PRIVACY POLICY

Effective Date: 2026/04/07
Responsible Party: Pagora

1. Introduction

This Privacy Policy explains how we collect, use, disclose, and protect your personal information in accordance with the Protection of Personal Information Act (POPIA).

2. Personal Information We Collect

We may collect the following categories of personal information:

• Identity and contact data: name, email address, phone number, physical address (if provided).
• Account data: username, password (hashed), account preferences.
• Usage data: IP address, browser type, pages visited, time stamps, referring URLs.
• Content data: the websites you generate, text you input, images you upload, and AI prompts you submit.
• Payment data: billing information is processed by our third‑party payment processor; we do not store full card details.

3. Lawful Basis for Processing (POPIA Section 11)

We process your personal information because:

• You have given consent (e.g., when you sign up and agree to this policy);
• Processing is necessary for the performance of a contract (to provide the Service);
• Processing is necessary to comply with a legal obligation;
• Processing is necessary for our legitimate interests (e.g., improving security, preventing fraud), provided such interests are not overridden by your rights.

4. How We Use Your Information

We use your personal information to:

• Create and manage your account;
• Provide, maintain, and improve the Service;
• Generate and host your websites;
• Respond to your inquiries and support requests;
• Send service announcements, billing notices, and security alerts;
• Comply with legal obligations and enforce our Terms.

5. Disclosure of Personal Information

We may share your personal information with:

• Service providers (e.g., cloud hosting, AI model providers, email delivery services) under contracts that require them to protect your data.
• Law enforcement or regulators when required by law or to protect our rights.
• Successors in the event of a merger, acquisition, or insolvency.

We will not sell your personal information to third parties.

6. International Transfers

Some of our service providers may operate outside South Africa (e.g., in the EU or US). We will ensure that any cross‑border transfer complies with POPIA by implementing appropriate safeguards, such as binding corporate rules or standard contractual clauses.

7. Data Security

We implement reasonable technical and organisational measures to protect your personal information against loss, unauthorised access, disclosure, alteration, or destruction. However, no internet transmission is completely secure.

8. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Service. After account termination, we may retain certain data for legal, tax, or audit purposes for up to 5 years, after which it will be securely deleted.

9. Your Rights Under POPIA

You have the right to:

• Request access to your personal information held by us.
• Request correction of inaccurate or incomplete data.
• Request deletion of your personal information (subject to legal retention obligations).
• Object to processing based on legitimate interests.
• Withdraw consent at any time (without affecting the lawfulness of processing based on consent before its withdrawal).
• Lodge a complaint with the Information Regulator (South Africa).

To exercise these rights, email mishackmay@gmail.com with “POPIA Request” in the subject line. We will respond within a reasonable time (usually 30 days).

10. Cookies and Tracking

We use cookies and similar technologies to enhance your experience, analyse usage, and for security. You may disable cookies in your browser, but some features may not function properly.

11. Children’s Privacy

Our Service is not directed to individuals under 18. We do not knowingly collect personal information from minors. If you become aware that a child has provided us with personal information, please contact us.

12. Changes to This Policy

We may update this Privacy Policy. Material changes will be notified via email or a prominent notice on the Platform.

13. Contact and Information Officer

For privacy‑related queries or to report a data breach:
Email: mishackmay@gmail.com
(You may designate an Information Officer as required by POPIA.)