categories of personal information unless this has been specifically assessed and appropriate legal and technical safeguards have been implemented.

Certain higher-risk processing activities may require additional obligations or prior authorisation under POPIA.

15. Cookies and Website Technologies

Our website may use cookies or similar technologies required for website functionality, analytics, security or advertising.

Where required by applicable law, users may be provided with choices relating to non-essential cookies.

Third-party services integrated into our website may also set or process cookies according to their own privacy policies.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes to our services, technology, legal obligations or business practices.

The latest version will be published on our website with an updated revision date.

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17. Contact South Easter

Questions, privacy requests or concerns relating to this Privacy Policy or South Easter’s processing of personal information may be directed to:

South Easter Agency (Pty) Ltd
Cape Town, South Africa

Email: info@southeaster.co.za
Website: www.southeaster.co.za

Individuals may also contact or submit complaints to the Information Regulator of South Africa where applicable. The Regulator provides services for POPIA complaints, security-compromise reporting and other compliance matters.

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