Privacy Policy

1. Introduction

The Addex Platform is owned and operated by ADX Digital (Pty) Ltd.

Our Platform:

• is a marketing and advertising platform that connects users with brands, retailers, businesses and other service providers based on the user’s selected interests and preferences; and
• can be accessed and used by downloading our Addex App (“App”), browsing our website, when you are assisted by our employees or agents, or by any other means we may make available to you in the future.

This Privacy Policy (“Policy”) applies when you access and/or use our Platform, whether you’re a consumer browsing ads or a business running campaigns.

Your privacy is important to us. To understand your privacy rights and how we collect, use, store and protect your information, you must read this Policy carefully before accessing and/or using our Platform. Use of our Platform is governed by South African law as well as any requirements set by the Apple App Store and Google Play Store. This Policy must be read with our Cookie Policy and Notice and our Terms of Use.

2. Definitions

“We”, “our” and “us” means ADX Digital (Pty) Ltd, a private company incorporated in the Republic of South Africa with registration number 2022/659982/07, and includes (unless the context indicates otherwise) our agents, employees, service providers and affiliates.

“You”, “your” and “user” means any natural person who downloads, accesses and/or uses our Platform, whether in your personal capacity or on behalf of a juristic or other non-juristic entity.

“Personal information” means information as defined in the Protection of Personal Information Act 4 of 2013, South Africa (as amended from time to time) (“POPIA”), relating to you, the user, and includes information we learn about you when you use our Platform and location data we track in order to customise your experience. We do not collect or process any Special Personal Information, as defined in POPIA. However, if you choose to share health information or other special categories of personal information with us on your own initiative, we process this information based on our legitimate interests and so that we are able to establish, exercise or defend legal claims. In special circumstances, where required by applicable legislation, we may rely on your consent for our processing.

“Process” or “processing”, where it concerns your personal information, means collection, receipt, recording, organising, collating, storing, updating, modifying, retrieving, altering, consulting, using, disseminating (by means of transmission, distribution or making available in any other form), merging, linking, restricting, degrading, erasing or destruction.

3. Processing your personal information

3.1 We will process your personal information so that you can benefit from the features of our Platform, and to provide, personalise and improve our services, including:

• to register you to use our Platform and manage your profile;
• to facilitate targeted advertising and marketing based on your preferences;
• to personalise and customise your experience on our Platform, based on your specified interests;
• to communicate important updates;
• to respond to your queries, complaints or requests, including those you send through the contact form on our website;
• to comply with legal obligations under POPIA and international regulations (where applicable);
• for statistical purposes and analytics;
• to conduct surveys, research or data analysis;
• to manage payments when campaigns or listings are created, if you have registered an advertiser or marketer profile;
• to send you notifications and announcements about us and our products via email, SMS and/or push notifications, if you are an advertiser or marketer;
• to display your business information to our other users in terms of their chosen preferences and interests, if you have registered an advertiser or marketer profile;
• to facilitate competitions; or
• for any other purpose you may agree to.

3.2 We will only process your personal information in a lawful manner that does not infringe on your right to privacy.

3.3 We will not process your personal information excessively.

3.4 We may process your personal information for the following lawful reasons:

• where you consent to the processing;
• where the processing is necessary to carry out actions in order to conclude or perform in terms of a contract with you;
• where the processing complies with an obligation imposed on us by law;
• where the processing protects your legitimate interest;
• where the processing is necessary for us to perform in terms of a public law duty, if we are a public body; or
• where the processing is necessary for pursuing our legitimate interest, or the legitimate interest of a third party to whom we may supply information.

3.5 You must contact us if you have any query, complaint or request regarding your personal information.

4. Collecting your personal information

We collect your personal information:

• directly: when you register, contact us (including through the contact form on our website), or use our Platform and services;
• automatically: through cookies (refer to our Cookie Policy), App usage tracking, logs and analytics tools; and
• from third parties,

to develop, provide and improve our services and Platform, and to communicate with you.

You must inform us if your information changes.

4.1 Personal information we may collect and process

4.2 Information automatically collected when using our Platform

When you interact with our Platform, we automatically collect certain personal information to help us understand usage patterns and improve your experience. This may include:

• Usage information: details such as the pages or content you view, click or share; your navigation behaviour (clickstream data); time spent on the Platform; searches you perform; purchases or orders made; and the specific services within the Platform you engage with.
• Log and device data: information about how you use the Platform, including interactions with third-party links, your IP address, access times and dates, device type, operating system, app version, crash logs, unique device identifiers (such as Apple’s IDFA and IDFV), and content viewed before or after using the Platform.
• Cookies and similar technologies: we may use cookies and related technologies to enhance functionality, track engagement and personalise your experience when accessing our website. Data collected through cookies and tracking tools will be processed as outlined in our Cookie Policy.

4.3 Information we may process from third parties, or that may be processed by third parties

• Third-party services: we may collect and process personal information from sources such as third-party services. If you link, connect or log in to our Platform using a third-party service (e.g. Facebook), you direct the service to send us your profile information, such as your name and email address, as controlled by that service or as authorised by you via your privacy settings at that service. We process this personal information based on the consent you provide when directing the third-party service to send us your profile information.
• Email communications providers: information collected from recipients of our email communications and further processed by us (only applicable when you register and create an advertiser profile to advertise or market on our Platform). We use third-party service providers to manage and distribute our email communications. These providers may collect certain data about how recipients interact with our emails, including:
  • the recipient’s identity (email address, IP address, user ID);
  • when the email is opened (date and time);
  • which links within the email are clicked;
  • whether the email was accessed via a mobile device or a web browser;
  • the type of operating system used; and
  • the specific campaign or communication the interaction relates to.

We receive detailed reports from these service providers containing the above information. We use these insights to understand engagement levels, evaluate which content resonates with our audience, and improve the design and relevance of future communications.

This data is processed based on our legitimate interest in optimising and enhancing the effectiveness of our email campaigns. Should you wish to opt out of the processing of this information, you must de-register as a user of our Platform and delete our App. If you are not a registered user of our Platform, you may opt out of receiving our marketing emails at any time by clicking the unsubscribe link in our marketing emails or by emailing supportadx@addex.co.za.

• Public sources (only applicable to prospective advertisers and marketers on our Platform): we may collect publicly available information, such as your name, contact details, company name and professional role, from public websites and online business directories. We collect this information for legitimate business purposes, including:
  • contacting you in the normal course of our business operations; and
  • marketing our products and services to you where permitted by law and where additional consent is not required.

The legal basis for processing this information is our legitimate interest in maintaining business communications and promoting our services effectively. You may opt out of receiving our marketing emails at any time by clicking the unsubscribe link in our marketing emails or by emailing supportadx@addex.co.za.

4.4 Information you choose to give us

You may choose to provide us with additional personal information about you. This information could include:

• information that you provide as part of our email correspondence with you;
• information that you submit through the contact form on our website, such as your name, email address, enquiry type, business name, phone number (optional) and message; and
• other information that you provide to us on your own initiative in connection with support queries or other interactions that you have with us.

5. Further processing your personal information

Once we process your information for the purposes set out in this Policy, we may further process your information for other reasons. We will only do so if the purpose of the further processing is lawful and compatible with the purpose for which we originally collected the personal information.

5.1 Sharing your information

We do not sell your information, but we may share it with:

• Service providers: for hosting, analytics, payment processing and other services that we have specifically contracted them for.
• Legal authorities or third parties: when required by law.
• Marketers and advertisers: for marketing and advertising purposes, only with your consent. In all other instances, we will anonymise your information before sharing data so that it cannot personally identify you.

5.2 Targeted advertising

We may use your information to show you relevant, interest-based advertisements while you use our Platform or browse other websites and apps. This may involve the use of cookies, clickstream data and similar tracking technologies.

For example, if you’ve searched for or interacted with content related to our services, you may see Addex ads on other websites or platforms you visit. This practice, often referred to as “targeted advertising”, “behavioural advertising” or “cross-context behavioural advertising”, allows us and our advertising partners to better understand your interests and tailor ads accordingly. You must maintain your advertising preferences on the platforms you visit.

We believe this approach enhances your experience by presenting advertisements that are more relevant to you. If you are using a mobile device, you may be able to limit or opt out of targeted ads by adjusting your device settings or resetting your advertising identifiers or preferences.

5.3 Data processors

We may share personal information with service providers to help us run our business and deliver the Platform. These service providers may assist us to fulfil the purposes set out in this Policy and our Platform Terms of Use, including (but not limited to) by:

• processing payments for campaigns and listings;
• hosting software functions which enable the functioning and development of our Platform;
• providing hosting services;
• supporting tools for improving the functionality, availability, resilience and security of the Platform;
• performing data analytics;
• providing performance measurements for ads and campaigns;
• automating SMS, email and ad delivery, for example sending out newsletters;
• delivering messages submitted through the contact form on our website;
• managing our social media and online advertising presence; and
• providing integrated tools which help us deliver customer care services.

Whenever we use a service provider to process personal data on our behalf, we make sure that they are contractually bound to protect your personal information by way of a data processing agreement.

5.4 Third-party geo-location services

We use third-party geo-location services, with whom we share data, to provide our Platform and to help us run our business as described below. These third-party geo-location services may process personal information for their own purposes as controllers.

If you are a user of our mobile App, we may access your geo-location data via our third-party geo-location service provider, Google.

If you are an advertiser or marketer, we access the location data of your business via our third-party geo-location provider, Google, based on our legitimate interest in being able to see where your business is located on a map, in order to:

• provide, improve and develop the Platform; and
• inform interested users.

Google Maps features and content are subject to the then-current versions of the Google Maps/Google Earth Additional Terms of Service and Google’s Privacy Policy. We encourage you to familiarise yourself with these terms before using our services.

5.5 Public bodies

We may disclose your personal information to public bodies, including courts and law enforcement departments, only if and to the extent we are required or permitted to do so by law.

5.6 Public relations (“PR”) and media agencies

We may share your personal information with third parties, such as PR firms, media outlets or promotional agencies, if you have consented to participate in promotional activities or have entered into an agreement with us for such participation.

Depending on the nature of the engagement, these third parties may act either as independent data controllers or as data processors working on our behalf. Where they act as processors, they will handle your personal information strictly in accordance with our instructions and under a formal data processing agreement, as required by applicable data protection laws.

5.7 Business transfers

In the event that we are involved in a bankruptcy, insolvency, merger, acquisition or reorganisation event, your personal information may be transferred or shared as part of that transaction (e.g. for due diligence purposes) with advisors, counterparties, authorities and other relevant third parties as necessary. This Policy will continue to apply to your information after it has been transferred to or shared with any new Addex entity.

6. International data transfers

We may transfer and process your personal information outside of South Africa for purposes such as cloud storage, collaboration with third-party service providers, or to support our broader business operations.

Whenever such transfers occur, we take appropriate steps to ensure your information remains protected. This includes implementing at least one of the following safeguards:

• transferring data only to countries with data protection laws that offer a level of protection comparable to South African legislation; or
• entering into legally binding agreements or standard contractual clauses with third-party service providers to ensure your data is handled lawfully, securely and in line with applicable privacy standards.

If you would like more details about how your personal information is transferred and protected outside of South Africa, you may contact us directly.

7. Storage period

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and applicable law, where we may need to keep the information for statistical or research purposes, and/or where we have a lawful business reason to do so.

The criteria used to determine our retention periods include:

• the length of time we have an ongoing relationship with you and provide our Platform to you, e.g. for as long as you have an account or profile with us or keep using the Platform;
• whether there is a legal obligation to which we are subject, as certain local laws require us to keep records of your transactions for a certain period of time before we can delete them; and/or
• whether retention is advisable in light of our legal position, e.g. litigation or regulatory investigations.

8. Data security

Protecting your personal information and the security of our Platform is a top priority for us. We have implemented a range of appropriate technical, organisational and physical safeguards to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised access or disclosure, whether it is being transmitted, stored or otherwise processed. In addition, we only work with service providers who meet recognised industry standards and apply robust security measures in line with best practices for IT and data protection.

9. Your rights regarding your personal information

As the Responsible Party under South African data protection law, we recognise and respect your rights in relation to your personal information, subject to the conditions and exceptions set out in applicable legislation.

9.1 You have the right to:

• Access: understand whether we hold personal information about you, request a copy or description of the personal information we have about you, and ask for the names or categories of any third parties with whom we have shared your personal information (refer to our PAIA manual).
• Correction: request that we update or correct your personal information.
• Objection: on reasonable grounds, object to the processing of your personal information where the information is being processed for your, our or a third party’s legitimate interest.
• Deletion or destruction: request deletion or destruction of your information unless we are legally required to retain it. Where we depend on access to this personal information, your request may result in us terminating your use of our Platform, including our App.
• Opt-out: opt out of direct marketing communications by visiting “Profile” on our Platform and selecting “Delete Account”, where you are already registered to use our Platform. If you are not registered to use our Platform, you may click the “unsubscribe” link in our marketing emails, reply “Stop” on social media platforms, or contact us at supportadx@addex.co.za.
• Withdraw consent: withdraw consent for us to process and further process your information by visiting “Profile” on our App, or by visiting our website (if you are a registered marketer or advertiser), and selecting “Delete Account”.
• Complain: you may lodge a complaint with us by emailing supportadx@addex.co.za. You may also lodge a complaint with the Information Regulator (South Africa) at POPIAComplaints@inforegulator.org.za or visit inforegulator.org.za. However, we encourage you to contact us first so that we can address your concerns directly and resolve the matter as efficiently as possible.
• Legal action: take legal action to protect your privacy rights, or request that the Information Regulator (South Africa) take such action, if the matter falls within the regulator’s jurisdiction.

To exercise any of these rights (other than the right to opt out or withdraw your consent), contact us at supportadx@addex.co.za. We will respond to your request within a reasonable time and provide you with all relevant forms that you may need to complete. We will inform you of any fees that may apply to your request. Where your information was provided via our App, you may be able to update your information by visiting “Profile”. Please note that some data may be exempt from these rights under applicable data protection or other legal regulations.

To help us verify your identity and safeguard your information, we may request specific details from you before responding to any rights-based request. This ensures that personal data is not disclosed to anyone without proper authority. We may also follow up to clarify your request and expedite our response.

You may also contact us at supportadx@addex.co.za if you have any queries regarding your personal information.

9.2 Your preferences and opt-outs

• Addex is a marketing and advertising Platform.
• When you use our services via our App, we will display our full directory of, and content from, marketers and advertisers at all times. You, however, remain in control of your notification preferences.
• You can manage your notification preferences in the App by selecting or de-selecting the categories you are interested in (tap the heart icon on a category). We will only send you advertising and marketing notifications via our App for categories you specifically select.
• This does not affect any communications and notifications we may send to you as required by law, in terms of our contract with you, or for operational or safety reasons.
• To opt out of in-App marketing or advertising from a specific brand, marketer or advertiser, you must visit “Profile” and select “Delete Account”, and you must also delete the App from your device.
• If you are a prospective marketer or advertiser and we market our Platform, products and services to you via email, SMS or social media platforms, you may unsubscribe from these communications and newsletters using the “unsubscribe” link or by replying “Stop”.
• Should you wish to withdraw your consent for us to process your personal information, you must visit “Profile” and select “Delete Account”, and you must also delete the App from your device.

10. Children’s privacy

Our Platform is intended for users aged 18 and older, and we do not knowingly collect personal information from anyone under the age of 18.

If we become aware that we have inadvertently collected personal information (or any protected data under applicable law) from a child under 18, we will take reasonable steps to delete it from our systems without delay.

If you believe that we may have collected information from or about a child under the age of 18, please contact us immediately using the details in the Contact information section below.

11. Cession

We may cede, assign or delegate our rights in terms of this Policy without your consent, which may result in your personal information being transferred to another party. We will notify you should this occur.

12. Law

This Policy is governed by, and must be interpreted in accordance with, the laws of South Africa.

Our Platform is intended for use by South African citizens or residents only. If you are a citizen or resident of a country outside of South Africa, please note that we process your personal information in accordance with South African data protection laws, as we are a South African-based entity. If foreign data privacy laws apply to your use of our services, we encourage you to contact us directly so that we can assist you further.

13. Changes to this Policy

We may update this Privacy Policy from time to time by publishing the updated Policy on our website and App, and by notifying you on our Platform. If you do not agree with the updated Policy, you may delete your account by visiting “Profile” and selecting “Delete Account”, and you must also delete the App from your device.

14. Contact information

Responsible Party

ADX Digital (Pty) Ltd

Registration number

2022/659982/07

Registered address

42a 4th Avenue, Illovo, Sandton, Johannesburg, 2196

Complaints, queries and support

supportadx@addex.co.za

Website

www.addex.co.za

By using our Platform, you agree to the terms outlined in this Privacy Policy.

This Privacy Policy must be read with the Addex Platform Terms of Use and any other policy applicable to our Platform (as published by us).