Operator agreement

1Roles and scope

This agreement is between the organiser that holds a Promavue account (“you”) and I-Sixty Group, trading as Promavue (“we”). It covers the personal information of people who take part in your promotions: entrants, raffle buyers and prize winners. It also covers the email addresses of the report recipients you choose.

You are the responsible party: you decide why and how this information is collected. We are your operator: we process it for you. Your own account details are covered by our privacy notice instead, because for those we are the responsible party.

2We act only on your instructions

Your instructions are the way you set up and use Promavue: the experiences, form fields, consent wording, limits, prizes, report recipients and other settings you choose, and anything else you ask us to do in writing. We process participant information only to:

• show your promotion pages and record entries, raffle orders, spins and draws;
• apply your entry limits, prize stock and draw rules;
• show results to your team, according to the roles you assign;
• create reports and email them to the recipients you approve;
• provide support, keep the service secure, and meet our legal obligations.

We do not use participant information for our own purposes. We do not market to your participants, and we do not sell their information.

3Confidentiality

Participant information is treated as confidential. Within Promavue, only platform administrators can see it, and only when they need to provide support or run the service.

4Security measures

The measures in place, as required by section 19 of POPIA, are:

• Access to participant data is limited by organisation and role. Removing someone's access takes effect on their next request.
• Everyone with an organiser role that can change anything, and every platform administrator, must use an authenticator app to sign in.
• Passwords, participant entry credentials, setup links and one-time codes are stored only as hashes. A keyed hash of each mobile number supports entry limits.
• The application, database and file storage run on I-Sixty Group's own infrastructure in South Africa. Reports and uploaded files are stored privately and served only after an access check.
• Traffic uses HTTPS, and the connection between the application and its database is encrypted.
• Workspace actions are recorded in an audit history.
• The database and stored files are backed up nightly on a rolling cycle of about 30 days.

5Service providers

You authorise us to use the following service providers to run the service. Each receives only what is described here:

SMS is not currently used. Before any new service provider receives participant information, including an SMS provider, we will update this list and email organisation owners.

SendGrid is in the United States, so emailed reports leave South Africa. We rely on SendGrid’s contractual data-protection commitments under section 72(1)(a) of POPIA. If you do not want participant information sent by email, download reports from your workspace instead of scheduling email delivery.

6Security incidents

If we have reasonable grounds to believe that participant information has been accessed or acquired by an unauthorised person, we will notify you immediately, as section 21(2) of POPIA requires. We will give you the information we have so that you can notify the Information Regulator and the people affected, and we will help you do so.

7Requests from participants

If a participant asks us to access, correct or delete their information, we will pass the request to you and help you respond. You can export your results from the workspace at any time. Promavue does not yet have self-service tools for correcting or deleting individual participant records. Until it does, our team carries out those changes manually when you instruct us in writing.

8Retention, return and deletion

Promavue does not currently delete participant information automatically, including when a campaign closes or a paid plan ends. The retention instructions you record in a campaign’s settings are kept with the campaign, but they are not yet applied automatically.

On your written instruction, including when this agreement ends, we will return participant information to you as an export and then delete it from the live service. Deleted information can remain in backups until they are replaced, about 30 days later. We may keep records that the law requires us to keep. We cannot recall reports that were already emailed or downloaded. We will confirm in writing what was deleted and what remains.

9Your responsibilities

• Have a lawful basis for collecting each piece of participant information, and collect only what your promotion needs.
• Write the privacy notice, competition terms and marketing-consent wording shown to participants. We show them as you write them.
• Avoid collecting special personal information, such as health, religious or biometric information, and children's information, unless the law allows it and you have the required consent.
• Honour participants' requests and opt-outs, and keep your instructions to us lawful.

10Information and liability

We will give you the information you reasonably need to show that this agreement is being followed. Liability under this agreement is governed by our terms of service. Write to support@isixty.co.za about anything in this agreement.