FINEHUB (PTY) LTD

Protection of Personal Information Act (POPIA) Compliance

1. Introduction

FINEHUB (PTY) LTD ("we", "us", "our", or "FINEHUB") provides traffic fines aggregation and representation services (the "Services"). This Privacy Policy explains how we collect, use, store, share, and protect your personal information in accordance with the Protection of Personal Information Act, 4 of 2013 ("POPIA"). By using our Services, you agree to the collection and use of information as outlined in this Policy.

2. Purpose of this Policy

This policy explains:

• What personal information we collect

• How we use and protect your information

• Your rights under POPIA

• How to contact us if you have any questions

3. What Information We Collect

We collect various types of personal information to provide and improve our Services:

3.1 Personal Information

For Commercial Clients and End Users, this may include:

• Full name and surname

• South African ID number

• Driver's license number and details

• Email address and phone number

• Business or employer details

• Vehicle registration details and BRNC information

• Billing or payment information

• Traffic fine and infringement data

• Authorized Representative/Proxy information

• Any content you voluntarily submit (e.g. support requests, uploaded documents)

3.2 Traffic Fine Data

We collect and process traffic fine information from:

• AARTO (Administrative Adjudication of Road Traffic Offences)

• RTMS (Road Traffic Management System)

• NATIS (National Traffic Information System)

• Municipal traffic departments

• Subscription-Based Enforcement Providers

3.3 Usage Data

We may collect information automatically through your interaction with our Platform, such as:

• IP address

• Browser type and device identifiers

• Pages visited and time spent

• Operating system and crash logs

• Cookies and tracking data (see section 10)

4. Special Personal Information

We do not intentionally collect or process Special Personal Information as defined in Section 26 of POPIA, such as:

• Health or biometric data

• Religious, political, or philosophical beliefs

• Race or ethnic origin

• Trade union membership

• Criminal history (except as contained in traffic offense records)

If we ever need to process such data, it will be extremely limited, and only:

• With your explicit consent; or

• Where allowed or required by law; or

• For the establishment or defense of a legal right

5. No Automated Decision-Making

We do not use any form of automated decision-making or profiling that produces legal effects or similarly significant consequences for users. All representation decisions and fine management actions involve human review and decision-making.

6. How We Use Your Information

We use the information we collect for the following purposes:

• To provide, maintain, and improve our Services including traffic fine aggregation and representation

• To register and maintain Authorized Representatives/Proxies with traffic authorities

• To access traffic fine data from AARTO, RTMS, NATIS, and other Issuing Authorities

• To process fine redirections, payments, and remittances to relevant authorities

• To provide legal representation and advocacy in traffic fine matters

• To respond to enquiries and support requests

• To process billing and manage accounts

• To notify you about service updates, fine status changes, or policy changes

• To monitor and analyse usage for performance and security

• To comply with legal and contractual obligations

We only process your personal information for the purposes it was collected, unless required by law or with your consent.

7. Sharing of Personal Information

We may share your personal information with:

Traffic Authorities and Issuing Authorities: We share information with AARTO, RTMS, NATIS, municipal traffic departments, and Subscription-Based Enforcement Providers as necessary to provide our Services, including accessing traffic fine data, processing payments, and conducting representations.

Trusted Third-Party Service Providers: We may share information with service providers who help us operate and support the Services (e.g. cloud hosting, payment processors, data centers). These providers are contractually bound to keep your data confidential and use it only for the agreed purposes.

We may also share your data:

• When required by law, court order, or government authority

• To prevent or investigate unlawful activities

• To protect the rights, safety, or property of FINEHUB, our clients, End Users, or the public

• As part of a merger, acquisition, or asset sale (with safeguards in place)

8. Transfers Outside South Africa

Your personal data may be stored or processed outside of South Africa, including countries that may not have the same data protection laws. This may occur where we use cloud hosting services or other service providers with international operations.

In such cases, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by the Information Regulator

• Processing in countries with adequate data protection laws

• Explicit consent where necessary

9. Security of Your Data

We take reasonable, appropriate, and industry-standard precautions to protect your information. These include:

• Encryption of sensitive data in transit and at rest

• Role-based access control and authentication

• Secure cloud infrastructure with regular security updates

• Staff confidentiality agreements and security training

• Regular security audits and vulnerability assessments

• Firewall protection and intrusion detection systems

Despite these measures, no system is completely secure. You acknowledge that any transmission of data is at your own risk. We will notify you and the Information Regulator of any data breach in accordance with POPIA requirements.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Enable core Platform features and functionality

• Remember your preferences and login sessions

• Analyse site performance and usage patterns

• Enhance security and prevent fraud

You can manage or disable cookies through your browser settings. However, disabling cookies may impact your experience with our Services and some features may not function properly.

Types of cookies we use include:

• Session cookies – for Platform functionality and authentication

• Preference cookies – to remember user settings

• Security cookies – to protect your data and prevent unauthorized access

• Analytics cookies – to understand how users interact with our Platform

11. Your Rights Under POPIA

You have the right to:

• Access your personal information and request a copy of the data we hold about you

• Request correction or deletion of inaccurate, outdated, or incomplete data

• Object to processing for direct marketing or on certain legal grounds

• Withdraw consent at any time (where processing is based on consent)

• Request restriction of processing in certain circumstances

• Request destruction or deletion of personal information that is no longer needed

• Lodge a complaint with the Information Regulator of South Africa

12. Objections and Withdrawals

If you object to our processing of your personal information, or wish to withdraw previously granted consent, you may submit a request to:

Email: info@finehub.co.za

Subject line: POPIA Objection / Consent Withdrawal

Postal Address: 24 Ouplaats, 708 Old Farm Road, Faerie Glen, Pretoria, 0081

We will process your request in accordance with applicable legal requirements. Please note that withdrawal of consent may affect our ability to provide certain Services to you.

13. Retention of Information

We retain your information:

• As long as necessary to provide Services and comply with legal obligations

• For the duration of the client relationship plus 7 years for traffic fine and financial records

• For 15 years for representation case files due to prescription periods

• For a reasonable period thereafter for backup, legal, audit, or legitimate business purposes

We will securely delete or anonymise your information when it is no longer required. Upon request and subject to legal obligations, we may destroy personal information earlier than the standard retention periods.

14. Children's Privacy

Our Services are not intended for users under the age of 18. We do not knowingly collect personal information from minors without verified parental or guardian consent.

If we become aware that we have collected information from a minor without appropriate consent, we will take steps to delete such data promptly. If you believe we have inadvertently collected information from a minor, please contact us immediately.

15. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, Services, legal requirements, or for other operational reasons. The latest version will always be available on our website and will include the "Effective Date" at the top.

We may notify you by email, Platform notification, or in-app notice if significant changes are made. Your continued use of our Services after such modifications constitutes acceptance of the updated Privacy Policy.

16. Contact Us

For questions, requests, or concerns about this Privacy Policy or your personal information, please contact:

FINEHUB (PTY) LTD

Information Officer: Anandi De Villiers

Email: info@finehub.co.za

Phone: +27 87 265 3849

Website: finehub.co.za

Physical Address:

24 Ouplaats, 708 Old Farm Road, Faerie Glen, Pretoria, 0081

Information Regulator Contact Details:

If you are not satisfied with our response, you may lodge a complaint with:

Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

Postal Address: P.O Box 31533, Braamfontein, Johannesburg, 2017

Telephone: 012 406 4818

Email: inforeg@justice.gov.za

Website: www.justice.gov.za/inforeg/