POPIA Notice

CommHub (Pty) Ltd
Registration number: 2026/318433/07
Registered address: Dreyer Street, Claremont, Cape Town, 7708, South Africa
Email: hello@commhub.co.za

Name: Paul Dando
Email: hello@commhub.co.za

The Information Officer is your point of contact for any privacy-related question, request, or complaint.

We may collect the following personal information:

• Identifying information: name, work email, contact number, role, company name
• Account information: login credentials, account preferences
• Transaction information: invoicing details, billing address, payment status
• Usage information: IP address, browser type, device, pages visited, cookies
• Communications: support requests, sales enquiries, demo bookings
• Customer Data: where a brokerage uses CommHub, the Platform processes data uploaded by that brokerage, including policyholder information, policy data, and commission records. CommHub processes this data as an operator on behalf of the brokerage, who is the responsible party for that data.

• To provide, operate, and improve the CommHub Platform
• To respond to demo requests and other enquiries
• To manage your account, billing, and communication
• To send marketing communications where you have consented
• To comply with legal and regulatory obligations
• To prevent fraud and protect our systems
• To produce aggregated, anonymised analytics

We rely on one or more of the following lawful grounds set out in section 11 of POPIA:

• Your consent
• Performance of a contract with you
• Compliance with a legal obligation
• Protecting your legitimate interest
• Pursuit of CommHub's legitimate interests, balanced against your rights

Providing personal information is generally voluntary. However, certain information (such as a name, email, and company details) is required to register an account, respond to a demo enquiry, or process billing. Without it, we may be unable to provide you with the requested service.

If you choose not to provide the information we request, we may not be able to:

• Create or maintain your account
• Process your demo enquiry
• Issue invoices or process payments
• Communicate with you about the Platform

We share personal information only with:

• Service providers (cloud hosting, email, analytics, payment processing) under appropriate confidentiality and data protection agreements
• Professional advisors (lawyers, accountants, auditors) where required
• Regulators, courts, or law enforcement where legally required
• A successor entity in a merger, acquisition, or sale of business assets

We do not sell personal information.

Where personal information is transferred outside South Africa (for example, to a cloud service provider whose servers are located in another country), we ensure that:

• The receiving country provides an adequate level of protection, OR
• The transfer is necessary for the conclusion or performance of a contract with you, OR
• You have consented to the transfer

We implement appropriate, reasonable technical and organisational measures as required by section 19 of POPIA, including encryption, access controls, security monitoring, employee training, and incident response procedures.

We retain personal information only for as long as is necessary for the purpose for which it was collected, or as required by law. Refer to our Privacy Policy for category-specific retention periods.

Under POPIA, you have the right to:

• Be notified that personal information about you is being collected
• Access your personal information
• Request correction or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or unlawfully obtained
• Object to processing
• Object to direct marketing
• Not be subject to a decision based solely on automated processing
• Lodge a complaint with the Information Regulator

To exercise any of these rights, contact us at hello@commhub.co.za.

If you are not satisfied with how we handle your personal information, you may lodge a complaint with:

The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Email: complaints.IR@justice.gov.za

We may update this notice from time to time. The most recent version is always available on this page.

CommHub (Pty) Ltd
Information Officer: Paul Dando
Email: hello@commhub.co.za
Address: Dreyer Street, Claremont, Cape Town, 7708, South Africa