This policy sets out how long eRunna (Pty) Ltd (registration number [TBD: company registration number]) retains personal information, the legal bases for each retention period, and how data subjects may exercise their access, correction, and deletion rights under the Protection of Personal Information Act 4 of 2013 (POPIA). Where eRunna is or may become an accountable institution under the Financial Intelligence Centre Act 38 of 2001 (FICA), the applicable customer due-diligence (CDD) and transaction-record obligations are set out separately below. [ATTORNEY-REQUIRED: confirm whether eRunna currently meets the FICA definition of an "accountable institution" under Schedule 1, and if so, which category applies — this determines whether the FICA retention obligations in §3 are currently operative or prospective.]
1. Retention principles (POPIA s14)
We retain personal information no longer than is necessary to achieve the purpose for which it was collected (POPIA s14(1)), unless:
- retention is required or authorised by law;
- we have reasonable grounds to believe that deletion would prejudice a legitimate interest of the data subject;
- retention is required for the fulfilment of an agreement with the data subject; or
- retention is required for the exercise or defence of a legal claim.
Once the retention period expires (or its purpose lapses), personal information is deleted or de-identified as soon as reasonably practicable.
2. POPIA retention schedule
The periods below are our operational defaults. Where a legal minimum exceeds the operational default, the legal minimum governs.
| Category | Retention period | Primary basis |
|---|---|---|
| Account and identity data (customers, runners, merchants, partners) | While the account is active; deleted within 30 days of a verified deletion request, subject to legal-hold exceptions below | Contract (POPIA s11(1)(a)); legal obligation |
| Order/errand records (including pricing, route, and timestamps) | 5 years from the date of the transaction | Financial and tax reporting obligations; dispute resolution |
| Payment transaction metadata (Paystack tokens and authorisation codes; no full PANs stored — see Refunds & Payments) | 5 years from the date of the transaction | Financial/tax reporting; POPIA s14; potential FICA obligation (see §3) |
| Runner assignment and delivery-event records | 5 years from the date of the errand | Dispute resolution; potential tax and labour-law obligations [ATTORNEY-REQUIRED: confirm minimum retention period in light of runner classification — employee vs independent contractor — and applicable labour/ SARS record-keeping requirements] |
| Precise location / route-tracking data | Up to 12 months from collection; aggregated or de-identified thereafter | Service improvement; safety and fraud prevention (POPIA s11(1)(f)) |
| Support communications and in-app chat logs | 24 months from the date of the communication | Customer support; dispute evidence |
| Technical logs and diagnostics | 12 months; aggregated where possible | Security monitoring; service integrity |
| Marketing consent records (waitlist sign-ups, mall-activation opt-ins) | For the duration of the marketing relationship, plus 3 years after opt-out or last contact, as evidence of consent | POPIA s11(1)(b); CPA compliance; evidence of lawful processing |
| KYC / onboarding documents for merchants and partners | 5 years from end of business relationship, or longer if required by FICA (see §3) | Legal obligation; fraud prevention |
3. FICA record-keeping obligations
[ATTORNEY-REQUIRED: Confirm accountable-institution status and applicable Schedule 1 category before publishing this section. The analysis below frames the obligation; the attorney must verify whether it currently binds eRunna and, if so, specify the correct category and any applicable exemptions.]
To the extent that eRunna constitutes an accountable institution under FICA, the following obligations apply in addition to the POPIA schedule above:
- Customer due-diligence (CDD) records — records obtained when establishing a business relationship or conducting a single transaction (identity documents, verification records, beneficial-ownership information) must be retained for a minimum period prescribed by FICA from the date on which the business relationship ends or the transaction is completed. [TBD: attorney to confirm the prescribed FICA minimum period applicable to eRunna's category; the current general obligation under FICA is [TBD: period — attorney to confirm from the current FICA text and any applicable exemption notice].]
- Transaction records — records of each transaction conducted through the platform (including amounts, parties, and dates) must be retained for the FICA-prescribed minimum period from the date of the transaction. [TBD: same period as CDD — attorney to confirm.]
- Suspicious Transaction Reports (STRs) and related correspondence — retained indefinitely pending advice from the Financial Intelligence Centre (FIC), or for such period as the FIC directs. [ATTORNEY-REQUIRED: Confirm reporting obligations and whether eRunna has designated a Compliance Officer and Information Officer as required by FICA and POPIA respectively.]
- These FICA records are kept separately from general operational data and are accessible only to authorised compliance personnel and, on lawful demand, to the FIC and other competent authorities.
4. Your rights as a data subject (POPIA s5, s23, s24)
Under POPIA, you have the following rights in relation to your personal information held by eRunna:
- Right of access (s23) — you may request confirmation of whether we hold personal information about you and, if so, a description of the information and the purpose for which it is held.
- Right to correction (s24) — you may request that we correct or delete personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or unlawfully obtained.
- Right to deletion / restriction — subject to lawful retention requirements (including the FICA obligations in §3), you may request that we delete or de-identify your personal information once the purpose for processing has lapsed.
- Right to object (s11(3)) — you may object to the processing of your personal information on grounds of a legitimate interest, unless we can demonstrate compelling legitimate grounds that override yours.
- Right to portability — we will provide your personal information in a structured, commonly used format where technically feasible.
- Right to lodge a complaint — you may lodge a complaint with the Information Regulator of South Africa (www.inforegulator.org.za) if you believe we have processed your personal information unlawfully.
Certain rights may be limited where retention is required by law (e.g., FICA record-keeping), to protect the rights of another person, or to exercise or defend a legal claim. We will always inform you of the basis for any limitation.
5. How to submit a DSAR
- Email: info@erunna.app with subject line "Data Subject Access Request".
- In-app: via the Account > Privacy settings menu (where available).
- Information Officer: [TBD: full name and contact details of the designated Information Officer, once registered with the Information Regulator.] [ATTORNEY-REQUIRED: eRunna must designate and register an Information Officer under POPIA. Confirm name, registration status, and whether a Deputy Information Officer is required.]
We will verify your identity before processing any DSAR. We aim to respond within 30 days of receiving a complete request. Where a request is complex or we receive multiple requests, we may extend this period by a further 30 days and will notify you accordingly.
Where a deletion is actioned, we will notify relevant processors and sub-processors of the deletion obligation within a reasonable time.
6. Deletion procedures
Deletion is carried out as a logical deletion followed by a physical purge in accordance with the schedule in §2. Backup copies are purged within 30 days of the scheduled purge date. Aggregated or de-identified data (from which you cannot reasonably be identified) may be retained beyond the retention period for analytical purposes.
FICA records (§3) are subject to separate archival procedures and are not subject to data-subject deletion requests where lawful retention is mandated.
7. Exceptions and legal holds
We may depart from the standard retention schedule in the following circumstances:
- A legal or regulatory requirement mandates longer retention (e.g., SARS, FICA, court order).
- The information is necessary to resolve an active dispute or enforce an agreement.
- A supervisory authority (including the Information Regulator or FIC) has directed that information be preserved.
- We have reasonable grounds to believe that deletion would harm the data subject's own legitimate interests.
Where a legal hold is applied, we will document the hold, its scope, and its basis, and will notify the data subject to the extent permitted by law.
8. PAIA manual
Private bodies are required to compile and make available a manual under the Promotion of Access to Information Act 2 of 2000 (PAIA), including the categories of records held and how to submit an access request. [ATTORNEY-REQUIRED: The PAIA manual is a separate statutory requirement under PAIA (the manual obligation is commonly associated with s51 — confirm the current operative section and its sub-parts). A prior exemption for certain small private bodies has been reported to have lapsed [ATTORNEY-REQUIRED: confirm the exemption's expiry date and whether any private body currently qualifies for exemption]. eRunna must prepare and publish a PAIA manual. This document does NOT substitute for that obligation.] Until the PAIA manual is published, access requests may be directed to info@erunna.app.
9. Data collection at physical activations and waitlist sign-ups
Where personal information is collected at in-person mall activations or via the "Join the waitlist" web form, the following applies:
- A POPIA-compliant collection notice (s18) is provided at the point of collection, specifying the purpose, the responsible party, and data-subject rights. [ATTORNEY-REQUIRED: Confirm the current collection notice meets the s18 requirements in full — including disclosure of any third-party marketing recipients and the data subject's right to object to direct marketing under s69.]
- Marketing consent collected at these touchpoints is retained for the period specified in the retention schedule (§2, marketing consent row).
- If any promotional competition or giveaway is conducted at a mall activation, the CPA promotional-competition rules apply (including public notification of material conditions and prize details). [ATTORNEY-REQUIRED: Confirm CPA compliance obligations for any planned giveaways — in particular whether the activity constitutes a "promotional competition" under the CPA and what notice, record-keeping, and prize-disclosure obligations apply.]
10. Changes to this policy
We may update this policy from time to time. Material changes will be communicated via in-app notification and/or email. The "Last updated" date at the top of this page reflects the most recent revision. Your continued use of the Services after a material change constitutes acknowledgement of the updated policy.