Last Updated: 25/08/2026

1. Purpose

This POPIA Privacy Notice explains how Novy Co. processes personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA").

POPIA distinguishes between a "responsible party", which determines the purpose and means of processing, and an "operator", which processes personal information on behalf of another party.

For information processed by novy. for its own purposes, Novy Co. will generally act as the responsible party.

Where novy. processes information on behalf of a business customer, the precise allocation of responsibilities may depend on the nature of the processing and contractual arrangement.

2. Responsible Party

Novy Co.
Email: support@novy.co.za

3. Information Officer

Information Officer:

Thabiso William Hlongoane

Email: thabiso@novy.co.za

4. Personal Information We Process

Depending on your interaction with novy., information may include:

• identification and contact information;
• account information;
• professional information;
• business information;
• profile information;
• photographs and other uploaded content;
• transaction information;
• technical information;
• usage information;
• communications with support; and
• other information voluntarily provided by you.

5. Purposes of Processing

We may process personal information to:

1. provide and administer the Services;
2. create and maintain accounts;
3. provide customer support;
4. process payments;
5. manage subscriptions;
6. provide profile functionality;
7. provide analytics;
8. maintain security;
9. detect fraud and abuse;
10. improve our products;
11. communicate with customers;
12. conduct lawful marketing;
13. comply with legal obligations; and
14. establish, exercise or defend legal rights.

6. Lawful Processing

We process personal information only where there is a lawful basis for doing so.

Depending on the circumstances, this may include:

• consent;
• performance of a contract;
• compliance with a legal obligation;
• protection of legitimate interests;
• legitimate interests of novy. or a third party; or
• another lawful basis recognised under POPIA.

7. Voluntary and Mandatory Information

Some information is necessary to create an account or provide particular Services.

Where information is mandatory, failure to provide it may prevent us from providing the relevant Service.

Where information is optional, you may choose whether to provide it.

8. Public Profile Information

Users control much of the information published on their novy.Profile.

Where a user chooses to publish personal information publicly, that information may be accessible to other people.

Users should carefully consider what information they make public.

9. Recipients

Information may be processed by authorised service providers, including hosting, payment, communications, analytics and technical service providers.

POPIA requires appropriate arrangements where operators process information on behalf of a responsible party.

10. Cross-Border Processing

Certain service providers may process information outside South Africa.

Where applicable, novy. will take reasonable steps to ensure that cross-border transfers comply with POPIA.

11. Security

We implement reasonable security safeguards appropriate to the nature of the information processed.

Where an operator becomes aware that personal information has been accessed or acquired by an unauthorised person, POPIA contains specific notification obligations toward the responsible party.

12. Data Subject Rights

Subject to applicable law, you may request:

• access to personal information;
• correction or updating;
• deletion where legally applicable;
• restriction or objection to certain processing;
• withdrawal of consent where consent is the applicable basis;
• objection to direct marketing; and
• information concerning the processing of your personal information.

13. Direct Marketing

novy. will conduct electronic direct marketing in accordance with applicable law.

POPIA generally prohibits electronic direct marketing without consent unless the applicable existing-customer exception is satisfied.

14. Complaints

If you believe your personal information has been processed unlawfully, please contact us first so that we can investigate and attempt to resolve the matter.

You may also have the right to lodge a complaint with the Information Regulator of South Africa.

15. Updates

We may update this Notice periodically.