Privacy Policy

The responsible party for purposes of POPIA is the organisation, shul, programme, or administrator operating this app.

• Responsible Party Name: Hendler Family / Shul Programme Administration
• Email Address: admin@myprogram.co.za

Depending on how the app is used, we may collect and process the following:

• identification and account information (name, email, phone number, login credentials);
• profile information such as Hebrew name and programme participation details;
• attendance and participation records;
• financial information such as bank account details, earnings history, and payment records;
• application information including date of birth, address, student status, and next-of-kin details;
• uploaded files such as CVs or portraits;
• communication data including WhatsApp phone numbers and messages; and
• technical and session information.

In some application flows, users may voluntarily provide limited health or mental health information. Under POPIA, this may qualify as special personal information. Where this occurs, the information is processed only for specific programme administration or participant wellbeing purposes described at the point of collection, and on the basis of explicit consent or another lawful basis permitted by POPIA.

We collect personal information:

• directly from users when they register, log in, complete profiles, submit attendance, apply to programmes, upload documents, or communicate through WhatsApp-supported flows;
• from administrators when they manage users, record payments, approve applications, or update programme information; and
• automatically through session mechanisms and operational logs needed to keep the app functioning securely.

We process personal information for one or more of the following purposes:

• creating and managing user accounts;
• authenticating users and maintaining secure sessions;
• administering attendance, programme participation, and eligibility;
• processing programme applications and related supporting documents;
• communicating with users about their accounts, attendance, applications, or payments;
• calculating earnings, recording payments, and maintaining financial records;
• supporting WhatsApp-based submissions, reminders, or account administration;
• operating, maintaining, securing, troubleshooting, and improving the app;
• enforcing programme terms and preventing misuse; and
• complying with legal, regulatory, tax, accounting, or dispute-resolution obligations.

Depending on the context, processing may be based on:

• the user's consent;
• the conclusion or performance of an agreement or programme arrangement;
• compliance with legal obligations;
• legitimate interests of the responsible party; or
• another lawful ground recognised under POPIA.

The app uses session cookies and related session identifiers to keep users signed in and protect authenticated areas of the service. The mobile application may store session information securely on-device for login continuity. These mechanisms are used for operational and security purposes rather than behavioural advertising.

We may share personal information with service providers that help us run the app, subject to appropriate confidentiality and security obligations. These may include hosting and infrastructure providers, cloud database providers, cloud file storage providers, messaging providers, and professional advisers. We do not sell personal information.

Some service providers used to host, store, transmit, or support app data may be located outside South Africa. Where cross-border transfers occur, the responsible party takes reasonable steps to ensure that the recipient is subject to laws or safeguards that provide an adequate level of protection as contemplated by POPIA.

We take reasonable technical and organisational measures to secure personal information against loss, misuse, unauthorised access, interference, modification, or disclosure. These include access controls, password hashing, session management controls, restricted administrative access based on role, and use of established cloud infrastructure providers. No method of transmission or storage is completely secure.

We retain personal information only for as long as reasonably necessary to fulfil the purposes described in this policy, to maintain programme and accounting records, to resolve disputes, to enforce rights, or to comply with legal obligations.

Subject to POPIA and any lawful limitations, a data subject may request:

• confirmation of whether we hold personal information about them;
• access to their personal information;
• correction, updating, or deletion of inaccurate or outdated personal information;
• objection to certain processing;
• withdrawal of consent where processing is based on consent; and
• deletion or destruction of records where retention is no longer authorised.

Requests should be directed to the Information Officer using the contact details listed in this policy.

This app is not intended to collect personal information from children unless the relevant programme and lawful basis specifically permit it and appropriate authorisation has been obtained.

If you have concerns about how personal information is processed, please contact the Information Officer first. Data subjects also have the right to lodge a complaint with the Information Regulator of South Africa:

• Website: inforegulator.org.za
• Email: POPIAComplaints@inforegulator.org.za

This policy may be updated from time to time to reflect legal, operational, or product changes. The latest version will be kept available through the app, together with its effective date.

Privacy or POPIA-related requests should be sent to:

• Email: admin@myprogram.co.za