Privacy Policy
What findproperly collects, why, who else touches it, and what you can ask us to do about it. Written for POPIA, and written against the code rather than from a template.
Last updated
Draft, under legal review
A South African attorney has not settled this wording yet. What it describes is what the product does today, and the words can still change before this document is final.
1. Who we are
findproperly is a service of Haple IO (Pty) Ltd, a company registered in South Africa (registration number 2024/547503/07) at Cabernet Villas, 0 Cabernet Sauvignon Street, Oude Westhof, Bellville, 7530. For the purposes of the Protection of Personal Information Act, 4 of 2013 (POPIA), we are the responsible party for the personal information described here.
Requests about your own personal information go to our Information Officer, and the contact form reaches them. Say in the message that it is a POPIA request so it is handled as one. A dedicated address will be published here once it is set up.
This policy covers findproperly.co.za and the findproperly application. It does not cover other sites we link to, and it sits alongside our terms of service.
2. What we collect about you
When you sign in
Signing in happens through Google and nothing else. What we keep from it is your account identifier (a stable number that identifies you to us), your name, your email address and your profile picture. That is the whole of it. You never create a password with us and we never see your Google password. We do not read your Gmail, contacts, calendar or files, and we do not ask Google for permission to.
The account identifier is what ties your saved properties to you. There is no separate user record: your identity is the Google account, which is also why losing access to it means losing access to your library.
When you pay
We hold a billing record: which plan you are on, whether the subscription is active, the dates of the current period, how much of the monthly allowance you have used, your prepaid credit balance, and Paystack's references for your customer and subscription records. We also keep a reusable card token from Paystack, which lets us charge the same card for a top-up without sending you through checkout again.
Card numbers, expiry dates and CVV numbers never reach findproperly. They are entered on Paystack's own checkout. The token we hold is useless anywhere except our Paystack account.
When you use the product
- the address you searched and the property the registry matched it to,
- the report that came back, and the images that came with it,
- which deeds documents you checked for availability, and any copy you ordered,
- a ledger row for every billed action, recording what was bought and what it cost us,
- when you last opened the Properties page, which is how the "new since you last looked" counter works,
- your conversations with the assistant, if it is open to your account. It is closed at present.
When you write to us
The contact form collects your name, email address, your company or agency if you name one, and your message. Alongside it we record your browser's user agent string and a one-way hash of your IP address. We store the hash rather than the address itself, because the hash is enough to rate-limit the form and to spot the same sender submitting repeatedly, and holding raw IP addresses would make that table something worth attacking.
We use what you send to answer you and to keep the form from being abused, and nothing else. It is not added to a mailing list, and it is not shared with anyone outside Haple IO (Pty) Ltd.
3. Information about property owners
Most of the personal information that passes through findproperly is not about our customers. A deeds report names the registered owner of a property and sets out the transfer history with prices and dates, the bonds and endorsements registered against it, and the deeds office references for each. Those people are not our customers, did not come to us, and in most cases will never know a report was pulled.
The source is the South African deeds registry, retrieved through LexisNexis WinDeed under a paid account. The registry is a public register: the Deeds Registries Act makes its records open to inspection on payment of the prescribed fee, and a deeds search is ordinary practice in property work.
Identity numbers are withheld
WinDeed returns a natural person's identity number in full. findproperly does not show it. A South African identity number is not only an identifier: the first six digits are a date of birth, and the rest carries gender and citizenship. Nothing the product does needs it, because the owner's name and the document number already answer who owns what.
The number arrives inside the supplier's response and is stripped from everything the product displays and from everything it sends to a browser. The setting that would reveal it is closed by default, so an unset or mistyped configuration hides the number rather than publishing it.
4. Why we process it, and on what ground
POPIA requires a lawful ground for every purpose. Ours are:
- Running your account and delivering the reports you ask for. Necessary to perform our contract with you.
- Taking payment and keeping the records of it is necessary to perform that same contract, and the accounting records are ones South African law obliges us to keep.
- Retrieving and storing deeds information about property owners rests on our legitimate interests and yours in carrying out lawful property due diligence, drawing on a public register that exists to be inspected. Withholding identity numbers is how we hold that processing to what the work actually needs.
- Answering what you send through the contact form rests on your consent, given when you tick the box on that form. You can withdraw it by asking us to delete the message.
- Keeping the service secure and the form free of abuse: our legitimate interests.
We do not sell personal information, we do not share it for advertising, and we do not profile you to decide anything about you automatically.
5. Who processes it on our behalf
POPIA calls a supplier that processes personal information for us an operator. Ours are:
- LexisNexis WinDeed retrieves deeds data. We send the address or property identifiers being searched, and receive the report.
- Paystack processes card payments and subscriptions. It receives the name, email address and card details you enter at checkout.
- Google provides sign-in, and Google Maps Platform receives the address text typed into the search box so it can suggest and locate places.
- Supabase hosts the Postgres database everything is stored in.
- Vercel hosts and serves the application.
- Anthropic would process conversation content if the assistant were open to your account. It is closed at present, so nothing is being sent.
Each of them is bound to process only on our instructions. We also disclose information where the law requires it, for example on a valid court order or a lawful request from a regulator.
There is no advertising network, no analytics vendor and no data broker in that list, and there is nothing left out of it.
6. What your colleagues can see
Organisations has not shipped. Today an account is a single seat and the library belongs to it, so no colleague sees what you pull. What follows is how sharing will work once it does ship.
Where you use findproperly as part of an organisation, the library will belong to the firm. Every member of the organisation will be able to see every report the organisation holds, including reports you pulled and reports pulled before you joined, and including members with the Billing role whose job is the invoice rather than the property work.
That is a deliberate design, and it widens who sees information about property owners. Think about it before an outside bookkeeper is invited. Your own name and email address will be visible to your organisation's Admin, along with which reports you spent the firm's credits on, and removing a member will end their access immediately.
8. Where it is stored
The database is hosted by Supabase and the application runs on Vercel. The regions they are configured in are [TO BE CONFIRMED: hosting regions for Supabase and Vercel].
Some of the operators listed above process personal information outside South Africa. POPIA allows a cross-border transfer where the recipient is subject to a law, binding rules or an agreement giving protection comparable to POPIA's own conditions, and we rely on our contracts with those providers for that. The specific countries each of them stores data in are [TO BE CONFIRMED: per-operator processing locations, to be verified with each provider].
9. How long we keep it
- Your library is kept while your account, or your organisation, is active.
- A lapsed organisation's library is locked rather than deleted, so it can be restored if the subscription is. Nothing is destroyed on a failed payment.
- Delete a property and it goes, along with its report, its images and any document copies. The ledger row saying what it cost survives with the link to the property removed, because the charge happened and we have to be able to account for it.
- Billing and tax records are kept for the period South African tax and company law requires: [TO BE CONFIRMED: statutory retention period for financial records].
- Contact form submissions are kept for 12 months from the day you send them, then deleted.
- Once an account is closed, the remaining records are deleted after [TO BE CONFIRMED: retention period after account closure], apart from anything we are obliged to keep.
10. How we protect it
- Sign-in is delegated to Google, so we store no password and cannot leak one. Two-factor authentication on your Google account protects your findproperly account too, and turning it on is the single most useful thing you can do here.
- Card details are never held by us.
- Owner identity numbers are withheld by default and never sent to a browser.
- The contact form stores a hash of the sender's IP address rather than the address.
- Traffic to the site and to the database is encrypted in transit.
No service is immune. If a security compromise affects your personal information, POPIA requires us to notify the Information Regulator and the people affected, and we will do that as soon as we reasonably can after establishing what happened.
11. Your rights
Under POPIA you may:
- ask what personal information we hold about you and be given a copy,
- ask us to correct anything inaccurate, or delete anything we no longer need,
- object to processing we base on legitimate interests,
- withdraw consent you have given, which does not undo processing already done,
- complain to the Information Regulator.
Write to our Information Officer at [TO BE CONFIRMED: Information Officer email address]. We will answer within a reasonable time. A formal access request under the Promotion of Access to Information Act has a prescribed form and may carry a prescribed fee, and we will tell you if that applies to what you have asked for.
If you are named in a report
Property owners have these rights too, and they do not depend on being our customer. You can ask what we hold about you and ask us to correct it. What we cannot do is change the deeds registry: an error in the underlying record has to be corrected through the Registrar of Deeds, and until it is, that is what the registry will keep returning to anyone who searches it.
12. The Information Regulator
The supervisory authority for POPIA is the Information Regulator (South Africa). You can complain to it if you think we have handled your personal information unlawfully, and you can do that whether or not you have raised it with us first, though we would rather have the chance to fix it.
The Regulator publishes its current contact details and its complaint forms at inforegulator.org.za.
13. Changes to this policy
We update this policy when what we do with personal information changes, for example when a new operator is added. The date at the top of the page says when it last changed. Where a change materially affects you, we will tell you by email or in the product rather than leaving you to notice the date.
14. Contacting us
Haple IO (Pty) Ltd, trading as findproperly.
- Registered address: Cabernet Villas, 0 Cabernet Sauvignon Street, Oude Westhof, Bellville, 7530
- Information Officer: [TO BE CONFIRMED: Information Officer name]
- Email: [TO BE CONFIRMED: Information Officer email address]
For anything that is not about personal information, the contact form is the quickest route, and the terms of service cover billing, credits and refunds.