Privacy Policy

1. Introduction

RROI (Pty) Ltd respects your right to privacy and is committed to processing personal information lawfully, reasonably, transparently and securely in accordance with the Protection of Personal Information Act 4 of 2013, commonly referred to as POPIA, and other applicable South African laws.

This policy should be read together with the RROI Terms and Conditions, Refund Policy, Affiliate Terms where applicable, and any consent notices displayed when you create an account, submit information, place an order or make a payment.

2. Who We Are and Our Role

RROI (Pty) Ltd is the responsible party for personal information processed through the RROI platform. This means RROI determines why and how personal information is processed for purposes connected with operating and providing the RROI service.

RROI provides an online emergency-information platform through which a profile owner can create and maintain an emergency profile linked to a unique QR code. When the QR code is scanned, the profile information made publicly visible under the applicable profile level may be displayed in a web browser.

3. Scope of This Policy

This policy applies to personal information processed through:

• the RROI website at www.rroi.co.za;
• the RROI web application and mobile application;
• Free and Premium emergency profiles;
• RROI QR codes, wallpapers and physical QR products;
• Premium subscriptions, renewals and Premium Kit purchases;
• the RROI online store;
• the RROI affiliate programme;
• support, service and marketing communications; and
• related administrative, security and legal processes.

4. Meaning of Key Terms

In this policy:

• “Personal information” means information relating to an identifiable person, as described in POPIA.
• “Special personal information” includes information concerning a person’s health, medical circumstances, religious beliefs and certain other protected categories.
• “Processing” includes collecting, recording, storing, using, sharing, updating, deleting or otherwise handling personal information.
• “Profile owner” means the account holder who creates, manages or is authorised to manage an RROI profile.
• “Public profile” means the information displayed when an RROI QR code or public profile link is opened.
• “Emergency contact” means a person whose details are supplied by a profile owner for emergency-contact purposes.
• “Child” has the meaning assigned to that term under applicable South African law and POPIA.

5. Information We Collect

RROI collects information that you voluntarily submit, together with limited information generated through the operation, security and administration of the platform.

5.1 Account information

• email address;
• authentication and account identifiers;
• account creation and verification information;
• login and session information;
• marketing-consent status and related timestamps; and
• account status and account-deletion information.

Passwords are processed through RROI’s authentication service. RROI does not have access to your password in readable form.

5.2 Identity and profile information

• first name and surname;
• profile photograph;
• date of birth and automatically calculated age;
• gender;
• nationality;
• province and city;
• primary and secondary language;
• height and weight;
• eye colour, hair colour, skin tone and identifying marks; and
• other information you choose to add to your profile.

5.3 Emergency and medical information

• blood type;
• allergies;
• medical conditions;
• medications;
• implanted devices;
• mobility information;
• pregnancy information;
• organ-donor status;
• preferred hospital;
• medical-aid provider, plan and membership or policy number;
• general practitioner and specialist contact details;
• additional medical notes;
• local ambulance or security-company details; and
• custom emergency call-button information.

5.4 Emergency-contact information

• emergency-contact names;
• relationship to the profile owner;
• telephone numbers; and
• any additional emergency-contact information voluntarily supplied.

5.5 Subscription, payment and consent information

• subscription type and status;
• subscription start and end dates;
• payment amount, payment status and payment reference;
• discount or affiliate codes used;
• records confirming acceptance of applicable legal terms;
• the date and time of legal acceptance;
• IP address and user-agent information recorded during checkout; and
• transaction information returned by the payment provider.

RROI does not request or store your complete payment-card number, card security code or online-banking password. Payment information of that nature is entered into and processed through the third-party payment provider.

5.6 Order and delivery information

• customer and recipient names;
• email address and cellphone number;
• delivery address;
• products and quantities ordered;
• order and delivery status;
• courier and tracking information;
• QR link and public profile identifier required to manufacture personalised QR products; and
• limited profile and emergency information required to prepare the ordered product.

5.7 Affiliate information

• affiliate application information;
• contact information and location;
• promotional methods and target audience;
• social-media handles supplied by the applicant;
• experience and application responses;
• affiliate code and status;
• bank name, account-holder name, account number, account type and branch code;
• referral, commission and payout records;
• EFT references; and
• internal review notes.

5.8 Ratings and feedback

• star rating;
• experience comments;
• improvement feedback;
• permission or refusal regarding public use of feedback; and
• whether an authorised review has been selected for homepage display.

5.9 Technical and security information

• IP address where collected for security, consent or transaction purposes;
• browser and user-agent information;
• device and operating-system information made available through normal web requests;
• authentication and session information;
• security, diagnostic and error information;
• service-worker and application-cache information; and
• information stored through essential browser storage.

6. How We Collect Information

Personal information may be collected:

• directly from you when you register, complete or update a profile;
• when an authorised parent or guardian creates or manages a profile for another person;
• when you place an order, subscribe, renew or make a payment;
• when you apply for or participate in the affiliate programme;
• when you submit a rating, support request or other communication;
• automatically through essential authentication, browser-storage and security technologies;
• from PayFast after a transaction is attempted or completed; and
• from service providers where necessary to deliver, secure or administer the RROI service.

7. Purposes for Processing Information

RROI may process personal information for the following purposes:

• creating, verifying and administering user accounts;
• creating and maintaining emergency profiles and unique QR codes;
• displaying the appropriate public profile when a QR code is scanned;
• generating phone and smartwatch QR wallpapers;
• providing Free and Premium profile functionality;
• processing subscriptions, renewals, purchases and payments;
• manufacturing and delivering personalised QR products;
• operating and administering the affiliate programme;
• calculating and recording affiliate commissions and payouts;
• sending account, verification, order, payment, tracking, affiliate and renewal communications;
• responding to support, privacy and account requests;
• recording legal agreements and transaction consent;
• preventing misuse, unauthorised access, fraud and security incidents;
• maintaining, testing and improving the platform;
• complying with legal, regulatory, accounting and tax obligations;
• establishing, exercising or defending legal rights; and
• sending marketing communications where valid consent has been provided.

8. Lawful Grounds for Processing

Depending on the circumstances, RROI processes information on one or more lawful grounds, including:

• your consent;
• performance of a contract or steps taken at your request before entering into a contract;
• compliance with legal obligations;
• protection of your legitimate interests or those of another person;
• RROI’s legitimate interests in operating, securing and administering the service, where those interests do not unjustifiably interfere with your privacy; and
• other grounds permitted under POPIA or applicable law.

Where RROI relies on consent, you may withdraw that consent, subject to lawful limitations and the consequences of no longer being able to provide the relevant feature.

9. Special Personal Information

Emergency profiles may contain health, medical, religious and other special personal information. Providing these fields is voluntary unless a particular field is clearly marked as required for a requested transaction or product.

RROI processes this information for the specific purpose of storing and displaying emergency information selected by the profile owner, administering the account and providing related services. RROI does not diagnose, treat, monitor or verify medical conditions and does not independently confirm the accuracy of information submitted by users.

You should only provide special personal information that is relevant to the emergency-profile purpose and that you are comfortable making visible under your selected public-profile level.

10. Public Emergency Profiles and QR Codes

The central purpose of RROI is to make selected emergency information accessible when a unique QR code or public profile link is opened. A public RROI profile does not require the person scanning the QR code to log in.

• A Free profile publicly displays the information made available in Section 1 of the profile.
• A Premium profile may publicly display completed information from Sections 1 to 7.
• Only completed fields intended for public display are shown.
• A profile owner may complete information that is not publicly visible under the Free profile level.
• Anyone who obtains or scans the QR code may be able to view the publicly available profile information.
• RROI cannot control screenshots, photographs, copying or further sharing by a person who has accessed a public profile.

Profile owners must carefully consider what information they enter and must protect their QR code and public profile link in a manner appropriate to the information displayed.

11. Accuracy and Responsibility for Information

Profile owners are responsible for ensuring that information entered into RROI is accurate, complete, current and not misleading. Emergency and medical information should be reviewed and updated whenever circumstances change.

RROI does not independently verify medical information, emergency contacts, identity information or other user-supplied content. Incorrect, incomplete or outdated information may reduce the usefulness of the profile.

12. Information About Other People

When you provide information about an emergency contact, child, dependant or another person, you confirm that:

• you are authorised to provide and use that information;
• you have obtained any consent required by law;
• the information is accurate to the best of your knowledge; and
• you have informed the person, where appropriate, about how the information will be used and displayed.

13. Children’s Information

Profiles relating to children must be created or managed with the involvement and lawful authority of a parent, legal guardian or other competent person as required by applicable law.

A person under 13 may not independently create or manage an RROI profile. A parent or legal guardian should create and manage the profile on that person’s behalf.

Where a profile relates to a person under 18, the person creating or managing the profile confirms that they have the necessary authority and consent to process and publish the child’s information. RROI may request confirmation of that authority and may restrict or remove a profile where lawful authority cannot be established.

14. Payments

RROI uses PayFast to process payments. When you proceed to payment, information necessary to process the transaction is transmitted to PayFast. PayFast processes payment information under its own terms and privacy practices.

RROI may receive and store transaction references, amounts, payment status, payer information returned by PayFast and related transaction records. RROI does not store your complete payment card details or online-banking credentials.

15. Service Providers and Information Sharing

RROI does not sell personal information. Information may be disclosed to service providers, contractors or other recipients where reasonably necessary for the purposes described in this policy.

Current categories and examples of providers include:

• Supabase for database hosting, authentication and file storage;
• Vercel for website and application hosting and delivery;
• PayFast for payment processing;
• Brevo for transactional and authorised marketing email delivery;
• courier and delivery providers for physical-product fulfilment;
• Google services for relevant mobile-application distribution and business communications;
• Microsoft services for relevant business administration and records; and
• professional advisers, accountants, tax practitioners or legal advisers where reasonably necessary.

Providers are given only the information reasonably necessary for the service they perform and may be subject to contractual, technical and legal confidentiality or data-protection obligations.

16. Other Circumstances in Which Information May Be Disclosed

RROI may disclose personal information where:

• you have authorised the disclosure;
• disclosure is necessary to provide a service or complete a transaction requested by you;
• RROI is required or permitted to do so by law, regulation, court order, warrant or lawful regulatory request;
• disclosure is reasonably necessary to investigate fraud, misuse, security threats or unlawful activity;
• disclosure is required to protect the rights, safety or property of RROI, a user or another person;
• disclosure is necessary to establish, exercise or defend legal rights; or
• RROI undergoes a lawful merger, acquisition, sale, restructuring or transfer of business, subject to applicable privacy requirements.

17. International and Cross-Border Processing

Some service providers used by RROI operate or store information outside South Africa. Personal information may therefore be transferred to, stored in or accessed from other countries.

RROI will take reasonable steps to ensure that cross-border processing occurs in accordance with POPIA, including by using reputable providers, appropriate contractual safeguards or other lawful transfer mechanisms where required.

18. Cookies, Sessions and Browser Storage

RROI uses essential technologies required for authentication, security and operation of the platform. These may include:

• authentication cookies or session tokens that keep users signed in;
• local storage or session storage used for essential application functions;
• service-worker and cache storage used to support the web application or installed application experience;
• security information used to prevent unauthorised access; and
• temporary storage required to complete forms, downloads or application functions.

These technologies are necessary for the requested service and are not used by RROI to sell personal information.

RROI does not currently use third-party advertising cookies or behavioural advertising trackers. If optional analytics, advertising or similar non-essential technologies are introduced, this policy and any required consent process will be updated.

Blocking essential browser storage may prevent login, account access or other features from functioning correctly.

19. Marketing Communications

RROI sends marketing emails only where the user has selected the applicable marketing-consent option or where another lawful basis permits the communication.

Users may subscribe or unsubscribe through their profile where that option is available, use an unsubscribe method contained in a communication, or contact RROI at support@rroi.co.za.

Withdrawing marketing consent does not prevent RROI from sending essential service communications such as verification, transaction, security, subscription, order or account notices.

20. Data Security

RROI applies reasonable technical and organisational safeguards appropriate to the nature of the information processed. These measures include, where applicable:

• encrypted HTTPS connections;
• managed authentication and password hashing through the authentication provider;
• server-side authentication and authorisation checks;
• restricted administrator access using a dedicated authorised administrator account;
• service-role credentials retained on the server and not intentionally exposed to users;
• database access controls and row-level security where applicable;
• input validation and restricted administrative endpoints;
• two-factor authentication on relevant business services where enabled;
• controlled access to business systems and records; and
• weekly offline backup copies stored on a separately secured hard drive in a locked safe.

Despite reasonable safeguards, no internet service, database, device, transmission method or storage system can be guaranteed to be completely secure. Users must keep their login credentials and devices secure and must notify RROI promptly if they suspect unauthorised access.

21. Security Incidents

If RROI becomes aware of a security compromise involving personal information, RROI will investigate, contain and respond to the incident and will make notifications to affected persons and the Information Regulator where required by applicable law.

Notifications may be delayed where a competent authority determines that notification would impede a criminal investigation.

22. Data Retention

RROI retains personal information only for as long as reasonably necessary for the purposes for which it was collected, while an account or transaction remains active, or for a period required or permitted by law.

• Active account and profile information is generally retained while the account remains active.
• Public visibility may be reduced when a Premium subscription expires or is cancelled, while the underlying account continues to exist.
• Incomplete store-checkout records may remain temporarily until completed, deleted through account deletion or removed through normal administrative processes.
• Legal-consent records connected with payment checkout may be retained for up to five years for evidentiary, dispute-resolution, fraud-prevention or legal purposes.
• Transaction, tax, accounting, payment-provider and business records may be retained for the applicable period required or permitted by law.
• Affiliate payout and related business records may be retained where required for accounting, tax, fraud-prevention, dispute-resolution or legal purposes.
• Information may be retained for longer where reasonably required for an actual or anticipated legal claim, regulatory investigation or lawful instruction.

When information is no longer required, RROI will take reasonable steps to delete, destroy, de-identify or restrict it, subject to applicable technical and legal limitations.

23. Backups

RROI creates an offline backup approximately once per week for disaster-recovery and business-continuity purposes. The previous backup is normally overwritten when the next backup is created.

Information deleted from the live system may therefore remain in a backup for a limited period, generally until the next weekly backup rotation. Backup information is not intended for ordinary operational use and would only be accessed where reasonably necessary for disaster recovery, security investigation, legal compliance or business continuity.

24. Account Deletion

A logged-in user may use the in-app account-deletion process. The process requires confirmation and authentication before the account is deleted.

Subject to successful completion of the process and applicable legal-retention requirements, account deletion removes active user-linked information including:

• the authentication account;
• the emergency profile and public profile;
• the unique profile QR records;
• emergency-contact records;
• uploaded profile photographs stored by RROI;
• subscriptions;
• active payment and application records linked to the account;
• Premium order-form and shipping information;
• pending store-order information;
• RROI order records linked to the account;
• ratings, feedback and public-review permission;
• affiliate applications, referral records and affiliate account information; and
• associated affiliate payout records where removed through linked database deletion rules.

Certain separate records may remain where retention is required or permitted for legal agreements, transaction evidence, accounting, tax, fraud prevention, disputes, security, enforcement or other lawful purposes. Records retained after deletion will not be used to recreate the deleted public profile unless required by law or expressly authorised by the affected person.

External providers, including payment, email or delivery providers, may retain their own records under their legal and contractual obligations. RROI cannot directly delete information controlled independently by those providers.

25. Your Rights

Subject to POPIA and other applicable laws, you may have the right to:

• ask whether RROI holds personal information about you;
• request access to personal information held by RROI;
• request correction or updating of inaccurate information;
• request deletion or destruction where legally permitted;
• object to processing on reasonable grounds where POPIA permits an objection;
• withdraw consent where processing is based on consent;
• object to or unsubscribe from direct marketing;
• request information about the identity of third parties that have had access to your information where legally applicable;
• submit a complaint to RROI; and
• lodge a complaint with the Information Regulator.

RROI may request reasonable information to verify your identity and authority before processing a privacy request. A request may be refused or limited where permitted or required by law, and RROI will explain the lawful reason where appropriate.

26. Complaints

Privacy concerns should first be sent to RROI at support@rroi.co.za. Please provide enough information for RROI to understand and investigate the concern.

If you believe that your personal information has been processed in violation of POPIA, you may lodge a complaint with the Information Regulator of South Africa. The Information Regulator’s designated POPIA complaints email is POPIAComplaints@inforegulator.org.za.

27. Automated Decision-Making

RROI does not currently use solely automated decision-making that produces legal or similarly significant effects concerning users. Automated processes may be used for ordinary operational functions such as account verification, subscription status, payment confirmation, reminders, fraud checks and profile visibility.

28. Medical and Emergency-Service Clarification

RROI is an information-storage and retrieval platform. It is not a medical practitioner, healthcare provider, emergency-response service, ambulance service or substitute for professional medical advice or emergency assistance.

RROI does not direct medical treatment and does not guarantee that a QR code will be scanned, that a profile will be accessed, that information will be relied upon or that the service will be continuously available. Healthcare professionals, emergency personnel and other persons remain responsible for their own professional decisions and legal duties.

29. Changes to This Policy

RROI may update this Privacy Policy when its services, legal obligations, providers or processing activities change. The revised policy will be published on the RROI website with an updated effective date.

Where a change materially affects how personal information is processed, RROI will take reasonable steps to provide an additional notice or obtain consent where required by law.

30. Contact RROI

Questions, access requests, correction requests, deletion requests, objections, marketing-consent requests and other privacy enquiries may be submitted by email to: