Privacy Policy

1. What this Privacy Policy covers

This privacy policy (“Privacy Policy”) governs how Jointly (Pty) Ltd (“Jointly”, “we”, “us”, or “our”) collects, uses, stores, shares, and protects personal information obtained from users (“you” or “your”) across our platform.

This policy explains:

1. The personal information we collect about you and your family;
2. The legal bases and purposes for collecting and using that information;
3. How and with whom your information may be shared;
4. How you can exercise your privacy rights under South African and international law; and
5. How you can update your information or contact our Information Officer.

By accessing or using our website at https://www.jointly.co.za (the “Site”), using our iOS or Android software applications (the “App”), contacting customer service, or using any co-parenting tools, financial features, or calling services (collectively, the “Services”), you acknowledge and consent to the practices described in this Privacy Policy.

This policy does not apply to third-party websites or services that Jointly does not own or control, or to individuals that Jointly does not employ or manage.

2. Information collection and lawful grounds for processing

We process “Personal Information” (and “Special Personal Information”) as defined under the Protection of Personal Information Act (POPIA) and applicable global data protection laws (such as the UK/EU GDPR).

Categories of data we collect

1. Account & Identity Data: Full name, national identity number or passport number, date of birth, physical address, email address, contact numbers, and login credentials.
2. Co-Parenting & Family Data: Names, dates of birth, school information, medical contacts, emergency contact details, and child care schedules.
3. Financial Data: Payment card details, bank account numbers (processed securely via regulated third-party payment gateways), billing history, and expense reimbursement records.
4. Communication & User Content: In-app messages, calendar entries, journal logs, audio/video call recordings, transcripts, and tone analysis metrics.
5. Technical & Usage Data: IP address, device type, operating system, unique device identifiers, browser type, crash logs, and clickstream interactions.

Lawful bases for processing

Pursuant to Section 11 of POPIA and applicable international data laws, we process your data under the following lawful grounds:

3. Recorded audio and video calls

When utilizing Jointly’s integrated audio or video communication tools, you will be prompted for explicit consent before any call is recorded or transcribed.

1. Mandatory Consent: If you do not consent to being recorded, you must not join or remain on the recorded call.
2. Child Consent: Where calls involve or capture details regarding minors (individuals under 18 years of age in South Africa), consent must be granted by a parent or legal guardian.
3. Access to Transcripts: Downloadable copies of recordings and text transcripts may be accessed by call participants and, where authorized, by linked professional accounts (such as legal representatives, mediators, or family court officials).

4. Artificial Intelligence (AI) features

Jointly may offer AI-driven communications tools (e.g., tone perception alerts and alternative phrasing suggestions) to assist users in maintaining constructive co-parenting dialogue.

1. No Public Training: We do not sell, lease, or permit third-party AI providers to use your private family communications to train external or public AI models.
2. Data Usage: Data intentionally submitted to AI tools is processed strictly to generate immediate writing suggestions and tone evaluations.
3. User Responsibility: AI output is generated probabilistically. It does not constitute legal, psychological, or therapeutic advice. You remain solely responsible for reviewing and verifying any AI-suggested text before sending it.

5. Automated data collection & cookies

When you visit our Site or open our App, we use cookies, web beacons, and similar tracking technologies to gather technical information automatically.

Cookie classifications

1. Essential Cookies: Necessary for core website operations, security, and authentication.
2. Functional Cookies: Remember your preferences, language settings, and customized layout.
3. Analytics Cookies: Track aggregate usage patterns to help us measure app performance and content relevance.
4. Marketing Cookies: Help us evaluate the effectiveness of our promotional campaigns (you may opt out at any time).

You can modify your browser settings to decline or limit cookies. However, disabling essential or functional cookies may impair app performance or prevent access to certain features.

6. App permissions (mobile devices)

To deliver full functionality, the Jointly App may request access to certain hardware and system permissions on your mobile device, including:

• Camera & Photo Library: To upload receipts, documentation, or profile photos.
• Calendar: To sync co-parenting schedules with your device's native calendar.
• Microphone & Camera: To facilitate audio and video calls.
• Storage & Files: To download exportable PDF communication logs and court-ready records.
• Notifications: To deliver instant alerts for new messages, expense requests, or schedule updates.

You may adjust these permissions at any time through your device settings.

7. Information sharing and disclosure

Jointly does not sell or rent your Personal Information to third parties. We only share information under the following strictly managed conditions:

1. Linked Accounts & Shared Data: Messages, shared expenses, and calendar events are intentionally disclosed to the co-parent or professional accounts (e.g., attorneys, mediators) linked to your group.
2. Service Providers & Operators: We share data with vetted third-party vendors who assist in operating our platform (including cloud hosting providers, IT security firms, SMS gateways, and payment processors). These service providers are contractually bound under Section 20 of POPIA to preserve data confidentiality.
3. Legal & Regulatory Obligations: We may disclose your information to law enforcement authorities, courts, or regulatory bodies if required to do so by subpoena, court order, or applicable law, or where necessary to protect the safety and rights of our users.
4. Business Restructuring: In the event of a merger, acquisition, or sale of company assets, customer records may be transferred as part of the business assets, subject to this Privacy Policy.
5. Aggregate / Anonymous Data: We reserve the right to generate, analyze, and commercialize fully de-identified and aggregated statistical data that cannot be linked back to any natural person.

8. International data transfers

Jointly is based in South Africa. However, our server infrastructure, technical support tools, or service providers may operate in foreign jurisdictions (including the United States, the European Economic Area, or the United Kingdom).

When transferring Personal Information outside South Africa, we comply with Section 72 of POPIA by ensuring that:

1. The recipient country offers an adequate level of data protection substantially similar to POPIA;
2. Standard Contractual Clauses (SCCs) or binding data transfer agreements are executed with the recipient; or
3. The transfer is necessary for the performance of our contract with you, or you have granted explicit consent.

9. Data retention and deletion restrictions

We retain Personal Information for as long as your account remains active or as needed to provide you with the Services, comply with legal obligations, resolve disputes, and enforce our agreements.

Shared data exception

Due to the joint legal nature of family records, Shared Data (such as past messages, expense histories, and court-stamped logs) constitutes an important legal record for both linked co-parents.

Requesting the deletion of your account will not automatically erase Shared Data from a linked co-parent’s active portal, as doing so would prejudice their legal rights to maintain historical records. Erasing Shared Data requires either:

1. The mutual written consent of all active subscribers connected to that shared record; or
2. A formal order issued by a court of competent jurisdiction.

10. Your privacy rights

Under POPIA (and European/UK data protection regulations where applicable), you have specific rights regarding your Personal Information:

1. Right to Access: Request confirmation of whether we hold personal information about you and receive a copy of that data.
2. Right to Correction / Rectification: Request the correction or updating of inaccurate, incomplete, or out-of-date information.
3. Right to Object: Object to the processing of your personal data on reasonable grounds relating to your particular situation (unless processing is mandated by law).
4. Right to Opt-Out of Direct Marketing: Request that we stop sending you promotional or marketing materials at any time using the “unsubscribe” link or by contacting us.
5. Right to Erasure / Deletion: Request the deletion of personal data that is no longer necessary or where processing lacks a lawful basis (subject to the Shared Data Exception in Section 9).
6. Right to Lodge a Complaint: Lodge a complaint with the statutory data protection regulator.

11. Supervisory authority / complaints

If you are unsatisfied with how we handle your Personal Information, we encourage you to contact our Information Officer first so we can resolve the issue.

However, you retain the right to submit a formal complaint to the South African Information Regulator:

The Information Regulator (South Africa)
Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Email: complaints.IR@inforegulator.org.za
Website: https://inforegulator.org.za

(For users accessing Services from the UK or EU, you may also lodge a complaint with the UK Information Commissioner's Office (ICO) or your local EU Data Protection Authority).

12. Changes to this Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our legal obligations, technology, or service features. We will publish updated versions directly on our Site and App. Your continued use of the Services following the posting of an updated Privacy Policy signifies your acceptance of the revised terms.

13. Contact us & Information Officer

If you have questions, wish to exercise your statutory rights, or need further information regarding this Privacy Policy, please contact our designated Information Officer:

Attn: Information Officer / Data Protection Team
Entity: Jointly (Pty) Ltd
Email: hello@jointly.co.za
Website Contact: https://www.jointly.co.za/contact