1. Introduction
Zeturi Platform (Pty) Ltd (“Zeturi”, “we”, “us”, “our”) is committed to protecting personal information. This policy explains how we collect, use, disclose and safeguard personal information when you use the Zeturi Platform (the “Service”). We comply with the Protection of Personal Information Act, 2013 (POPIA) and applicable South African laws.
2. POPIA Roles and Responsibility
For scheme data, your scheme is the Responsible Party. Zeturi acts as an Operator and processes personal information on your documented instructions to provide and improve the Service.
For our own account data (billing, support, platform security, fraud prevention) Zeturi is the Responsible Party.
3. Information We Collect
Personal and Member Information
- Names, contact details, identity numbers (where required by scheme rules or law)
- Dates of birth and member identifiers
- Bank details for contributions and distributions (if captured by the scheme)
- Dependants’ details for burial society claims (managed by adult members)
Financial and Scheme Records
- Contributions, distributions, loans and repayments
- Unit holdings, valuations and statements
- Claims and supporting documents
- Governance proposals, voting activity and audit logs
Technical Data
- IP address, device and browser information
- Usage analytics, session and event logs
- Cookies or similar technologies (see Cookies and Analytics)
4. How We Use Information
- Provide, secure and maintain the Service
- Process contributions, distributions, claims and statements
- Operate governance, audit trails and notifications
- Comply with legal and regulatory requirements
- Prevent fraud and misuse; investigate incidents
- Improve functionality and user experience
- Create aggregated or de-identified insights that do not identify a person or scheme
5. Justification Grounds for Processing
We process personal information on one or more of these POPIA grounds:
- Consent by the data subject for specified purposes
- Contractual necessity to provide the Service to your scheme
- Legal obligations (e.g. tax, accounting, FICA if applicable)
- Legitimate interests of the scheme, Zeturi or a third party, balanced against data subject rights
7. Security and Incidents
- Encryption in transit (TLS) and at rest for sensitive data
- Role-based access controls and row-level policies
- Multi-factor authentication for privileged access
- Activity logs and monitoring
- Regular security reviews and vendor assessments
If we become aware of a personal-information security compromise, we will notify the scheme representative and the Information Regulator as soon as reasonably possible, describing the nature of the compromise, affected categories of information, and steps to mitigate harm.
8. Cross-border Transfers
Personal information may be processed in South Africa or other countries where we or our operators maintain facilities, subject to POPIA section 72 safeguards (e.g. adequate protection laws, binding agreements, or data subject consent). We take steps to ensure equivalent protection for transferred information.
9. Retention and Deletion
We retain personal information for as long as needed to provide the Service, for legitimate business purposes, or to meet legal obligations. Typical minimum periods include:
- Accounting and tax records: up to 7 years
- FICA records (where applicable): at least 5 years after the end of the relationship or transaction
When a scheme terminates, we provide a time-limited export window (see Terms of Service). Thereafter we delete or de-identify data, noting backups and logs that cycle out within standard retention.
10. Your POPIA and PAIA Rights
You may exercise these rights, subject to lawful limitations:
- Access to your personal information
- Correction or updating of inaccurate information
- Deletion where legally permissible
- Objection to certain processing, or restriction of processing
- Data portability for information you provided, where technically feasible
- Withdraw consent for consent-based processing
Submit requests to privacy@zeturi.com. Requests may require identity verification and, for PAIA access requests, completion of the prescribed form and payment of a reasonable fee if applicable.
12. Children and Special Personal Information
The Service is not directed to children under 18. Dependants recorded for burial societies are managed by adult members. Where claims involve health or death records (special personal information), schemes must have a valid justification ground under POPIA (e.g. consent, legal obligation, or authorisation by law). Zeturi processes such information only on the scheme’s documented instructions.
13. Changes to this Policy
We may update this policy from time to time. Material changes will be notified by email or through the Service. The “Last updated” date reflects the effective date of the current version.
14. Information Officer and Complaints
Contact our Information Officer for questions or to exercise your rights:
- Email: privacy@zeturi.com
If you are not satisfied with our response, you may complain to the Information Regulator (South Africa):
Information Regulator of South Africa
Website: inforegulator.org.za
Email: enquiries@inforegulator.org.za
Toll Free: 0800 017 160
Landline: 010 023 5200