Legal

POPIA Compliance Statement

This document summarises how AGILEGYPSY LABS PTY LTD complies with the Protection of Personal Information Act 4 of 2013 (“POPIA”), which gives effect to the constitutional right to privacy, as contemplated in Section 14 of the Constitution of the Republic of South Africa, 1996.

Effective Date: 1 July 2021 (POPIA commencement date) · Version 1.1

01

Responsible Party and Information Officer

Responsible Party:AGILEGYPSY LABS PTY LTDCIPC Reg. No.:2026/270871/07Registered Address:125 Benoni Road, Rynfield AH, Benoni, 1501, Gauteng, South AfricaInformation Officer:John WellardIO Email:john@agilegypsy.comInfo Regulator Ref:2026-005090IO Appointment Date:31 March 2026

The Information Officer is the person responsible for ensuring that POPIA is complied with throughout our operations, responding to data subject requests, and liaising with the Information Regulator. The IO is registered with the Information Regulator in terms of Section 55(1)(a) of POPIA.

02

Commitment to the Eight Conditions for Lawful Processing

AGILEGYPSY LABS PTY LTD is committed to complying with all eight conditions for lawful processing of personal information as set out in Chapter 3 of POPIA:

Condition 1: Accountability

We accept full responsibility for processing personal information in compliance with POPIA. Our Information Officer (John Wellard) ensures ongoing compliance and responds to data subject enquiries.

Condition 2: Processing Limitation

We process personal information lawfully and in a reasonable manner. We only collect the minimum personal information necessary for the specific, defined purpose of each processing activity.

Condition 3: Purpose Specification

All personal information is collected for specific, explicitly defined, and lawful purposes. We collect personal information directly from data subjects where possible, and we inform data subjects of the purpose at the time of collection.

Condition 4: Further Processing Limitation

We do not process personal information for a purpose beyond that for which it was originally collected, unless we obtain consent, or the further processing is compatible with the original purpose, required by law, or necessary for our legitimate interests.

Condition 5: Information Quality

We take reasonable steps to ensure that personal information we hold is complete, accurate, and not misleading, and is updated where necessary.

Condition 6: Openness

Our Privacy Policy is publicly available at agilegypsy.com/legal/privacy. We notify data subjects of our processing activities at the time of collection or as soon as reasonably practicable thereafter.

Condition 7: Security Safeguards

We implement appropriate technical and organisational measures to protect personal information in our possession from loss, damage, unauthorised access, and unauthorised processing. All data is encrypted in transit (TLS 1.3) and at rest on Cloudflare infrastructure.

Condition 8: Data Subject Participation

We respect all POPIA rights of data subjects, including the right to access, rectify, delete, and object to processing. Requests are handled by the Information Officer within 30 days.

03

Data Subject Rights (POPIA Sections 23–25)

Under POPIA, you have the following rights in respect of your personal information held by us:

RightSectionHow to Exercise
Right of AccessSection 23Request a copy of personal information held about you. Response within 30 days.
Right to RectificationSection 24Request correction of inaccurate or outdated personal information.
Right to DeletionSection 24Request deletion where information is no longer necessary for its original purpose.
Right to ObjectSection 11(3)Object to processing on legitimate grounds. We will consider all such objections.
Right to Withdraw ConsentSection 11(1)(a)Where consent was the basis for processing, withdraw at any time.
Right to ComplainSection 74Lodge a complaint with the Information Regulator at inforegulator.org.za

To exercise any of these rights, submit a written request to our Information Officer at john@agilegypsy.com. We will acknowledge your request within 3 business days and respond fully within 30 calendar days. Prescribed forms for objections (Form 1), correction or deletion requests (Form 2), and direct-marketing consent (Form 4) are described in our PAIA & POPIA Manual and are available from the Information Officer on request.

04

Security Compromise Notification (POPIA Section 22)

In the event of a security compromise affecting personal information in our possession:

  • We will notify the Information Regulator as soon as reasonably possible after discovery of the breach.
  • We will notify all affected data subjects as soon as reasonably possible, in accordance with Section 22 of POPIA.
  • Notifications will include the nature of the breach, the categories of data affected, the steps taken to mitigate harm, and recommended protective steps for affected individuals.

If you believe your personal information held by us has been compromised, please contact our Information Officer at john@agilegypsy.com immediately.

05

Operator Agreements (POPIA Section 21)

Where we engage operators (third parties) to process personal information on our behalf, we ensure that binding written agreements are in place that:

  • Require the operator to process personal information only with our knowledge and authorisation.
  • Prohibit the operator from processing personal information without our instructions.
  • Require the operator to implement the same or equivalent security safeguards as required of us.
  • Require the operator to notify us immediately of any security compromise.
06

Contact the Information Regulator

If you believe we are processing your personal information in violation of POPIA, and you are unsatisfied with our response to your complaint, you may contact the Information Regulator:

The Information Regulator (South Africa)

Physical: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

Postal: P.O Box 31533, Braamfontein, Johannesburg, 2017

General Enquiries: inquiries@inforegulator.org.za

POPIA Complaints: POPIAComplaints@inforegulator.org.za

Website: inforegulator.org.za

Contact the Information Officer

Agilegypsy Labs (Pty) Ltd
CIPC Registration No: 2026/270871/07
Information Regulator Reference: 2026-005090
Registered Office: 125 Benoni Road, Rynfield AH, Benoni, Gauteng, 1501
Information Officer: John Wellard
Email: john@agilegypsy.com

© 2026 AGILEGYPSY LABS PTY LTD. All rights reserved.