Privacy Policy

Lokshin Wifi (Pty) Ltd

(Registration number: 2022/465585/07) together with its Subsidiaries (“The Company”)


as prescribed by the provisions of



1.1 Company means Lokshin Wifi (Pty) Ltd (registration number 2022/465585), a company duly registered and incorporated with limited liability in accordance with the company laws of the Republic of South Africa and having its principal place of business situated at 13 Wessels Road,Shirdo Holdings office park, Rivonia, 2191, Republic of South Africa together with its subsidiaries as specified in Appendix 1;

1.2 Conditions for Lawful Processing means the conditions for the lawful processing of Personal Information as fully set out in chapter 3 of POPIA;

1.3 Constitution means the Constitution of the Republic of South Africa, 1996;

1.4  Customer refers to any natural or juristic person that received or receives services from the Company;

1.5  Channel refers to a platform made available to the Data Subject through which the Data Subject can  interact with the Company.

1.6  Data Subject has the meaning ascribed thereto in section 1 of POPIA;

1.7  Head of the Company means the “head” as defined in section 1 of PAIA and referred to in clause 4;

1.8  Information Officer means the Company’s appointed Information Officer as referred to in clause 4;

1.9  Manual means this manual prepared in accordance with section 51 of PAIA and regulation 4(1) (d) of the POPIA Regulations;

1.10  PAIA means the Promotion of Access to Information Act, 2000;

1.11  Personal Information has the meaning ascribed thereto in section 1 of POPIA;

1.12  Personnel refers to any person who works for, or provides services to or on behalf of the Company, and receives or is entitled to receive remuneration and any other person who assists in carrying out or conducting the business of the Company, which includes, without limitation, directors (executive and non-executive), all permanent, temporary and part-time staff as well as contract workers;

1.13  POPIA means the Protection of Personal Information Act, 2013;

1.14  POPIA Regulations mean the regulations promulgated in terms of section 112(2) of POPIA;

1.15  Private Body has the meaning ascribed thereto in sections 1 of both PAIA and POPIA;

1.16  Processing has the meaning ascribed thereto in section 1 of POPIA;

1.17  Responsible Party has the meaning ascribed thereto in section 1 of POPIA;

1.18  Record has the meaning ascribed thereto in section 1 of PAIA and includes Personal Information;

1.19  Requester has the meaning ascribed thereto in section 1 of PAIA;

1.20  Request for Access has the meaning ascribed thereto in section 1 of PAIA; and 1.21 SAHRC means the South African Human Rights Commission.

Capitalised terms used in this Manual have the meanings ascribed thereto in section 1 of POPIA and PAIA as the context specifically requires, unless otherwise defined herein.


2.1  This privacy policy is issued on behalf of the Company.

2.2  The Company is committed to protecting your privacy and personal information and  complying with applicable data protection and privacy laws in South Africa when you access  our site or make use of the Company’s Services, and accordingly, shall take all reasonable  steps, including technological, procedural and controls, to protect your personal information.  Any personal information that you provide when accessing the Company will be used and  retained in accordance with this Privacy Policy and all other relevant codes and standards.  This Privacy Policy is intended to inform you of the privacy practices that apply to your access  and use of the Company’s Services, and to explain how we collect, store, use, transfer and  disclose your personal information. We also describe the kinds of information that the  Company collects from you.

2.3  The Company is made up of different legal entities which are incorporated in South Africa.  When we mention “Lokshin Wifi”, “we”, “us” or “our” in this privacy policy, we are referring to the  Company responsible for processing your data.

2.4  In this policy, reference to “Data Protection Laws” means any statutes, laws, legislation, or  regulations or binding policy, code of any government authority that relates to the security and  protection of personally identifiable information, data privacy, trans-border data flow or data  protection in force from time to time in the Republic of South Africa, including but not limited to  POPIA, Electronic Communications and Transactions Act 25 of 2002, Promotion of Access to  Information Act 2 of 2002, and/or any equivalent legislation of other jurisdiction(s) where  Personal Information is being processed or where a party is obliged to comply with, including,  where applicable, EU Data Protection Laws [General Data Protection Regulation (EU)  2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of  national persons with regard to the Processing of Personal Data and on the free movement of  such data, as amended, replaced or superseded from time to time.

2.5  In this policy, the use of any word or expression, or terms or process of definition in this policy  which has its meaning derived from the Protection of Personal Information Act 4 of 2003  (“POPIA”), including but not limited to “Personal Information”, “Responsible Party”, “Data  Subject”, “Personal Information Breach”, “Information Regulator”, will be construed to mean  the corresponding word or expression or term or process or definition which has its meaning  derived from GDPR or any applicable Data Protection Laws, such as “personal data”,  “controller”, “data processor”, “process” / “processing”, “data subject”, sub-processor”,  personal data breach”, supervisory authority”, ‘commission”, “member state”.

2.6  We are a data controller of your Personal Information. This means that we are responsible for  deciding how we hold and use Personal Information about you. We always aim to be  transparent about how we use your data and Personal Information, and to comply with applicable Data Protection Laws in making you aware of the information contained in this  policy.

2.7  We do not circumvent any of the personal privacy settings on any of the platforms and/or  suppliers from where we collect data. Our system processes is intended for and focused on  information that our customers have given us access to and/or have sent directly to us, such  as documents (ID and Proof of Address) required for RICA and sim activations.


3.1  This policy will inform you about what data we collect from our data subjects (natural or  juristic), including but not limited to various Company Channels, Services and social  platforms, with whom we have direct relationships for purposes of our business, how we use  such data, circumstances where we may disclose this data to others, and how we keep it  secure.

3.2  Any questions relating to this policy and our privacy practices should be sent to us using the  contact details set out below.


4.1  The details of the Company are as follows:

Physical address

Shirdo Holdings Office park,

13 WesselsRoad,

Rivonia, 2191,

South Africa

Postal address:  Same as above
Telephone number:  010 449 2262
Fax number  N/A



5.1  The Information Officer’s contact details are as follows:

Physical address

Shirdo Holdings Office Park,

13 Wessels Road,

Rivonia, 2191,

South Africa


Postal address Same as above
email address:


Fax number  N/A



6.1  We use the term “personal information” or “personal data” to mean information that relates to  you. Personal information includes, for example, your name, contact information including  your cell phone number, email address, identity number, and information relating to your  residential address. Information that is not linked to a particular individual, such as statistical  or aggregated information, is not personal information and is not covered by this Privacy  Policy. We may collect, process, use, disclose and transfer non-personal information for any  purpose. You can choose not to provide personal information that we may request of you, but,  in general, most of the personal information we request is required in order to provide the  Services, and the lack of such personal information may prevent us from doing so.

6.2  Generally, we may collect personal information about you when you access the Company’s Channel and/or subscribe for the Services offered on the Company’s Channel. We may also  collect information about you when you use the site, report a problem with the site, use  support services, or communicate with us. In addition, information may be collected when  you respond to customer surveys, and promotions. What is mentioned above is not a  complete list of all the ways that we could collect information. We set out below information  that may be collected and processed. These are as follows: –

6.2. 1 Information that you provide on or through the Company’s Channel. This includes  information provided at the time of registering to use the Company’s Channel (if  applicable), receive maintenance, making payments or posting material. We may also ask  you for information when you report a problem with the Company’s Services.

6.2.2  Details of your visits to and use of our site and/or mobile App including, but not limited to,  traffic data, location data, weblogs, service provider page viewing statistics and other  communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

6.2.3  Details about problems that may occur when you utilize our Services, and/or use our help  desk, if applicable.

6.2.4  Information related to you and your use of the Company’s Channel and/or the Services,  including but not limited to your online activity, contributions, payment history, correspondence, internet protocol addresses, device and software data (such as type,  configuration and unique identifiers);

6.2.5  A record of correspondence if you contact us.

6.2.6  Information obtained from surveys that we may ask you to voluntarily complete from time  to time, which we use for research purposes.

6.2.7  Information posted by you pursuant to reviews of the Company’s Channel and the  Services: and

6.2.8  any other information that may be necessary: (i) to carry out actions for the conclusion or  performance of a contract to which you are a party; (ii) to comply with an obligation  imposed on us by law; (iii) to protect your legitimate interest; (iv) to pursue a legitimate  interest of ours or of a third party to whom the information is supplied.

6.3  Lokshin Wifi  may also collect non-personal information such as your IP address, date, time, and  duration of your access to the Company’s Channel to track your visits to the Company’s Channel so that we are able to deliver a more personalized experience. This information is  used to develop future products and/or services that meet your requirements and needs.

6.4  We may collect information about your device, mobile or other, including where available  your internet protocol address, operating system, and browser type, for system  administration and to report aggregate information to our advertisers and/or service  providers. This is statistical information about your browsing actions and patterns and does  not identify you.

6.5  By using the Company’s Channels, including but not limited to the website and mobile app,  you are consenting to our use of cookies, caching tools and analytics tools, in accordance  with this Privacy Policy. If you do not agree, please refrain from using the Company’s  Channel. We use cookies and similar technologies to collect additional data and to improve  our Services. These technologies use small data files that are transferred to your mobile  device. If you return to an application, it shows that it is a repeat visit. The technologies  cannot be used to identify you on the websites of third parties, including the website of the  analysis provider. It can additionally be used to store your preferred settings, e.g., language and country settings, so that they will be immediately available on your next visit.  We use the web analysis system to raise the efficiency of our mobile App. Personal  information is collected and stored either electronically using “cookies” or provided  voluntarily with your consent and knowledge.

6.6  We do not knowingly collect or share: –

6.6.1  except in the form of Aggregated Data any Special Categories of Personal Data  about you (this includes details about your race or ethnicity, religious or philosophical  beliefs, sex life, sexual orientation, political opinions, trade union membership,  information about your health, and genetic and biometric data);

6.6.2  any information about criminal convictions and offences.; or

6.6.3  any information relating to children under the age of 13.

  We are committed to respecting the privacy of children online. If we learn that our systems  have inadvertently collected information relating to children under the age of 13, we will  promptly delete the information, notify the necessary customer representatives to facilitate a  consultation on how this data was collected and put measures in place for it not to happen  again.


7.1  The information that we collect from you Is stored and processed within the Republic Of  South Africa and may be transferred to, and stored at, a destination outside of South Africa.

7.2  It may also be processed by staff members operating outside of South Africa who work for us  or for one of our service providers (including but not limited to payment processors, cloud  service or other information technology providers, and other companies that provide services  to us). Such staff members may be engaged in, among other things, the provision of the  service or the provision of maintenance and support services.

7.3  By submitting your personal information, you agree to this transfer, storing or processing. We  will take all steps reasonably necessary to ensure that your information is treated securely  and in accordance with this Privacy Policy and in accordance with the terms of POPIA.


8.1  We will only process your Personal Data when we have legal grounds to do so. Generally, we  rely on the legal ground which allows us to process your Personal Data where it is necessary  for our legitimate interests (our subsidiaries, parent companies, and affiliates) and your  interests and fundamental rights do not override those interests.

8.2  Our legitimate interests for processing data are in order to provide our Services to our  customers, which include providing technology and mobile data services.

8.3  We also use the data in related or ancillary ways, to the Services that we offer. For example,  we may use the data to comply with our legal obligations or enforce our rights, including the legal obligations or enforcement of rights of third parties. We may also use the data to  improve our Services.

8.4  For us to make your use of the Company’s Channel and Services as successful as  possible, the Company collects, stores, and uses your personal information. Below are  some of the purposes for us collecting your personal information, in relation to which  purposes you hereby expressly consent to our processing your personal information:

8.4.1  To communicate requested information and Services to you.

8.4.2  To authenticate the user and provide access to restricted pages.

8.4.3  To create products or services that may meet your future requirements.

8.4.4  To compile non-personal statistical information about browsing habits, click-patterns and  access to the Company’s Channel.

8.4.5  To ensure that content on the Lokshin Wifi  Channel and the Services are presented in the most  effective manner for you and for your computer or other device.

8.4.6 To determine your general geographic location, enforce the terms of this Privacy Policy,  personalize the Company’s Channel and the Services and our marketing to better reflect  particular interests, helping us to quickly and efficiently respond to inquiries and requests  and otherwise analyze, enhance, administer or promote the service offering for you and  other users.

8.4.7  To carry out our obligations arising from any agreements entered between you and us, if  any.

8.4.8 To allow you to participate in interactive features of the Company’s Channel and Services, when you choose to do so; and

8.4.9 To notify you about changes to the Company’s Channel and Services.

8.5  We will only share your data with any member of our company group (i.e. our subsidiaries,  parent companies, and affiliates).

8.6  We may share your data with selected third parties, including our business partners,  suppliers, for the performance of any contract we enter into with them. We may also share  your data with analytics and search engine providers that assist us in the improvement of our  website and systems.

8.7  We may also disclose your data to other third parties. For example, if we sell or buy any  business or assets, we may disclose your data to the prospective seller or buyer of such business or assets. Alternatively, if we or substantially all of our assets are acquired by a third  party, your data may be part of the transferred assets.

8.8  If any third-party processes any of your data, we ensure there are sufficient contractual and  operational safeguards protecting your data.

8.9  In respect of your Personal Data, we will not:

8.9.1  sell, licence or purchase any data obtained from Social Media Platforms.

8.9.2  use your Personal Data to make decisions about eligibility, including whether to approve  or reject an application or how much interest to charge on a loan.

8.9.3  put your Personal Data in a search engine or directory or include web search functionality  on our apps on Social Media Platforms.

8.9.4  prefill any content in captions, comments, messages, or the user message parameter of posts.

8.9.5  proxy, request or collect your usernames or passwords for Social Media Platforms. 8.9.6  transfer your Personal Data to a data broker or sell your Personal Data.

8.9.7  share your user IDs for Social Media Platforms with service providers who build or run  any of our apps. Your user IDs for Social Media Platforms will be kept secure and  confidential; and/or

8.9.8  use friends or connections data from Social Media Platforms to establish social  connections in our apps, unless you have granted you access to that information.

8.9.9  If you have any concern regarding the use of your information, please contact us at

8.10  Except as otherwise set out expressly herein, we do not disclose personal information  about users to our advertisers (if any) but we may provide them with aggregate information or  information in an otherwise anonymous form about our users (for example, we may inform  them that 500 men aged under 30 have clicked on their advertisement and/or application on  any given day). We may also use such aggregate information to help advertisers reach the  kind of audience they want to target (for example, individuals in a specific territory).


8.11  We may make use of the personal information we have collected from you to enable  us to comply with advertisers’ wishes by displaying their advertisement to that target  audience.

8.12  In addition, we may use other companies, agents, or contractors to perform services  on our behalf or to assist us with the provision of access to the Company’s Channel and  the Services to you. For example, we engage services providers to provide marketing, communications, infrastructure, and information technology services, personalize and  optimize our site and the online services, provide customer service, analyze and enhance  data, including users’ interaction with the online services, and process consumer surveys.  In the course of providing such services, these service providers may have access to your  personal information. We do not authorize these service providers to use or disclose your  personal information except in connection with providing the services we request of them.

8.13  Only personal information that is necessary for the purposes stated in this Privacy  Policy will be collected, stored, used and otherwise processed by the Company.


9.1  All non-personal information collected and assembled by the Company, is owned and  retained by the Company. You are hereby expressly notified of and consent to our collection  of your personal information.

9.2  The personal information that has been collected by the Company, may be disclosed or  otherwise processed by us if permitted by applicable law, if necessary, consent has been  obtained from you and/or if the access, use, preservation, disclosure or other processing of  such information is reasonably necessary: –

9.2.1  For legal and regulatory compliance of applicable law, regulation, legal process, or governmental request.

9.2.2  To conduct research and improving our products or services.

9.2.3  To enforce applicable terms of use and terms and conditions (including but  not limited to this Privacy Policy), including investigation of potential violations thereof.

9.2.4  To detect, prevent, or otherwise address illegal or suspected illegal activities,  security, or technical issues.

9.2.5 To protect against harm to the rights, property or safety of us, our users or  the public as required or permitted by law, which includes exchanging information with other companies and organizations for the purposes of fraud  protection and credit risk reduction.

9.2.6  In connection with any reorganization, restructuring, merger or sale, or other  transferring of assets; provided that the receiving party agrees to respect your personal information in a manner that is consistent with this Privacy Policy; and/or

9.2.7  For the compilation, use and sharing of information that does not pertain to  any specific individual, and you hereby consent to us and our duly authorized  agents and contractors processing your personal information for such purposes.

9.2.8  TheC ompany may for lawful purposes and in accordance with applicable  laws,monitor your activity and such information will be made available to the authorities if and to the extent required by law.


10.1  You have the right to ask us to review your personal information that you have provided  to us and make any desired changes to it.

10.2  You have the right to request the origin of the personal information pertaining to you.

10.3  You have the right to choose whether you wish to receive marketing material. By  accepting this policy, you consent to receiving marketing material. Should you wish to no  longer receive such material you can opt out by contacting us by email at  The Company undertakes to comply with all applicable law in relation to direct marketing  including the CPA in this regard.

10.4  You have the right to request the Company to correct or delete your personal  information. However, the Company will retain such personal information that it is required to  retain in terms of any applicable law and/or in concert with prescribed retention periods. We  take reasonable steps to ensure that the personal information we collect, and store is  accurate, complete and up to date. We also endeavor as best we can to delete any incorrect  or unnecessary personal information, particularly in respect of your contact details. Please  ensure that your personal information is accurate, complete and up-to date by contacting us  as soon as possible if you become aware that your personal information is in any way  inaccurate, incomplete or out-of-date.

10.5  You have the right to request details in respect of the identity of third parties who have or  had access to your personal information, if applicable, and you have the right to request the identity of third persons who are in charge of your personal information as well as those third person to whom your personal information may have been communicated, if applicable.

10.6  You have the right to lodge a complaint with the Information Regulator in accordance with POPIA.

10.7  Please note that you have an obligation to provide the Company with accurate personal  information keep Lokshin Wifi informed of any changes to your personal information as and when  these occur.

10.8  Please note that the Company may, from time to time, contain links to and from the  websites of our partner networks, advertisers, service providers and affiliates. If you follow a  link to any of these websites, please note that these websites have their own privacy policies, and that Lokshin Wifi does not accept any responsibility or liability for these policies. Please check  these policies before you submit any personal data to these websites.


11.1  Lokshin Wifi  is committed to protecting the security of your personal information and will take all  reasonable steps to secure the personal information that you submit to us, including your  contact information.

11.2  We use a variety of security technologies and physical, electronic, and managerial  procedures to protect the personal information that we have collected, or that you have  provided, from unauthorized access, use or disclosure.

11.3  This will minimize the risk of loss, misuse, alteration, disclosure and unauthorized access  of your information that is under our control. Unfortunately, the transmission of information via  the Internet is not completely secure. Although we will do our best to protect your personal  information, we cannot always guarantee the security of your personal information which is  transmitted via the Company’s Channel.


12.1  POPIA gives you the right to access information held about you. Your right of access  can be exercised in accordance with POPIA.

12.2  Any access request may be subject to a fee for meeting our costs in providing you with  details of the information we hold about you.


13.1  We review our data retention periods regularly and will only hold your Personal Data for  as long as is necessary for the relevant activity, or as required by law (we may be legally  required to hold some types of information). However, if you request that we delete your data,  we will delete your data from our system, provided it is not in contravention of any laws or  current legislation.

13.2  Details of retention periods for different aspects of your Personal Data are available in  our retention policy are available by contacting us using the details provided below. To  determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use  or disclosure of your Personal Data, the purposes for which we process your Personal Data  and whether we can achieve those purposes through other means, and the applicable legal  requirements.


Any changes we make to our privacy policy in the future will be posted on our website and,  where appropriate, displayed on our premises notified to you by e-mail

Appendix 1


1. Cultivationpoint Pty Ltd


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