Privacy Policy (POPIA)

Last updated: 30 August 2025

1) Who We Are (Responsible Party) & Information Officer

This Privacy Policy explains how Senca Research (Pty) Ltd (Reg. No: 2025/482457/07) ("Senca", "we", "us", "our") processes personal information for the EarnPlus / Earn+ platform in South Africa, in accordance with the Protection of Personal Information Act, 2013 (POPIA).

• Responsible Party: Senca Research (Pty) Ltd
• Physical Address: 7th Street, Parkhurst, Johannesburg, South Africa
• General Email: hello@earnplus.co.za
• Information Officer: I. Mutemeri — alerts@earnplus.co.za

2) Scope & Application

This Policy applies to individuals in South Africa who use EarnPlus / Earn+ (the "Platform") and to our website/app visitors. By using the Platform, you acknowledge this Policy. Capitalised terms used but not defined here have the meanings given in our Terms & Conditions.

3) Information We Collect

• Identity & contact: name, email, mobile number, optional profile info.
• Verification & payout: uploaded verification documents (where required by an offer), bank details, payout preferences.
• Usage & device: app activity, IP address, device identifiers, logs.
• Location: coarse location (if provided/derived).
• Content: reviews you post and information you send to support.

4) Why We Process Your Information (POPIA Principles & Lawful Grounds)

• Provide the service / perform our contract: create and manage your account; verify contact details; run offers; process and pay rewards; prevent fraud and abuse.
• Consent-based activities: electronic direct marketing (email/SMS) and certain analytics/cookies. You can withdraw consent at any time.
• Legal obligations: record-keeping and responding to lawful requests.
• Legitimate interests: service improvement, security, non-electronic marketing permitted under POPIA.

5) Direct Marketing (Email/SMS) vs Service Messages

Service messages (e.g., account, payouts, security) are necessary to operate the Platform and are not marketing. For electronic direct marketing, we obtain your opt-in consent (or use the limited existing-customer exception permitted in South Africa). Every marketing message includes a clear opt-out. You can also manage preferences in-app or via email.

6) Cookies & Analytics

We use analytics to understand usage and improve the Platform, including PostHog and Google Analytics. You can manage cookies via your browser and (where provided) our in-app controls. Some analytics relies on consent; where not consent-based, we apply minimal collection and aggregation.

7) Sharing & Disclosure

We do not sell your personal information. We share it only as necessary to operate EarnPlus:

• Offer fulfilment partners: for example, an insurer/advertiser may contact you to complete a quote or offer you elected to pursue.
• Payments providers: banks and cash-send services to pay rewards.
• Service providers: hosting, analytics, support — bound by confidentiality and POPIA-aligned obligations.
• Legal: where required by law or to protect rights, safety, and security.

8) Cross-Border Transfers

Some providers may process data outside South Africa. Where that occurs, we use safeguards permitted by POPIA (for example, adequate protection in the recipient country, contractual protections, or your consent).

9) Security & Breach Notification

We implement technical and organisational measures designed to protect personal information. If a security compromise occurs, we will notify affected individuals and the Information Regulator as soon as reasonably possible, as required by POPIA.

10) Retention

We keep personal information only as long as reasonably necessary for the purposes above and to comply with legal obligations. When you delete your account, we aim to delete or de‑identify personal information within 15 days, except where we must retain certain records (e.g., financial/transaction records) for statutory periods; we keep those only for the required period and then delete or de‑identify them.

11) Your Rights

You may request to access, correct, delete, object to or restrict processing, and withdraw consent. To exercise these rights, contact our Information Officer at alerts@earnplus.co.za.

You may also lodge a complaint with the Information Regulator:

• Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
• Email: POPIAComplaints@inforegulator.org.za
• Phone: 010 023 5200

12) Children

We do not knowingly process personal information of persons under 18. If you believe a minor has registered, contact us and we will delete the account and associated data.

13) Changes to this Policy

We may update this Policy from time to time. We will notify you (e.g., in‑app/email) and indicate the effective date above.

14) Contact

Information Officer: I. Mutemeri — alerts@earnplus.co.za
General Contact: hello@earnplus.co.za
Address: 7th Street, Parkhurst, Johannesburg, South Africa

15) Trademarks

EarnPlus and Earn+ are trademarks of Senca Research (Pty) Ltd. All other marks are the property of their respective owners.