Privacy Policy

1. Who we are

KeepSave (Pty) Ltd is a company registered in South Africa. In this policy, "KeepSave", "we" and "us" mean that company. We run:

• our website, keepsave.co.za; and
• the KeepSave platform at app.keepsave.co.za: the portal people use to plan for their family, and the workspace financial advisers use to run their practice.

This policy explains what personal information we collect, why we collect it, who we share it with, and your rights under the Protection of Personal Information Act 4 of 2013 (POPIA). It applies to:

• people with a KeepSave account;
• financial advisers and their staff who use KeepSave;
• people whose details someone else adds, such as family members, executors, witnesses and the people who will receive a message; and
• visitors to our website.

You can reach our Information Officer at [email protected]. Our postal address is 125 Murray, Vierlanden, Western Cape.

2. Our two roles

POPIA has two roles. A responsible party decides why and how personal information is used. An operator uses it on someone else's behalf and on their instructions.

• Your own account. For the information in your KeepSave account, we are the responsible party.
• Financial advisers. When a practice uses KeepSave to run its own work (its client notes, tasks, meetings, prospects and forms), the practice is the responsible party for that information. We are its operator, and we act only on its instructions under a written agreement. The practice's own privacy notice applies to that information.
• When you connect with an adviser. You accept an agreement to connect, and you choose what the practice may see. A practice may have to keep records of the advice it gives you, for five years as the financial advisory laws (FAIS) require, even if you later disconnect.

3. What we collect

What you give us

• Account and sign-in: your name, email address and password (stored only in a form that cannot be turned back into your password), passkeys and two-step settings. If you sign in with Google or Facebook, see sections 8 and 9.
• Your profile: preferred name, date of birth, gender, nationality, marital status and marriage regime, ID type and number, occupation, employer, languages, phone numbers and addresses. Religion is optional.
• Identity check: your South African ID number and a selfie. See section 4.
• Your will and estate: your executors, guardians, beneficiaries and gifts, what you own and what you owe, your funeral wishes, and what should happen to your online accounts. We never ask for the passwords to those accounts.
• Your documents: anything you upload to your vault, such as identity documents, policies, title deeds and medical records, with the dates, tags and notes you add.
• Messages: what you send to and receive from your adviser's practice and KeepSave support, including files and voice notes. If you use WhatsApp with us, see section 9.
• Legacy messages and memories: letters, audio and video recordings, photos, and when each one should be delivered.
• Signatures: when you sign a form in KeepSave, we keep your typed or drawn signature, the time, the place you enter, your IP address and your browser details, as a record of the signing.
• Advisers: your name, contact details, practice name, FSP number, licence details, designation and the team members you invite.

Information about other people

To plan for your family, you add other people: family members, trusted people, beneficiaries, executors, guardians, emergency contacts, people who will confirm your death, people who will receive a message, and witnesses. For each one we keep a name, contact details and how they relate to you. For a witness we also keep their ID number, and their date of birth if they sign in KeepSave.

Please add someone only when you have a good reason to, and let them know. When we contact them, for example to invite them, deliver your message or ask them to sign as a witness, we tell them who added them and why we are in touch.

What we collect automatically

• Security and use: sign-ins, the devices and browsers you use, IP addresses, active sessions, and a record of who opened your record and when.
• Our website: which pages you visit and how you use them, only if you accept analytics or marketing cookies. See section 16.

From other sources

• Home Affairs, through VerifyNow: whether your ID number and selfie match the national population register.
• Google and Facebook: if you choose to sign in with them.
• Your adviser's practice: if a practice invites you, we receive your email address and the practice's name.
• Other people using KeepSave: when someone adds you, as described above.
• Our website forms: if you apply as an adviser or ask for a referral from the estate calculator, we receive what you type in the form. The figures you enter in the calculator stay in your browser unless you ask for a referral.

Do you have to give it to us?

Most of it is your choice. Some of it is needed for a feature to work. You need an email address to have an account. You need to confirm who you are before you can add people, record what you own and owe, prepare your will pack or set a legacy message to be delivered. Without that, those features will not work. A will is only valid if it meets the Wills Act 7 of 1953, which is why we ask for your witnesses' details.

4. Sensitive information and children

POPIA calls some information special personal information and protects it more strictly. In KeepSave it can include:

• Biometric information: the selfie for your identity check. We send it to VerifyNow, which compares it with your Home Affairs photo. We keep the result. We do not keep the image.
• Health information: medical documents you choose to store.
• Religious beliefs: if you record your religion, or funeral wishes that show it.

We use this information only with your consent, or where POPIA allows it, and only for the reason you gave it to us.

Children. You must be 18 or older to have a KeepSave account. You may add details about your children, for example as beneficiaries or when you name a guardian. As their parent or guardian, you consent to us using that information for your plan. A witness can be 14 or older, as the Wills Act allows. If a witness is under 18, we keep only what a valid will needs.

5. Why we use it

POPIA lets us use personal information only for a clear reason and on a lawful ground (section 11). Ours are:

• To run your account and the features you use, such as your will, vault, people, messages, reminders and legacy messages: because we have an agreement with you.
• To confirm who you are before sensitive steps: with your consent, and to protect you and your family from fraud.
• To share your information with the people you choose: on your instruction and with your consent, which you can withdraw.
• To send you service messages, such as security alerts, expiry reminders, invitations and replies from your adviser: because we have an agreement with you.
• To keep KeepSave secure, prevent fraud, fix problems and keep a record of who did what: in our legitimate interest and yours, and to meet our legal duties.
• To improve KeepSave: using information that does not identify you, and only if you allow usage analytics in your privacy settings.
• To tell you about KeepSave: only with your consent, or as POPIA allows for existing customers. See section 15.
• To meet the law: for example a court order or a request from a regulator.

We do not use your information for a purpose that does not fit the reason you gave it to us, unless you agree or the law allows it.

6. Who can see it

• You.
• The people you choose. You can give a family member, trusted person or executor their own login, and choose what they may see: your documents, your will, your estate, your wishes, your legacy messages or your emergency information. You can change or remove their access at any time. Each time someone opens your record, you can see it in KeepSave under Security & Privacy, "Who has seen my record".
• Your adviser's practice, if you connect with one, and only what you allow.
• Our service providers, who help us run KeepSave. See section 10.
• Authorities, when the law requires it. We check that each request is lawful and share only what it needs.
• A buyer, if KeepSave is ever sold or merged with another company. We would tell you first, and this policy would keep applying to your information.

KeepSave staff do not look at your will, your documents or your messages. A small number of people who run our systems can reach them, and only to keep KeepSave working, to fix a problem you ask us to fix, or to meet a legal duty.

We do not sell personal information, and we do not share it so that anyone can advertise to you.

7. When you die

KeepSave exists for this moment. POPIA protects living people, but we keep treating your information with the same care, and we follow the instructions you left:

• the people you gave access to keep the access you gave them;
• your executor sees what you shared with them, once their access is active;
• the people you named can confirm your death, and your legacy messages are delivered only by the rules you set; and
• information about the living people in your plan, such as your family, stays protected by POPIA.

We keep the record of someone who has died for as long as the people they chose need it to carry out their wishes. Their executor can ask us to close it.

8. Google

Sign in with Google

If you choose to sign in with Google, Google sends us your name, email address, profile picture and Google account ID (the "openid", "profile" and "email" permissions). We use them only to create your account and sign you in.

Google Calendar, for advisers who connect it

An adviser can choose to connect their Google Calendar. KeepSave then asks Google for permission to see the adviser's calendars and events, and to manage events (the "calendar.readonly" and "calendar.events" permissions). We use this only to:

• show the adviser's Google Calendar events next to their KeepSave diary, so they can see when they are free; and
• add, move or remove an event in their Google Calendar when they book, change or cancel a meeting in KeepSave. The event holds the meeting title, the client's name, the time, the place and the adviser's note. We never add the client as a guest, so Google does not send the client an invitation.

We do not keep copies of Google Calendar events in KeepSave. We store the list of the adviser's calendars and the access key Google gives us, and that key is encrypted. An adviser can disconnect at any time in KeepSave under Settings, Calendar, or in their Google Account at myaccount.google.com/connections.

How we use information from Google

KeepSave's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

In plain terms: we use information from Google only to provide the features above. We do not sell it, use it for advertising, or use it to train AI models. People at KeepSave do not read it unless you ask us to for support, it is needed for security, or the law requires it.

Google Analytics

Our website uses Google Analytics to understand how people use it, only if you accept analytics cookies. See section 16.

9. Meta: Facebook and WhatsApp

Sign in with Facebook

If you choose to sign in with Facebook, Meta sends us your name, email address, profile picture and Facebook user ID (the "email" and "public_profile" permissions). We use them only to create your account and sign you in. We do not post to Facebook, and we do not see your friends.

WhatsApp

KeepSave uses the WhatsApp Business Platform, run by Meta, to send and receive WhatsApp messages. If you add your mobile number:

• we may send you a code on WhatsApp to confirm the number is yours;
• we send you the notifications you choose to get on WhatsApp in your notification settings; and
• your adviser's practice can message you on WhatsApp from KeepSave, and your replies go to the practice's KeepSave inbox.

These messages pass through Meta's systems, and WhatsApp's own terms and privacy policy apply to your use of WhatsApp. To stop WhatsApp messages from KeepSave, reply STOP. Reply IN to start them again. If you ask us for a code after that, we still send it. You can also change this in your notification settings.

Meta Pixel

Our website uses the Meta Pixel to measure our advertising on Facebook and Instagram, only if you accept marketing cookies. It sends nothing from your KeepSave account.

To delete information we received from Facebook, see section 14.

10. Our service providers

We use other companies (operators) to help run KeepSave. Each may use your information only to provide its service to us, must keep it secure and confidential, and is bound to us by an agreement or by its published terms.

• Hosting: runs the KeepSave platform and stores its information and files.
• Cloudflare (worldwide): protects and delivers our website and platform.
• Vercel (United States and worldwide): hosts our website.
• Email delivery: sends our emails.
• VerifyNow (South Africa): checks your ID number and selfie against Home Affairs records.
• Pusher (outside South Africa): delivers live updates in KeepSave, such as a new chat message, including the text of the message.
• Laravel Nightwatch (outside South Africa): watches KeepSave for errors and slow pages, which can include technical details of a request.
• Google (United States and worldwide): sign-in, Google Calendar for advisers who connect it, and Google Analytics on our website.
• Meta (United States and worldwide): Facebook sign-in, WhatsApp messages, and the Meta Pixel on our website.
• Microsoft Clarity (United States): shows how visitors use our website, only with their consent.
• Our customer relationship system (United States): keeps the adviser applications and referral requests sent through our website, so we can reply.

Transfers outside South Africa

Some of these providers store or use information outside South Africa. POPIA (section 72) allows this when the recipient is bound by a law, binding company rules or an agreement that protects your information as well as POPIA does, when you consent, or when the transfer is needed for our agreement with you. We use only providers that meet one of these tests.

11. How we protect it

• Every document in your vault is encrypted with AES-256 before it is stored, and each file has its own key.
• Information travels between your device and KeepSave over an encrypted connection.
• Passwords are stored only in a form that cannot be turned back into the password. You can add a passkey or a two-step code.
• What others can see is limited by the permissions you set, and each time someone opens your record it is logged where you can see it.
• We confirm your identity before sensitive steps, so nobody can pretend to be you.
• The access keys Google gives us are encrypted.

No system is perfectly secure. If we find that someone has reached your personal information without permission, we will tell the Information Regulator and you as soon as reasonably possible, as POPIA section 22 requires, and explain what you can do to protect yourself. If you think someone has used your account, contact us straight away.

12. How long we keep it

• While your account is open, we keep your information so KeepSave can do its job.
• Deleted documents stay in your trash for 30 days, so you can restore them. After that we delete them for good.
• When you delete your account, we delete it and the information in it from our live systems straight away. Your documents can no longer be opened, because their keys are deleted with your account. Copies in our backups are gone within 90 days.
• Data downloads you ask for are kept for 7 days.
• Security logs are kept for as long as we need them to protect you and KeepSave, and then deleted.
• Adviser applications and referral requests from our website are kept while we are in contact with you, and deleted when we no longer need them or when you ask us to.
• Records the law requires us to keep, for example for tax or to deal with a legal claim, we keep for as long as that law requires.
• Your adviser's practice keeps its own records of advice for as long as the law requires it to. See section 2.

13. Your rights

Under POPIA you have the right to:

• know whether we hold personal information about you, and get a copy of it. When you are signed in, you can download your information under Settings, Data;
• correct information that is wrong or out of date. You can edit most of it yourself;
• ask us to delete information we no longer have a right to keep. See section 14;
• object to us using your information on the ground of legitimate interest, and to direct marketing at any time;
• withdraw your consent at any time. This does not affect what we did before you withdrew it; and
• complain to the Information Regulator. See section 18.

To use a right, email [email protected]. We may ask you to prove who you are first. We reply within 30 days, and asking for your own information is free. Our PAIA manual, which explains how to ask for records under the Promotion of Access to Information Act, is available on request.

14. How to delete your information

• In KeepSave: go to Settings, Account, and choose Delete account. This deletes your account and its information, as section 12 explains.
• By email: write to [email protected] from the email address on your account. We confirm when it is done, within 30 days.
• If you signed in with Facebook or Google: deleting your KeepSave account also deletes what we received from them. You can also remove KeepSave's access in Facebook, under Settings & privacy, Settings, Apps and websites, or in your Google Account at myaccount.google.com/connections.
• Adviser applications and referral requests from our website: email us and we will delete them.

If you are connected to an adviser's practice, the records the practice must keep by law stay with the practice.

15. Marketing

We send you marketing by email or WhatsApp only if you agree to it, or if you are our customer and it is about a similar KeepSave product, as POPIA section 69 allows. Every marketing message tells you how to stop it, and you can switch marketing off in your privacy settings at any time.

Advisers who use KeepSave to write to their own clients are responsible for having their clients' consent. KeepSave leaves out clients who have switched off messages from their adviser, and stops WhatsApp messages as soon as someone replies STOP.

16. Cookies

• The KeepSave platform (app.keepsave.co.za) uses only the cookies it needs to keep you signed in and secure, and to remember settings such as how the screen looks.
• Our website (keepsave.co.za) also uses cookies for analytics (Google Analytics and Microsoft Clarity) and for marketing (the Meta Pixel), only after you accept them. You can change your choice at any time with the "Cookie settings" link at the bottom of every page.

Our Cookie Policy has the details.

17. Changes to this policy

We update this policy when KeepSave changes. The date at the top shows the current version. If a change affects how we use your information, we tell you by email or in KeepSave before it takes effect.

18. Contact us, and the Information Regulator

KeepSave's Information Officer
Email: [email protected]
Postal address: 125 Murray, Vierlanden, Western Cape

Please talk to us first, so we can put things right. You can also complain to the Information Regulator at any time.

Information Regulator (South Africa)
Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
P.O. Box 31533, Braamfontein, Johannesburg, 2017
Phone: 010 023 5200. Toll-free: 0800 017 160
Email: [email protected]
Complaints: use the online form or Form 5 at inforegulator.org.za/popia