Privacy Policy
Your privacy matters to us. Here's how we handle your information.
1. Introduction
Circle Connect (Pty) Ltd ("Circle Connect", "we", "us", or "our") is committed to protecting your personal information and respecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal information in accordance with the Protection of Personal Information Act, 2013 (POPIA) and other applicable South African legislation.
2. Information We Collect
We may collect the following categories of personal information:
- Identity Information: Full name, ID number, date of birth.
- Contact Information: Phone number, email address, physical address.
- Financial Information: Banking details, payment history, billing address.
- Technical Information: IP addresses, MAC addresses, device information, usage data, and connection logs.
- Location Information: Installation address and GPS coordinates for coverage verification and service delivery.
- Communication Records: Correspondence via email, WhatsApp, phone calls, and website forms.
3. How We Use Your Information
We use your personal information for the following purposes:
- To provide, maintain, and improve our internet and related services.
- To process payments and manage your account.
- To communicate with you about your service, including outages, upgrades, and promotions.
- To verify coverage availability at your location.
- To comply with legal and regulatory obligations, including RICA requirements for SIM-based services.
- To detect, prevent, and address fraud, abuse, and security threats.
- To improve our network performance and customer experience.
4. Legal Basis for Processing
We process your personal information based on one or more of the following grounds as permitted under POPIA:
- Consent: Where you have given explicit consent.
- Contract: Where processing is necessary to fulfil our service agreement with you.
- Legal Obligation: Where we are required by law to process your data (e.g., RICA, tax regulations).
- Legitimate Interest: Where processing is in our legitimate business interests, such as network security and fraud prevention.
5. Data Sharing & Third Parties
We do not sell your personal information. We may share your data with trusted third parties only where necessary:
- Service Providers: Payment processors, SMS/WhatsApp notification providers, and network infrastructure partners.
- Legal Authorities: When required by law enforcement, court orders, or regulatory bodies.
- Debt Collection: In cases of outstanding payments, your information may be shared with authorised collection agencies.
All third parties are contractually required to protect your information and may only use it for the specified purpose.
6. Data Security
We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include:
- Encrypted storage and transmission of sensitive data.
- Access controls and authentication for internal systems.
- Regular security reviews and monitoring.
- Staff training on data protection best practices.
7. Data Retention
We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Specifically:
- Account information is retained for the duration of your service and up to 5 years after termination for legal and accounting purposes.
- Connection logs may be retained for up to 3 years in compliance with applicable regulations.
- Hotspot session data is retained for 12 months.
8. Your Rights
Under POPIA, you have the following rights regarding your personal information:
- Access: Request a copy of the personal information we hold about you.
- Correction: Request that inaccurate or outdated information be corrected.
- Deletion: Request the deletion of your personal information, subject to legal retention requirements.
- Objection: Object to the processing of your information for direct marketing purposes.
- Complaint: Lodge a complaint with the Information Regulator of South Africa.
To exercise any of these rights, please contact us at info@circleconnect.co.za.
9. Cookies & Website Tracking
Our website may use cookies and similar technologies to enhance your browsing experience, analyse website traffic, and understand visitor behaviour. You can control cookie settings through your browser preferences.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated policy will be published on this page with a revised date. We encourage you to review this page periodically.
Last updated: February 2026