Privacy Statement

1. Introduction

Puntr (Pty) Ltd ("Puntr", "we", "us", or "our") is committed to protecting your privacy and personal information. This Privacy Statement explains how we collect, use, disclose, and safeguard your information in compliance with:

• POPIA - Protection of Personal Information Act, 2013 (Act No. 4 of 2013)
• FICA - Financial Intelligence Centre Act, 2001 (Act No. 38 of 2001)
• Other applicable South African laws and regulations

By using Puntr's services, you consent to the practices described in this Privacy Statement.

2. Information We Collect

2.1 Personal Information

We collect the following personal information when you register or use our services:

• Full name and surname
• Date of birth
• ID number or passport number
• Email address
• Mobile phone number
• Physical and postal address
• Banking details (for commission payments)
• Username and password (encrypted)

2.2 FICA Verification Information

To comply with FICA requirements and prevent money laundering and terrorist financing, we collect and verify identity information through our trusted verification partner, VerifyNow:

• Government-issued identification documents
• Proof of residence (not older than 3 months)
• Biometric verification data
• Source of funds information (where applicable)

VerifyNow processes this information securely on our behalf and provides verification results. We do not store copies of your identity documents on our servers; these are securely stored by VerifyNow in accordance with FICA requirements.

2.3 Usage & Technical Information

We automatically collect certain technical information when you use our Service:

• IP address and location data
• Device information (type, operating system, browser)
• Usage data (pages visited, time spent, features used)
• Cookies and similar tracking technologies
• Prediction history and betting preferences

3. How We Use Your Information

We process your personal information for the following lawful purposes:

3.1 Service Provision

• Create and manage your account
• Provide access to predictions, odds comparison, and community features
• Process referral commissions and rewards
• Enable communication with other users (where applicable)

3.2 Compliance & Security

• Verify your identity and age (18+) in compliance with gambling regulations
• Comply with FICA and anti-money laundering requirements
• Prevent fraud, unauthorized access, and illegal activities
• Detect and prevent problem gambling behaviors
• Comply with legal obligations and regulatory requests

3.3 Communication

• Send account-related notifications and updates
• Provide customer support
• Send marketing communications (with your consent - you may opt out anytime)
• Notify you of promotions, new features, and platform updates

3.4 Improvement & Analytics

• Analyze usage patterns to improve our Service
• Conduct research and development
• Personalize your user experience
• Generate aggregated, anonymized statistics

4. Information Sharing & Disclosure

We do not sell your personal information. We may share your information with:

4.1 Verification Partners

• VerifyNow: Our trusted FICA verification partner processes your identity documents and biometric data for age and identity verification. VerifyNow is bound by strict confidentiality and data protection obligations.

4.2 Affiliate Bookmakers

• When you click through to third-party bookmakers, we share minimal information (such as a referral ID) to track commissions. Each bookmaker has its own privacy policy governing their data practices.

4.3 Service Providers

• Cloud hosting and infrastructure providers
• Payment processors (for commission payments)
• Email and communication service providers
• Analytics and monitoring tools

All service providers are contractually required to protect your information and use it only for the purposes we specify.

4.4 Legal & Regulatory Authorities

• When required by law or court order
• To comply with FICA reporting obligations
• To protect our rights, property, or safety
• In connection with the investigation of fraud or illegal activity

4.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

5. Your Rights Under POPIA

Under the Protection of Personal Information Act (POPIA), you have the following rights:

• Right to Access: Request a copy of the personal information we hold about you
• Right to Correction: Request correction of inaccurate or incomplete information
• Right to Deletion: Request deletion of your information (subject to legal retention requirements)
• Right to Object: Object to the processing of your information for certain purposes
• Right to Restrict Processing: Request that we limit how we use your information
• Right to Data Portability: Request your information in a structured, machine-readable format
• Right to Withdraw Consent: Withdraw consent for marketing communications or optional data processing

To exercise any of these rights, please contact our Information Officer at privacy@punthub.fun. We will respond within 30 days.

6. Data Security

We implement appropriate technical and organizational security measures to protect your personal information, including:

• Encryption of data in transit (SSL/TLS) and at rest
• Access controls and authentication mechanisms
• Regular security audits and vulnerability assessments
• Employee training on data protection and confidentiality
• Secure data centers with physical access controls
• Regular backups and disaster recovery procedures

While we strive to protect your information, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials.

7. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services to you
• Comply with legal obligations, including FICA requirements (minimum 5 years after closure)
• Resolve disputes and enforce our agreements
• Fulfill legitimate business purposes

When your information is no longer required, we securely delete or anonymize it in accordance with our data retention policy and legal requirements.

8. Cookies & Tracking Technologies

We use cookies and similar technologies to enhance your experience. For detailed information, please see our Cookie Preferences page.

9. International Data Transfers

Your information is primarily stored and processed within South Africa. If we transfer data internationally (e.g., to cloud service providers), we ensure adequate safeguards are in place through standard contractual clauses or other legally approved mechanisms.

10. Children's Privacy

Puntr is not intended for persons under 18 years of age. We do not knowingly collect information from minors. If we discover that we have inadvertently collected information from someone under 18, we will delete it immediately. If you believe we have information about a minor, please contact us.

11. Changes to This Privacy Statement

We may update this Privacy Statement from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by email or through the platform. Your continued use of the Service after changes constitutes acceptance of the updated Privacy Statement.