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Refreshi Exchange is a verified business-to-business (B2B) marketplace operated by Refreshi (Pty) Ltd ("Refreshi", "we", "us", or "our"), a company incorporated under the laws of the Republic of South Africa. The Platform ("Refreshi Exchange") facilitates the sale and purchase of surplus, short-dated, discontinued, and overproduced Fast-Moving Consumer Goods (FMCG) stock between verified South African businesses. This Privacy Policy ("Policy") explains how we collect, use, store, protect, and share personal information from verified sellers, verified buyers, applicants, and any other individuals who interact with the Platform. This Policy complies with the Protection of Personal Information Act, No. 4 of 2013 ("POPIA"), as amended. By registering, applying, or using the Platform in any way, you confirm that you have read and understood this Policy and consent to the collection and use of your information as described herein.
The entity responsible for collecting and processing your personal information is: Refreshi (Pty) Ltd GR06 Twickenham, Brookside Office Park 11 Imam Haron Rd, Claremont Cape Town, 7708, South Africa Company registration number: 2022/860860/07 Platform contact: exchange@refreshi.co.za This Policy must be read together with the General Terms and Conditions, the Seller Terms and Conditions, and the Buyer Terms and Conditions, all of which are available on the Platform.
In accordance with POPIA, Refreshi (Pty) Ltd has appointed an Information Officer responsible for ensuring compliance with this Policy and applicable data protection legislation. Information Officer: Greg Whitfield Contact: exchange@refreshi.co.za You may direct any requests relating to your personal information, including access, correction, or deletion requests, to the Information Officer at the contact details above.
"Platform" refers to the Refreshi Exchange web application accessible at exchange.refreshi.co.za and any related services. "Seller" refers to a verified business registered on the Platform to list surplus FMCG stock for sale. "Buyer" refers to a verified business registered on the Platform to purchase surplus FMCG stock. "User" refers to any individual accessing or using the Platform, including sellers, buyers, company members, and applicants. "Verification Documents" refers to documents submitted during the application and verification process, including company registration documents, identity documents, bank confirmation letters, and related materials. "CAD" or "Collection Authorisation Document" refers to the document and unique authentication code generated upon payment confirmation, used to authorise physical stock collection. "POPIA" refers to the Protection of Personal Information Act, No. 4 of 2013, as amended.
Registration and Application Information: When you apply to join the Platform, we collect your full name and contact details, company name and registration number, VAT number, business address, banking details, identity documents, company registration documents, bank confirmation letters, proof of address, and company logo. Transaction and Order Information: We collect order details, proof of payment documents, EFT payment references, Collection Authorisation Documents and authentication codes, payout records, and warehouse collection details. Listing Information: We collect product details, descriptions, images, pricing, stock condition, expiry dates, batch numbers, stock locations (collection addresses), and logistics information. Platform Usage Information: We collect login activity, session data, access timestamps, and actions performed on the Platform. Communications: We collect in-platform messages, WhatsApp notifications, email correspondence, and support queries. Google Authentication: If you log in using Google Sign-In, we receive your Google account email address and name. We use this solely to create and manage your Platform account and do not access any other Google account data.
All sensitive documents uploaded to the Platform — including verification documents, proofs of payment, and CAD documents — are stored in private, access-controlled cloud storage. Documents are not publicly accessible. Access is restricted to authorised users only based on their role on the Platform. Document access is granted through time-limited secure mechanisms that expire after a short window, ensuring documents cannot be accessed by unauthorised parties. We have implemented role-based access controls, private document storage, secure authentication, single-use CAD authentication codes, and encrypted HTTPS connections throughout the Platform. We retain your personal information for as long as your account is active or as required by applicable South African law. When information is no longer required, we take reasonable steps to securely delete or anonymise it.
We use the personal information we collect to: • Verify your identity and business credentials before granting access to the Platform; • Create and manage your account and company profile; • Facilitate transactions between buyers and sellers, including order processing, payment verification, and stock collection authorisation; • Send transaction-related notifications via WhatsApp and email; • Process seller payouts; • Resolve disputes and investigate complaints; • Comply with applicable South African laws and regulations; • Maintain the security and integrity of the Platform; • Improve and develop the Platform. We do not use your personal information for targeted advertising, behavioural profiling, or any purpose not disclosed in this Policy.
Between Buyers and Sellers: Seller warehouse contact details and collection address are only disclosed to a buyer once payment is confirmed and the order reaches "Ready for Collection" status. For delivery orders, the buyer's delivery address and delivery contact name and phone number are disclosed to the seller once payment is confirmed, solely to enable delivery of the order. Beyond what is described in this clause, buyer and seller personal contact details are not disclosed to the other party. Service Providers: We share personal information with trusted third-party service providers including cloud infrastructure providers, WhatsApp Business API (Meta) for notifications, Google for authentication and address verification, and email service providers. All service providers are bound by data processing agreements. Legal Disclosure: We may disclose your personal information to courts, law enforcement, or regulatory bodies where required by law. No Sale of Personal Information: We do not sell, rent, or trade your personal information to any third party for commercial or marketing purposes.
Some third-party service providers we use may process or store data outside of South Africa. Where this occurs, we take appropriate steps to ensure your personal information is afforded a comparable level of protection, including through contractual safeguards consistent with POPIA requirements.
As a data subject under POPIA, you have the following rights: • Right of access: Request access to the personal information we hold about you; • Right to rectification: Request correction of inaccurate or incomplete personal information; • Right to erasure: Request deletion of your personal information, subject to legal retention obligations; • Right to restriction: Request that we restrict processing of your personal information; • Right to object: Object to processing where we rely on legitimate interests; • Right to withdraw consent: Withdraw consent at any time without affecting the lawfulness of prior processing. To exercise any of these rights, contact our Information Officer at exchange@refreshi.co.za. We will respond within one month. You also have the right to lodge a complaint with the Information Regulator of South Africa: Website: www.inforegulator.org.za Email: inforeg@justice.gov.za
The Platform is a B2B marketplace intended exclusively for registered business entities and individuals who are at least 18 years of age. We do not knowingly collect personal information from individuals under the age of 18.
We may update this Policy from time to time. Material changes will be notified to registered users via the Platform or by email. Your continued use of the Platform after any changes constitutes acceptance of the updated Policy.
For any questions or requests relating to this Privacy Policy, please contact: Refreshi (Pty) Ltd — Refreshi Exchange GR06 Twickenham, Brookside Office Park 11 Imam Haron Rd, Claremont, Cape Town, 7708 South Africa Email: exchange@refreshi.co.za Information Officer: Greg Whitfield Platform: exchange.refreshi.co.za