REFORM AND GLOW (PTY) LTD
Privacy Policy for the Reform and Glow Mobile Application, Website and Studio Services
Issued in terms of the Protection of Personal Information Act 4 of 2013 (POPIA)
Website: https://reformglow.co.za | Email: Reformandglow0@gmail.com
Effective Date: 1 August 2026
Last Updated: 1 August 2026
1.1 Reform and Glow (Pty) Ltd ("Reform and Glow", "we", "us" or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, share, protect and otherwise process your personal information when you use the Reform and Glow mobile application (the "App"), our website at https://reformglow.co.za (the "Website"), our reformer pilates studio(s) (the "Studio") and any related classes, memberships, packages and services (collectively, the "Services").
1.2 This Privacy Policy is issued in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") and its regulations, and is intended to give effect to the openness requirements in sections 17 and 18 of POPIA by notifying you of the matters that POPIA requires us to disclose. It should be read together with our Terms and Conditions, available in the App and at https://reformglow.co.za.
1.3 This Privacy Policy applies to all clients, prospective clients, App users, Website visitors, parents or guardians of minor participants, and other persons whose personal information we process in connection with the Services. It does not apply to the personal information of our employees or contractors, which is dealt with in separate internal policies.
1.4 By using the App, the Website or the Services, you acknowledge that you have read and understood this Privacy Policy. Where we rely on your consent to process your personal information (for example, in relation to your health information or certain marketing communications), we will ask for that consent separately and specifically, and you may withdraw it at any time as described in clause 9.
1.5 If you have any questions about this Privacy Policy, please contact our Information Officer at Reformandglow0@gmail.com.
2.1 For the purposes of POPIA, the responsible party that determines the purpose of and means for processing your personal information is:
2.2 Information Officer. In accordance with sections 55 and 56 of POPIA and section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), our Information Officer is responsible for encouraging and ensuring compliance with POPIA, dealing with requests made to us under POPIA and PAIA, and working with the Information Regulator in relation to any investigation. Our Information Officer is:
2.3 Our Information Officer has been (or will be) registered with the Information Regulator of South Africa as required by POPIA.
3.1 In this Privacy Policy, unless the context indicates otherwise, the following terms have the meanings given to them below, which are based on the definitions in POPIA:
3.2 Capitalised terms not defined in this Privacy Policy have the meanings given to them in our Terms and Conditions.
4.1 We are committed to processing your personal information in accordance with the eight conditions for the lawful processing of personal information set out in Chapter 3 of POPIA, namely:
5.1 The personal information that we collect depends on how you interact with us. We may collect and process the following categories of personal information:
| Category | Examples of personal information |
|---|---|
| Identity information | Full name, date of birth, age, gender (optional), identity or passport number (only where required, e.g. for corporate or medical-aid-linked programmes), profile photograph (optional). |
| Contact information | Email address, mobile telephone number, physical or postal address (optional), emergency contact name, relationship and telephone number. |
| Account information | Username, encrypted password or authentication token, login method (e.g. email, Sign in with Apple or Google Sign-In), account preferences, notification settings, acceptance records for our Terms and Conditions and this Privacy Policy. |
| Booking and membership information | Class bookings, attendance and check-in records, waitlist status, cancellations, late cancellations and no-shows, packages, memberships, class credits, membership freezes, Instructor preferences and class history. |
| Payment-related information | Transaction amounts, dates and references, products purchased, payment status, refund history, billing name and email, and a payment token or reference issued by Payfast. We do not collect or store your full card number, card expiry date, CVV or banking passwords (see clause 12.4). |
| Health and fitness information (special personal information) | Information disclosed in the Health Questionnaire and to Instructors, including medical conditions, injuries, pregnancy, surgeries, medications, physical limitations, fitness level and goals, medical clearance certificates, and incident or injury reports (see clause 6). |
| Device and usage information | Device model, operating system and version, unique device and app-instance identifiers, advertising identifiers (only where permitted by your device settings), push notification tokens, IP address, mobile network, language and time zone settings, app version, screens viewed, features used, session duration, in-app events, crash logs and performance data. |
| Location information | Approximate location inferred from your IP address; and precise device location only if you choose to grant location permission (for example, to find directions to the Studio or check in on arrival) (see clause 14). |
| Communications information | Emails, messages, in-app chat, WhatsApp or SMS correspondence, feedback, reviews, survey responses, complaints and records of telephone calls with us. |
| Marketing information | Your marketing preferences and consents, opt-out records, referral information, and interactions with our marketing emails and push notifications (e.g. whether a message was opened). |
| Images and CCTV footage | Photographs or videos taken at the Studio (only with your consent where you are identifiable), and CCTV footage recorded in reception and common areas for security purposes. |
5.2 Voluntary or mandatory. Where we request personal information that is necessary to create your Account, process a Booking or purchase, or ensure your safety (such as your name, contact details, emergency contact and Health Questionnaire responses), the supply of that information is mandatory in the sense that, if you do not provide it, we may be unable to provide the Services to you or allow you to participate in Classes. Where information is optional (such as a profile photograph or gender), we will indicate this, and you may choose not to provide it without affecting your access to the Services.
5.3 Information about other persons. If you provide us with personal information about another person (for example, an emergency contact or a person for whom you purchase a gift voucher), you confirm that you are authorised to do so and that you have informed that person of this Privacy Policy.
IMPORTANT – PROCESSING OF YOUR HEALTH INFORMATION
Health information is special personal information under section 26 of POPIA and is subject to additional protection. We process your health information only with your explicit consent (or as otherwise permitted by POPIA) and only for the purposes of ensuring your safety during Classes and Private Sessions, adapting exercises to your needs and responding to emergencies. You may withdraw your consent at any time, but this may mean that we cannot safely allow you to participate in Classes.
6.1 Why we collect health information. Reformer pilates and related activities involve physical exertion and the use of spring-loaded equipment. To enable our Instructors to provide safe, appropriate instruction and modifications, and to respond properly in the event of an injury or medical emergency, our Terms and Conditions require you to disclose relevant medical conditions, injuries, pregnancy, surgeries, medications and changes in your health before and while participating in the Services.
6.2 What we collect. The health information we may collect includes: responses to our Health Questionnaire; information about current and past injuries, medical conditions, surgeries and medications; pregnancy and post-natal status; physical limitations and mobility; medical clearance letters or certificates; notes made by Instructors regarding modifications required for your safety; and incident and injury reports.
6.3 Lawful basis – explicit consent (sections 26 and 27 of POPIA). Section 26 of POPIA prohibits the processing of special personal information unless a general authorisation in section 27 (or a specific authorisation in sections 28 to 33) applies. We rely primarily on your explicit consent in terms of section 27(1)(a) of POPIA. We obtain this consent through a separate, clearly worded consent mechanism (such as an unticked checkbox) when you complete the Health Questionnaire in the App, on the Website or at the Studio. We may also process health information where it is necessary for the establishment, exercise or defence of a right or obligation in law, in accordance with section 27(1)(b) of POPIA (for example, in connection with an incident report or a legal claim).
6.4 Minors. Where the data subject is a child, we will process health information only with the prior consent of a competent person (such as a parent or legal guardian), in accordance with sections 27(1)(a) and 35 of POPIA.
6.5 How we use it. We use health information only to: (a) assess whether it is safe for you to participate and whether medical clearance is required; (b) enable Instructors to modify exercises and select appropriate Classes; (c) respond to injuries and medical emergencies, including by sharing relevant information with emergency medical personnel; (d) record and investigate incidents; (e) process medical-related membership freezes or credits; and (f) establish, exercise or defend legal rights.
6.6 What we do not do. We do not use your health information for marketing or advertising, we do not sell it, we do not share it with analytics or advertising providers, and we do not use it to make automated decisions about you.
6.7 Access restrictions. Access to health information is strictly limited to authorised personnel who need it to perform their functions (for example, the Instructor teaching your Class and Studio management), each of whom is subject to confidentiality obligations. Health information is stored with additional access controls within our systems.
6.8 Withdrawal of consent. You may withdraw your consent to the processing of your health information at any time by emailing Reformandglow0@gmail.com or by using the relevant setting in the App (where available). Withdrawal will not affect the lawfulness of processing before withdrawal. Please note that, because the disclosure of relevant health information is a safety requirement under our Terms and Conditions, withdrawal of consent may mean that we are unable to allow you to participate in Classes or Private Sessions. We may retain records such as incident reports where we are entitled to do so under section 27(1)(b) of POPIA or other law.
6.9 Other special personal information. We do not intentionally collect other categories of special personal information (such as religious beliefs, race or ethnic origin, political persuasion or biometric information). Please do not provide such information to us unless we specifically request it for a lawful purpose. If we introduce any biometric check-in or similar feature, we will update this Privacy Policy and obtain your explicit consent beforehand.
7.1 Directly from you. We collect most personal information directly from you, for example when you: download the App and register an Account; complete your profile or the Health Questionnaire; make a Booking or purchase; check in at the Studio; communicate with us by email, WhatsApp, telephone, in-app messaging or social media; complete a survey, competition entry or feedback form; subscribe to our newsletter; or attend the Studio.
7.2 Automatically. When you use the App or Website, we and our third-party service providers automatically collect certain device and usage information through software development kits ("SDKs"), cookies and similar technologies, as described in clauses 12 and 13.
7.3 From third parties. We may receive personal information about you from third parties, including: Payfast (payment confirmations and transaction references); Apple or Google (if you use Sign in with Apple, Google Sign-In or in-app purchases, and aggregated statistics relating to App downloads); a person who purchases a gift voucher or class package for you, or who refers you; your employer or a corporate wellness partner (if you participate through a corporate programme); and social media platforms (if you interact with our pages or link your social media account).
7.4 From public sources. We may collect information that you have made publicly available, such as public comments or reviews about Reform and Glow on social media or review platforms.
7.5 In accordance with section 12 of POPIA, where we collect personal information from a source other than you, we will do so only where permitted by POPIA (for example, where the information is contained in a public record, where you have consented, or where collection from another source is necessary for a lawful purpose).
8.1 We process your personal information only for specific, explicitly defined and lawful purposes, and only where one or more of the lawful grounds in section 11(1) of POPIA applies. These grounds are: (a) your consent; (b) processing is necessary to carry out actions for the conclusion or performance of a contract to which you are a party; (c) processing complies with an obligation imposed by law; (d) processing protects your legitimate interest; or (f) processing is necessary for pursuing our legitimate interests or those of a third party to whom the information is supplied. The table below sets out our main purposes and the corresponding lawful grounds:
| Purpose | Categories of information | Lawful ground (POPIA) |
|---|---|---|
| Creating and managing your Account; verifying your identity; providing customer support | Identity, contact, account, communications | Performance of contract (s11(1)(b)); legitimate interests (s11(1)(f)) |
| Processing Bookings, waitlists, check-ins, packages and memberships; managing cancellations and no-shows | Identity, contact, account, booking and membership | Performance of contract (s11(1)(b)) |
| Processing payments, recurring billing and refunds via Payfast; preventing payment fraud | Identity, contact, payment-related | Performance of contract (s11(1)(b)); legal obligation (s11(1)(c)); legitimate interests (s11(1)(f)) |
| Assessing your fitness to participate safely, adapting Classes, and responding to injuries and emergencies | Health information, emergency contact | Explicit consent (s27(1)(a)); establishment, exercise or defence of legal rights (s27(1)(b)); protecting your legitimate interest (s11(1)(d)) |
| Sending service communications (booking confirmations, reminders, timetable changes, waitlist notifications, account and payment notices), including push notifications | Contact, account, booking, device (push tokens) | Performance of contract (s11(1)(b)); legitimate interests (s11(1)(f)) |
| Sending direct marketing, newsletters, promotions and special offers | Identity, contact, marketing | Consent, or existing-customer exception, in terms of s69 (see clause 10) |
| Analysing App and Website usage, measuring performance, diagnosing crashes and improving the Services | Device and usage, approximate location | Legitimate interests (s11(1)(f)); consent where required by your device settings or applicable law |
| Maintaining the security of the Studio, the App and our systems, including CCTV monitoring and fraud prevention | CCTV footage, device and usage, account | Legitimate interests (s11(1)(f)); protecting your legitimate interest (s11(1)(d)) |
| Complying with legal, tax, accounting and regulatory obligations, and responding to lawful requests from authorities | Identity, contact, payment-related, booking | Legal obligation (s11(1)(c)) |
| Handling complaints, disputes and legal claims, and enforcing our Terms and Conditions | All relevant categories | Legitimate interests (s11(1)(f)); legal obligation (s11(1)(c)); s27(1)(b) for health information |
| Using photographs or videos in which you are identifiable for marketing or social media | Images | Consent (s11(1)(a)) |
| Conducting surveys and obtaining feedback to improve our Services | Identity, contact, communications | Legitimate interests (s11(1)(f)); consent where required |
8.2 Legitimate interests. Where we rely on legitimate interests, we have considered whether those interests are outweighed by your rights and interests, taking into account the nature of the information, your reasonable expectations and the safeguards in place. You have the right to object to such processing, as described in clause 19.
8.3 Further processing. If we wish to use your personal information for a purpose that is not compatible with the purpose for which it was collected, we will do so only where permitted by section 15 of POPIA (for example, with your consent), and we will notify you beforehand where required.
8.4 De-identified information. We may de-identify or aggregate personal information so that it can no longer be used to identify you, and use such de-identified information for statistical, analytical and business-planning purposes. De-identified information is not personal information under POPIA.
9.1 Where we rely on your consent, that consent will be voluntary, specific and informed. We will request it separately from your acceptance of our Terms and Conditions (for example, by means of an unticked checkbox or a toggle in the App) and will record when and how it was given.
9.2 The processing activities for which we rely on your consent include: (a) processing your health information (clause 6); (b) electronic direct marketing to persons who are not existing customers (clause 10); (c) using identifiable photographs or videos of you in marketing; (d) processing the personal information of a child with the consent of a competent person (clause 21); and (e) device-level permissions such as push notifications and precise location (clause 14).
9.3 You may withdraw your consent at any time, free of charge, by: (a) adjusting the relevant settings in the App or on your device; (b) clicking the "unsubscribe" link in any marketing email; or (c) emailing Reformandglow0@gmail.com. We will give effect to your withdrawal as soon as reasonably practicable.
9.4 Withdrawal of consent will not affect the lawfulness of any processing carried out before withdrawal, or processing that is based on another lawful ground (for example, processing necessary for the performance of a contract or to comply with a legal obligation), in accordance with section 11(2)(b) of POPIA.
10.1 We may use your personal information to send you information about our Classes, memberships, promotions, events, workshops and other products and services that may be of interest to you, subject to section 69 of POPIA and the Consumer Protection Act 68 of 2008.
10.2 Existing customers. Where you are an existing customer and we obtained your contact details in the context of the sale of a product or service, we may send you electronic direct marketing (for example, by email, SMS or push notification) relating to our own similar products or services, provided that you were given a reasonable opportunity to object, free of charge and without unnecessary formality, when your details were collected, and that you are given the opportunity to object on each occasion that we send you a marketing communication, in accordance with section 69(3) of POPIA.
10.3 Non-customers. Where you are not an existing customer, we will send you electronic direct marketing only if you have given your prior consent. We will approach you for your consent only once, and only if you have not previously withheld such consent, in accordance with section 69(2) of POPIA.
10.4 Opting out. Every direct marketing communication we send will contain our details and an easy method for you to opt out (unsubscribe). You may opt out at any time by: (a) clicking the "unsubscribe" link in any marketing email; (b) replying "STOP" to marketing SMS or WhatsApp messages, where offered; (c) disabling marketing push notifications in the App or in your device settings; or (d) emailing Reformandglow0@gmail.com. We will process opt-out requests promptly and without charge.
10.5 Opting out of marketing does not affect service communications that are necessary to provide the Services (such as booking confirmations, cancellation notices and payment notifications).
10.6 We do not sell, rent or trade your personal information to third parties for their own direct marketing purposes.
11.1 We do not sell your personal information. We share personal information only to the extent necessary for the purposes described in this Privacy Policy, and only with the following categories of recipients:
11.2 Operator agreements. In accordance with sections 20 and 21 of POPIA, we require all operators that process personal information on our behalf to do so only with our knowledge and authorisation, to treat the information as confidential, and to establish and maintain appropriate security safeguards. Where an operator is not bound by standard terms that already meet these requirements, we will conclude a written agreement with it. Operators must notify us immediately if they have reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person.
11.3 Some third-party service providers (for example, Apple, Google and Payfast) also act as independent responsible parties in respect of certain personal information they collect directly from you, and their processing is governed by their own privacy policies.
12.1 The App and Website use, or may use, the third-party services, software development kits (SDKs) and plugins described in this clause 12. Some of these services are confirmed as part of our technology stack, while others are services that we may use from time to time to operate, support or improve the Services. These providers may process your personal information as our operators or, in some cases, as independent responsible parties. Each provider's processing is also governed by its own privacy policy, which we encourage you to read.
12.2 We select reputable providers, configure their services to limit data collection to what is reasonably necessary, and (where they act as our operators) require them to protect your personal information in accordance with POPIA. Many of these providers are located outside South Africa, and the transfer of personal information to them is subject to clause 15.
12.3 Google Analytics and Google Analytics for Firebase (app performance and usage analytics). We use Google Analytics and/or Google Analytics for Firebase, provided by Google LLC and its affiliates ("Google"), to understand how users interact with the App and Website, to measure performance and to improve our Services.
12.4 Payfast (online payment processing). We use Payfast, a third-party online payment gateway, to process payments for packages, memberships, Private Sessions and other Services made through the App or Website.
12.5 OneSignal (push notifications). We use OneSignal, provided by OneSignal, Inc., to send push notifications and in-app messages to your device.
12.6 Firebase Crashlytics (crash reporting and performance). We may use Firebase Crashlytics and Firebase Performance Monitoring, provided by Google, to identify and fix crashes, errors and performance issues in the App.
12.7 Google Firebase and cloud hosting. We may use Google Firebase services (such as Firebase Authentication, Cloud Firestore, Cloud Storage and Cloud Functions), Google Cloud Platform and/or other reputable cloud hosting and database providers to host the App's back-end, store Account and booking data, authenticate users and run server-side functions.
12.8 Apple App Store and Google Play (app distribution and in-app services). The App is distributed through the Apple App Store (operated by Apple Inc.) and Google Play (operated by Google LLC).
12.9 Google Maps (studio location). We may use Google Maps Platform, provided by Google, to display the location of the Studio in the App or on the Website and to provide directions.
12.10 Email service providers. We may use third-party email service and customer communication providers (such as Google Workspace, Microsoft 365 or reputable email-marketing platforms) to send transactional emails (such as booking confirmations, receipts and password resets) and, where permitted, newsletters and marketing emails.
12.11 Social media integrations. We may maintain pages on, and integrate features from, social media platforms such as Instagram, Facebook, TikTok, YouTube, WhatsApp and LinkedIn (for example, social sharing buttons, embedded content, links to our social media pages, or WhatsApp Business messaging).
12.12 Booking and studio management software. We may use a third-party studio management, scheduling or booking platform to manage the class timetable, Bookings, memberships, check-ins and client records. Such a provider would process your identity, contact, account, booking, membership and (where stored on the platform) health information on our behalf as our operator.
12.13 Other service providers. We may also use other service providers for customer support tools, website hosting and content management, IT security and backup, accounting and invoicing, and professional services. We will update this clause 12 from time to time to reflect material changes to the third-party services we use.
13.1 Our Website uses cookies, and our App uses SDKs, local storage and similar technologies (together, "cookies"), to operate, secure and improve the Services. Cookies are small data files placed on your device that allow a website or app to recognise your device and store certain information.
13.2 We may use the following types of cookies:
13.3 Where required by law, we will ask for your consent before placing non-essential cookies on your device, for example through a cookie banner on the Website. You can manage or delete cookies through your browser settings and manage in-app tracking through your device settings. Blocking certain cookies may affect the functionality of the Website or App.
14.1 The App may request access to certain features of your device. We will request each permission at the time it is needed (where your operating system allows), and you can grant, refuse or withdraw any permission at any time in your device settings. Refusing a permission will not prevent you from using the core features of the App, although certain functions may not work.
15.1 Some of our third-party service providers (including Google, OneSignal, Apple and certain email and hosting providers) store or process personal information on servers located outside the Republic of South Africa, including in the United States of America, the European Union and other jurisdictions.
15.2 In accordance with section 72 of POPIA, we will transfer your personal information to a third party in a foreign country only if:
15.3 Where we transfer personal information across borders, we take reasonable steps to ensure that the recipient provides adequate protection, for example by relying on providers that are subject to comprehensive data protection laws (such as the European Union General Data Protection Regulation) or that have contractually committed to data protection standards (such as standard contractual clauses or data processing terms).
15.4 Special personal information. Health information is stored with providers that apply strong security measures. Where health information is transferred outside South Africa, we will ensure that the transfer complies with section 72 of POPIA and, where required, with section 57 of POPIA (prior authorisation).
16.1 In accordance with section 19 of POPIA, we secure the integrity and confidentiality of personal information in our possession or under our control by taking appropriate, reasonable technical and organisational measures to prevent loss of, damage to or unauthorised destruction of personal information, and unlawful access to or processing of personal information.
16.2 To do so, we take reasonable measures to: (a) identify all reasonably foreseeable internal and external risks to personal information; (b) establish and maintain appropriate safeguards against the risks identified; (c) regularly verify that the safeguards are effectively implemented; and (d) ensure that the safeguards are continually updated in response to new risks or deficiencies.
16.3 Our safeguards include, as appropriate:
16.4 While we take all reasonable steps to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. You are responsible for keeping your Account login credentials confidential and for notifying us immediately at Reformandglow0@gmail.com if you suspect any unauthorised access to your Account.
17.1 In accordance with section 22 of POPIA, where there are reasonable grounds to believe that your personal information has been accessed or acquired by any unauthorised person (a "security compromise"), we will notify:
17.2 as soon as reasonably possible after the discovery of the security compromise, taking into account the legitimate needs of law enforcement and any measures reasonably necessary to determine the scope of the compromise and to restore the integrity of our information systems.
17.3 We may delay notifying you only if a public body responsible for the prevention, detection or investigation of offences, or the Information Regulator, determines that notification will impede a criminal investigation.
17.4 Notification to you will be in writing and communicated by at least one of the following methods: email to your registered email address; notice in the App; publication on our Website or in the news media; or as directed by the Information Regulator.
17.5 The notification will provide sufficient information to allow you to take protective measures against the potential consequences of the compromise, including: (a) a description of the possible consequences of the security compromise; (b) a description of the measures we intend to take or have taken to address the compromise; (c) a recommendation of the measures you can take to mitigate its possible adverse effects; and (d) if known, the identity of the unauthorised person who may have accessed or acquired your personal information.
17.6 We maintain an internal incident response procedure, and we require our operators to notify us immediately of any security compromise affecting personal information they process on our behalf.
18.1 In accordance with section 14 of POPIA, we retain personal information only for as long as necessary to achieve the purpose for which it was collected or subsequently processed, unless: (a) retention is required or authorised by law; (b) we reasonably require the record for lawful purposes related to our functions or activities; (c) retention is required by a contract between you and us; or (d) you (or a competent person, in the case of a child) have consented to the retention.
18.2 Our general retention periods are set out below. Actual periods may vary depending on the circumstances, for example where information is needed for an ongoing dispute or legal claim.
| Category | Indicative retention period |
|---|---|
| Account, identity and contact information | For as long as your Account is active, and for 3 (three) years after your Account is closed or becomes inactive, to deal with queries, disputes and legal claims. |
| Booking, attendance and membership records | For as long as your Account is active, and for 3 (three) years thereafter. |
| Health information and Health Questionnaires | For as long as you are an active client, and for 3 (three) years after your last attendance (being the general prescription period for most claims under the Prescription Act 68 of 1969), or longer where required in connection with an incident, injury report or legal claim. |
| Incident and injury reports | For at least 3 (three) years after the incident or, in the case of a minor, until 3 (three) years after the minor reaches the age of 18, or for longer if a claim is pending. |
| Financial and transaction records | For at least 5 (five) years as required by the Tax Administration Act 28 of 2011 and at least 7 (seven) years as required in respect of accounting records by the Companies Act 71 of 2008. |
| Marketing preferences and opt-out records | Until you withdraw consent or opt out, after which we retain a record of your opt-out to ensure your preference is respected. |
| Device, usage and analytics data | In accordance with the retention settings configured in the relevant service (for example, Google Analytics user-level data retention of up to 14 (fourteen) months), after which it is deleted or aggregated. |
| Crash and performance data | For a limited period determined by the relevant provider (e.g. Firebase Crashlytics). |
| CCTV footage | Up to 30 (thirty) days, unless required for the investigation of an incident or legal proceedings. |
| Communications and complaints | For 3 (three) years after the matter is resolved. |
18.3 In accordance with section 14(4) and (5) of POPIA, when we are no longer authorised to retain personal information, we will destroy or delete it, or de-identify it, as soon as reasonably practicable, in a manner that prevents its reconstruction in an intelligible form. Where processing must be restricted rather than deleted (for example, where you contest the accuracy of the information or where information must be kept for evidential purposes), we will restrict processing in accordance with section 14(6) of POPIA.
18.4 Account deletion. You may request deletion of your Account and associated personal information at any time through the account-deletion function in the App (where available), through our account deletion request page at the Profile section of the App, or by emailing Reformandglow0@gmail.com. We will delete or de-identify your personal information within a reasonable period, except for information that we are required or permitted to retain as described above.
19.1 Subject to POPIA and PAIA, you have the following rights in respect of your personal information, as set out in section 5 and Chapter 3 of POPIA:
20.1 You may exercise any of your rights by contacting our Information Officer at Reformandglow0@gmail.com. To help us deal with your request efficiently, please: (a) state which right you wish to exercise; (b) provide sufficient detail to identify the personal information concerned; and (c) provide your contact details.
20.2 Prescribed forms. You may use the forms prescribed under the Regulations relating to the Protection of Personal Information, 2018, including Form 1 (objection to the processing of personal information) and Form 2 (request for correction or deletion of personal information or destruction or deletion of a record of personal information). Requests for access to records may be made in accordance with PAIA and our PAIA manual, using the form prescribed under PAIA. These forms are available from the Information Regulator's website (https://inforegulator.org.za) or on request from us.
20.3 Verification of identity. To protect your personal information, we will take reasonable steps to verify your identity before responding to a request, and may ask you to provide proof of identity. Where a request is made on your behalf, we will require proof of the requester's authority.
20.4 Response times and fees. We will respond to your request within a reasonable time and, in the case of PAIA requests, within the time periods prescribed by PAIA (generally 30 (thirty) days, subject to extension in the circumstances allowed by PAIA). Confirmation of whether we hold personal information about you is free of charge. A prescribed fee may be payable for the reproduction of records in terms of PAIA, and we will provide you with a written estimate of any fee before providing the service, in accordance with section 23(2) of POPIA.
20.5 Refusal. We may refuse a request, in whole or in part, only on the grounds permitted by POPIA and PAIA (for example, where disclosure would involve the unreasonable disclosure of personal information about another person). If we refuse a request, we will give reasons and inform you of your right to complain to the Information Regulator.
20.6 Correction. Where we correct, delete or destroy personal information following your request, and the change has an impact on decisions made about you, we will, where reasonably practicable, inform each person or body to whom the information has been disclosed of the steps taken, in accordance with section 24(3) of POPIA.
20.7 PAIA manual. Our manual prepared in terms of section 51 of PAIA, which describes the categories of records we hold and the procedure for requesting access to records, is available on request from Reformandglow0@gmail.com.
21.1 The App and our Account services are intended for adults aged 18 (eighteen) years and older. We do not knowingly allow children to register an Account in their own name.
21.2 Where a child participates in Classes (to the extent permitted under our Terms and Conditions), the child's personal information, including any health information, will be processed only with the prior consent of a competent person (such as a parent or legal guardian), in accordance with sections 34 and 35(1)(a) of POPIA, or where otherwise permitted by section 35 of POPIA.
21.3 The competent person will be responsible for providing the child's information, completing the Health Questionnaire on the child's behalf, and managing the relevant Account or bookings. The competent person may exercise the child's rights under POPIA, including the right to access, correct or delete the child's personal information and to withdraw consent.
21.4 We will not use a child's personal information for direct marketing, and we will not publish identifiable images of a child without the specific prior consent of a competent person.
21.5 If we become aware that we have collected personal information from a child without the consent of a competent person, we will take reasonable steps to delete that information as soon as reasonably practicable. If you believe that we may have collected such information, please contact us at Reformandglow0@gmail.com.
22.1 We do not make decisions about you that result in legal consequences for you, or that affect you to a substantial degree, based solely on the automated processing of your personal information intended to provide a profile of you, as contemplated in section 71 of POPIA.
22.2 We may use limited automated processes in the ordinary course of providing the Services, for example: automatically allocating waitlisted clients to available places in the order in which they joined the waitlist; automatically applying late-cancellation or no-show rules in accordance with our Terms and Conditions; automatically sending reminders and notifications; and segmenting clients by broad criteria (such as membership type or class preferences) to send relevant communications. These processes are based on rules that are disclosed to you, and you may contact us at Reformandglow0@gmail.com to request human review of any outcome, to make representations, or to obtain information about the underlying logic.
22.3 We do not use your health information for any automated decision-making or profiling.
23.1 In accordance with section 16 of POPIA, we take reasonably practicable steps to ensure that your personal information is complete, accurate, not misleading and updated where necessary. You can help us by keeping your Account profile, emergency contact details and Health Questionnaire up to date and by informing us promptly of any changes.
23.2 The App and Website may contain links to third-party websites, apps and services that are not operated by us. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to read the privacy policy of every website or app you visit.
24.1 If you have any concern or complaint about how we process your personal information, we encourage you to contact our Information Officer first at Reformandglow0@gmail.com, so that we have an opportunity to address it. We will acknowledge your complaint promptly and endeavour to resolve it within a reasonable time.
24.2 You also have the right, at any time, to lodge a complaint with the Information Regulator of South Africa in accordance with section 74 of POPIA. Complaints must be submitted on the prescribed form (POPIA Form 5), which is available on the Information Regulator's website. The Information Regulator's contact details are:
25.1 We may amend this Privacy Policy from time to time to reflect changes in the law, in our processing activities, in the third-party services we use, or in the features of the App and Website. The amended Privacy Policy will be published in the App and on the Website, with the "Last Updated" date revised accordingly.
25.2 Where we make material changes, we will notify you by email, push notification and/or a prominent notice in the App before the changes take effect and, where the changes require your consent under POPIA, we will obtain your consent before applying them.
25.3 We encourage you to review this Privacy Policy periodically. Your continued use of the App, the Website or the Services after an amendment takes effect will be subject to the amended Privacy Policy, save where your consent is required.
26.1 If you have any questions, requests or concerns regarding this Privacy Policy or the processing of your personal information, please contact us: