Privacy notice

1. Who we are

RoboInsure Intermediary (Pty) Ltd ("RoboInsure", "we") is a short-term insurance intermediary (broker). We are the responsible party for the personal information described here. Our address: TODO: confirm physical / head office address.

Information Officer: [DRAFT: attorney to confirm the Information Officer's name and registration with the Information Regulator.] You can reach the Information Officer at info@roboinsure.co.za.

2. What we collect

• When you contact us: your name, email address, mobile number, the cover you are interested in, your message, and any business names you give.
• When we prepare a quote: your ID or passport number, date of birth, gender, marital status, address, contact preferences, details of what you want to insure (vehicles, buildings, contents, business details), your claims and insurance history, and the answers to our pre-qualification questions.
• About other people you tell us about: regular drivers, household members, business directors and members. Please let them know you are sharing their details with us.
• Special personal information: some pre-qualification questions ask about fraud, criminal and driving offences, and some claim forms ask about injuries, alcohol or drug tests and physical conditions. We ask for your explicit consent before we record these answers, and only staff who need them can see them.
• Children: if you name a person under 18 (for example a young driver), we record only what the insurer needs, with your consent as their parent or guardian. [DRAFT: attorney to confirm the basis.]
• When you use the customer app: your sign-in details (through Microsoft), quotes you accept (with your name, the time, your IP address and browser as the electronic signature), claims, photos and documents you upload, and, if you allow it, a notification address for your device.
• Automatically: technical logs (for example your IP address and the pages requested) to keep the service secure and working.

Supplying information is voluntary, but without it we cannot get you quotes, place cover or handle claims.

3. Why we use it, and on what basis

• To answer your enquiry and get you quotes from insurers (steps you asked for before a contract; your consent).
• To place and administer your cover, renewals, changes, cancellations and claims (performing our contract with you).
• To meet our legal duties as a financial services provider, for example keeping advice records (legal obligation).
• To prevent fraud and keep our systems secure (our legitimate interest, and the insurers').
• To send you news and offers, only if you said yes (your consent; you can withdraw it at any time).

[DRAFT: attorney to confirm the lawful ground for each purpose, and for the special personal information questions.]

4. Who receives your information

• Insurers we approach for quotes, cover and claims (and, through them, industry databases they use to prevent fraud).
• Microsoft: our systems run on Microsoft Azure; Microsoft Entra handles sign-in; Microsoft 365 sends our emails.
• Cloudflare: its Turnstile check on our forms helps stop automated abuse; it sees your IP address and browser signals.
• Push notification services (Google, Apple or Mozilla, depending on your device) deliver app notifications if you turn them on.
• Microsoft Azure DevOps: our development tools, used to build and test the platform.
• Anyone we are required to give it to by law.

We never sell your personal information.

5. Information that leaves South Africa

Our database, files and logs are stored in South Africa (Microsoft Azure, Johannesburg). Some of the services above may process information outside South Africa: Cloudflare's global network, the push notification services, Microsoft 365 email, Microsoft Entra sign-in and Azure DevOps. We rely on these providers' data protection terms to protect it to a standard similar to POPIA. [DRAFT: attorney to confirm the ground under POPIA section 72 for each.]

6. How long we keep it

We keep information only as long as we need it for the purposes above or as the law requires: for example, records of the advice and services we provide are kept for 5 years after the service ends (FAIS). Enquiries that never become cover are kept for a shorter period. [DRAFT: attorney to set the retention period for each kind of record.]

7. How we protect it

Your information is encrypted in transit and at rest, access is limited to staff who need it, and sensitive details are partly hidden on screen. If we ever learn of a breach that affects you, we will tell you and the Information Regulator as the law requires.

8. Your rights

• Ask whether we hold information about you, and for a copy of it (access).
• Ask us to correct or update it, or to delete it when we no longer need it.
• Object to us using it on the grounds of legitimate interest, and to direct marketing at any time.
• Withdraw a consent you gave (this doesn't affect what was done before).
• Ask for a person to review a decision that was made automatically (see below).
• Complain to the Information Regulator (details below).

To use these rights, contact us (section 10). [DRAFT: attorney to confirm the request procedure and response times, in line with our PAIA manual.]

9. Automatic decisions

Some applications end automatically: when an answer to a pre-qualification question means our insurers cannot cover it, or when you do not agree to the information consent we need to get quotes. We tell you when this happens, and you can ask for one of our team to review it and talk to you. [DRAFT: attorney to confirm.]

10. Contact us, and complaints

For questions or requests about your personal information, contact our Information Officer at info@roboinsure.co.za or through our contact page.

If you are not happy with how we handled your information, you may complain to the Information Regulator (South Africa): inforegulator.org.za, POPIAComplaints@inforegulator.org.za, 010 023 5200 (toll-free 0800 017 160), Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191.

11. Changes to this notice

When we change this notice we give it a new version and date (shown at the top).