1. Introduction
This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and what rights you have in relation to it. This Policy applies to all users of the Platform, including Creators, Brands, and consumers.
This Policy is governed by the Protection of Personal Information Act 4 of 2013 (“POPIA”) and should be read together with our Terms of Service.
2. Who is the Responsible Party?
Plug Central (Pty) Ltd
Website: plugcentral.co.za
Email: privacy@plugcentral.co.za
Information Officer: Reece Williamson
3. Personal Information We Collect
3.1 Information You Provide to Us
- Full name and username;
- Email address and contact number;
- South African ID number or passport number (for payment verification purposes);
- Banking details or payment account information (for Creator payouts);
- Business registration details (for Brand accounts);
- Profile photo, bio, and social media handles;
- Content you upload, including product links, images, and descriptions; and
- Communications you send to us or other users through the Platform;
- Messaging templates, automation settings, campaign configurations, AI-generated prompts, and communication preferences you create or configure through the Platform; and
- Information you provide when connecting Third-Party Platforms or communication channels to the Platform.
3.2 Information We Collect Automatically
- IP address and approximate location derived from it;
- Device type, operating system, and browser information;
- Pages visited, links clicked, and time spent on the Platform;
- Referring URLs and traffic sources;
- Creator content engagement patterns, including click-through rates, post performance, product interaction data, and storefront visit behaviour;
- Cookie and tracking data (see Section 8 below); and
- Messaging activity metadata, including message delivery status, timestamps, engagement metrics, reply activity, and automation performance data;
- Usage data relating to Messaging Services, including scheduling activity, campaign interaction metrics, and workflow analytics; and
- Technical logs and security information relating to connected Third-Party Platform integrations.
3.3 Information from Third Parties
- Social media platforms (e.g. Instagram, TikTok, Facebook, WhatsApp) if you connect your accounts to Plug Central;
- Third-Party Platform APIs and integration providers used to enable Messaging Services and automation functionality;
- Brand partners, for the purpose of tracking affiliate referrals and commission calculations; and
- Payment processors, for the purpose of verifying and completing transactions.
4. How We Use Your Personal Information
- To create, manage, and operate your account on the Platform;
- To facilitate affiliate tracking, commission calculations, and payouts to Creators;
- To enable Brands to run and manage affiliate programmes;
- To personalise your experience on the Platform;
- To communicate with you about your account, transactions, and Platform updates;
- To send you marketing communications where you have consented, or where we have a legitimate interest to do so;
- To derive anonymised, aggregated audience and engagement insights from Creator content activity, which may be packaged and shared with retail brand partners for market research and campaign planning purposes (see Section 6.4);
- To detect, investigate, and prevent fraud, abuse, or violations of our Terms of Service;
- To comply with our legal and regulatory obligations under South African law;
- To improve and develop the Platform through analytics and research;
- To provide, operate, monitor, and improve Messaging Services and automation functionality;
- To transmit, schedule, process, and manage communications initiated through connected Third-Party Platforms;
- To generate AI-assisted message suggestions, communication insights, and automation recommendations;
- To monitor platform integrity, detect spam or abusive behaviour, and enforce messaging-related restrictions and policies;
- To maintain logs, audit trails, and security records associated with Messaging Services;
- To comply with direct marketing, anti-spam, and platform compliance obligations;
We will not process your personal information for purposes incompatible with those listed above without your prior consent.
5. Legal Basis for Processing
- Contractual necessity: processing is required to perform our agreement with you (e.g. operating your account, processing payouts);
- Legitimate interests: processing is in our or a third party’s legitimate interests (e.g. fraud prevention, Platform security, analytics, and the derivation and commercialisation of anonymised audience insights, messaging infrastructure integrity, abuse prevention, automation monitoring, platform security, and service optimisation), where these are not overridden by your rights;
- Legal obligation: processing is required to comply with applicable law (e.g. tax reporting, regulatory requirements); and
- Consent: where we rely on your consent where required for direct marketing communications sent through Messaging Services (e.g. for marketing emails), you may withdraw that consent at any time.
6. Sharing Your Personal Information
6.1 With Brands
6.2 With Service Providers
- Payment processors (for Creator payouts and Brand billing);
- Email and communication platforms;
- Analytics and data intelligence providers; and
- Cloud hosting and infrastructure providers.
All service providers are required to process your information only on our instructions and in compliance with POPIA or equivalent data protection standards.
6.3 Messaging and Communication Providers
This may include message content, recipient identifiers, engagement metrics, delivery metadata, scheduling information, and automation configuration data strictly to the extent necessary to operate the Messaging Services.
We require such providers to implement appropriate security safeguards and process personal information only for authorised purposes consistent with this Privacy Policy and applicable law.
6.4 Retail Analytics Partners
We are committed to ensuring that data shared with retail analytics partners cannot be used to identify any individual Creator. Specifically:
- No names, email addresses, contact numbers, or other directly identifying personal information are included in data sold or shared with retail partners;
- Insights are aggregated across multiple Creators before being shared, so no individual Creator’s data is singled out; and
- Retail partners are contractually prohibited from attempting to re-identify individuals from the insights provided.
By registering as a Creator and using the Platform, you acknowledge that this commercial use of anonymised, aggregated data derived from your activity forms part of Plug Central’s business model. If you do not agree to this use, you may deactivate your account by contacting us at hello@plugcentral.co.za.
6.5 Legal Disclosure
6.6 Business Transfers
6.7 No Sale of Personal Information
7. Cross-Border Transfers of Personal Information
8. Cookies and Tracking Technologies
8.1 What Are Cookies?
8.2 Types of Cookies We Use
- Essential cookies: required for the Platform to function, including session management and security;
- Functional cookies: remember your preferences and settings;
- Analytics cookies: help us understand how users interact with the Platform (e.g. Google Analytics); and
- Affiliate tracking cookies: record click-through events and attribute purchases to Creators for commission purposes.
8.3 Your Cookie Choices
9. Data Retention
- Account information is retained for the duration of your account and for up to 5 years after closure, for legal and compliance purposes;
- Transaction and commission records are retained for 7 years in line with South African tax and financial record-keeping requirements;
- Analytics data is retained in anonymised or aggregated form indefinitely;
- Marketing consent records are retained for the duration of your consent and for a reasonable period thereafter as evidence of consent;
- Messaging logs, communication metadata, campaign activity, and automation records may be retained for operational, security, compliance, dispute resolution, and audit purposes;
When personal information is no longer required, we securely delete or anonymise it.
10. Security of Your Personal Information
- Encryption of data in transit using TLS/SSL;
- Access controls limiting who within our organisation can access personal information;
- Regular security assessments of our Platform and infrastructure; and
- Secure payment processing through PCI-DSS compliant third-party processors;
- Security controls and monitoring relating to connected Third-Party Platform integrations and Messaging Services.
No method of transmission or storage is completely secure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the Information Regulator as required by POPIA section 22.
User Responsibility & Liability
You are responsible for maintaining the confidentiality of your account credentials. Plug Central (Pty) Ltd implements rigorous security measures; however, we take no responsibility for any loss of income, commissions, or data incurred as a result of the leaking or compromise of your credentials due to your own negligence or third-party unauthorized access.
11. Your Rights Under POPIA
- Right of access: you may request a copy of the personal information we hold about you;
- Right to correction: you may request that we correct inaccurate or incomplete personal information;
- Right to deletion: you may request that we delete your personal information, subject to our legal retention obligations;
- Right to object: you may object to the processing of your personal information where we rely on legitimate interests;
- Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting prior processing; and
- Right to complain: you have the right to lodge a complaint with the Information Regulator of South Africa;
- Right to object to direct marketing: you may object at any time to the use of your personal information for direct marketing purposes;
To exercise any of these rights, please contact us at privacy@plugcentral.co.za. We will respond to your request within 30 days. We may need to verify your identity before processing your request.
12. The Information Regulator
Information Regulator (South Africa)
Website: inforegulator.org.za
Email: complaints.IR@justice.gov.za
Tel: 010 023 5207
13. Children’s Privacy
14. Direct Marketing
Where users utilise Messaging Services or automation functionality through the Platform, they are solely responsible for ensuring that they have obtained any legally required consents before sending direct marketing communications to third parties.
Plug Central may process and transmit communications on behalf of users strictly for the purpose of providing Messaging Services and related Platform functionality.
You may opt out of receiving marketing communications from Plug Central at any time by:
- Clicking the “unsubscribe” link in any marketing email; or
- Contacting us at hello@plugcentral.co.za.
Opting out of marketing communications will not affect transactional or service-related communications related to your account.
15. Third-Party Platforms and Links
If you choose to connect third-party social media accounts (such as Instagram or TikTok) to your Plug Central profile, those platforms’ own privacy policies govern how they collect and use your information. If you connect Third-Party Platforms or communication channels to Plug Central, we may access and process certain account information, messaging functionality, engagement data, and communications strictly to provide the services you enable. Your interactions with Third-Party Platforms remain subject to those providers’ own terms, privacy policies, and platform rules.
16. AI-Assisted Features and Automated Processing
These systems are intended to assist users and are not designed to make legally binding decisions about individuals without human involvement. Users remain responsible for reviewing and approving communications and actions generated through AI-assisted functionality.
We may process usage data, engagement metrics, prompts, and interaction patterns to improve Platform functionality, system performance, safety, and automation quality.
17. Changes to This Privacy Policy
We encourage you to review this Policy periodically to stay informed about how we protect your personal information.
18. Contact Us
Plug Central (Pty) Ltd — Information Officer
Website: plugcentral.co.za
Email: privacy@plugcentral.co.za