Privacy Policy

This Privacy Policy explains how Wakamoso Africa (Pty) Ltd (‘Wakamoso’, ‘we’, ‘us’, ‘our’) collects, uses, stores, shares and protects your personal information. It applies to everyone who creates a Wakamoso account or participates in a questionnaire fielded on the Wakamoso Platform — whether through WhatsApp or the Wakamoso mobile application.

Wakamoso processes personal information in compliance with the Protection of Personal Information Act, No. 4 of 2013 (POPIA). Wakamoso is registered with the South African Information Regulator under Registration Number 2026-018959 (registered 25 May 2026). The Information Officer accountable for this Policy is Mélani Prinsloo (Chief Executive Officer). Day-to-day operational responsibility sits with the Deputy Information Officer, Michael Matthews (Chief Information Officer). You can reach the Information Officer at info@wakamoso.africa.

This Policy is the v2.0 rewrite of the Wakamoso Privacy Policy. It supersedes Privacy Policy v1.1 (October 2023). The earlier version described an earlier Wakamoso (a ‘CV, Will and proof-of-residence data commons’) that no longer reflects the platform’s current operations as a community-research and data utility.

1. What Wakamoso does

Wakamoso operates a multi-tenant research platform. We collect community-generated evidence through structured questionnaires fielded via WhatsApp or our mobile application. We work with six categories of subscribers (‘Tenants’) — businesses, loyalty programmes, research agencies, academic institutions, government and municipalities, and development organisations and NGOs.

The data we collect from you may be used to:

• Build your profile on the Wakamoso platform and provide services that depend on that profile.
• Field community capability baselines and other research questionnaires, including the C3B (Community Capability Baseline) instrument, the Simmering Pot diagnostic, the SDG Alignment Rubric, and any other questionnaire that has been approved by the Wakamoso Ethics Review Office.
• Generate aggregate evidence about communities at whatever geographic scale is appropriate for the question — from individual streets through sub-places, wards, suburbs, municipalities, districts, provinces, or any custom polygon, with strict re-identification controls (see Section 5 of this Policy).
• Connect you to opportunities, services, or rewards that depend on your geographic, demographic, or skill profile, where you have opted in to those connections.
• Provide anonymised and aggregated insights to Wakamoso Tenants under terms set out in the Wakamoso Subscriber Agreement.
• Communicate with you about platform updates, your account, and any questionnaire you have agreed to participate in.

2. What personal information we collect

The personal information Wakamoso collects depends on which questionnaires you participate in. The categories below describe the types of information we may hold.

2.1 Identification and contact

• Your full name, mobile number, email address.
• Your South African identity number where you have provided it for verification purposes.
• Your residential location at the level you choose to provide — a pin you drop on a map, your suburb or town, or another geographic identifier you give us.
• Geolocation captured by the mobile application where you have granted location permission to the app.

2.2 Household and living conditions

• Dwelling type, household size, services available at your dwelling (water, electricity, sanitation, refuse removal).
• Household income band, expenditure pattern, financial stress indicators.
• Employment status, skills, qualifications, work experience (where you have provided them).

2.3 Health, wellbeing and safety

Some questionnaires ask about your health, your household’s food security, your wellbeing, your safety in your community, your experience of crime, your experience of household violence, your access to healthcare, and similar matters. These are sensitive topics and they are classified by POPIA as ‘special personal information’ (Section 26). We collect this information only with your express agreement, and only when the Ethics Review Office has approved the questionnaire (see Section 7 of this Policy).

2.4 Civic, social and cultural information

Your participation in community life, your social and institutional trust, your sense of agency, your civic engagement, your cultural and linguistic practices.

2.5 Verifier and referee information

When you ask Wakamoso to verify information you have provided — for example, your work experience or your skills — we ask you to identify a verifier or referee. You warrant that you have the referee’s permission to share their contact information with us, and that the referee is aware their details have been shared.

2.6 Technical information

When you use the Wakamoso mobile application or the WhatsApp channel, we automatically collect technical information including device type, operating system, network type, IP address, and platform usage logs. This information helps us deliver the service, prevent abuse, and improve the platform.

3. How you give us permission to process your information

3.1 The Wakamoso POPIA Opt-In

Before Wakamoso processes your personal information for any purpose, you are asked once to read and accept the Wakamoso POPIA Opt-In. This is a single, one-time opt-in. You can read it before you decide. If you accept, you join the platform and we may process your information for the purposes described in the POPIA Opt-In. If you do not accept, you do not join.

The current Opt-In is the Wakamoso POPIA Opt-In v2.0, published at https://wakamoso.africa/popia-opt-in. It covers: your platform profile and account; participation in research questionnaires fielded by Wakamoso or by Wakamoso’s Tenants; ward-level publication of anonymised aggregate evidence; collection of special-category information with your express consent; marketing communications (which you can refuse separately); verifier and referee details; minors’ participation via a competent person; and your right to withdraw consent and delete your account at any time.

3.2 Per-survey opt-in

Where a questionnaire is sent to you via WhatsApp, we send a WhatsApp Template message that introduces the questionnaire, names the Tenant, indicates any reward offered, and asks you to confirm that you wish to proceed. If you do not respond, or you respond no, the questionnaire does not reach you. Each questionnaire is a separate, explicit opt-in.

3.3 The Wakamoso mobile application

Where a questionnaire is sent to you via the mobile application, we send a push notification. You decide whether to tap into the questionnaire. You can disable Wakamoso notifications at any time in your device’s settings or in the app’s settings; this stops new questionnaire invitations from reaching you, although it does not delete the information we already hold.

3.4 Withdrawing your consent

You can withdraw your consent to the Wakamoso POPIA Opt-In at any time by deleting your Wakamoso account through the mobile application. Withdrawal is forward-looking — it does not affect the lawfulness of processing that took place before withdrawal. After you withdraw, we delete your personal information except where we are required by law to retain it (for example, fraud-prevention records). Anonymised and de-identified data that has already been incorporated into aggregate ward-level evidence is not affected by withdrawal because it can no longer be linked to you.

4. Special personal information

Some questionnaires touch on health, religion, ethnic origin, criminal behaviour, sex life, trade union membership, political persuasion, or biometric information. POPIA Section 26 classifies these as ‘special personal information’ and Section 27 requires a specific authorisation to process them.

Where Wakamoso collects special personal information, we do so under one or more of the following authorisations:

• Your explicit consent at the time the question is asked (Section 27(1)(a)).
• The research exemption in Section 32 of POPIA, where the processing is for historical, statistical or research purposes, and we have applied appropriate safeguards including the Ethics Review Office’s approval, aggregation, de-identification, and the publication floor in Section 5 of this Policy.
• Prior authorisation from the Information Regulator under Section 57, where required.

Special-category questions in any Wakamoso-fielded questionnaire include an option to decline (for example, ‘I would prefer not to say’). Choosing the decline option does not affect the reward you receive for completing the rest of the questionnaire.

5. How we publish aggregate evidence — the publication floor

Wakamoso publishes aggregate evidence at geographic scales appropriate to each research question — from streets and sub-places up through wards, suburbs, municipalities, districts, provinces, and any custom polygon agreed with the relevant Tenant or research partner. To protect you from being identified through small-area or small-cohort outputs, we apply a minimum cell-size floor:

• Standard cells: we do not publish any cell with fewer than five (5) respondents (k≥5 anonymity).
• Sensitive cells: where a cell intersects health, wellbeing, gender-based violence, religion, criminal-history disclosure, or any of the six C3B Tier One survival flags, we do not publish any cell with fewer than ten (10) respondents (k≥10).
• Aggregation: where a cell fails either floor, we either suppress it or aggregate it up to the next geographic or demographic unit.

These rules are documented in the Wakamoso Data Publication Policy v1.0 and apply to every dashboard, report, public post, conference presentation, and API output.

6. Who we share your information with

Wakamoso shares your information only as follows:

• With Tenants who have an approved questionnaire and a signed Subscriber Agreement. Tenants receive only the responses to their own questionnaire, and only at the aggregation level set by the Ethics Review Office’s approval.
• With operators acting on our behalf — for example FuseIT (support partner), Amazon Web Services (hosting, Cape Town region), Meta (WhatsApp Business API). Each operator is bound by a Data Processing Agreement that requires them to comply with POPIA and follow our security and confidentiality standards.
• Where the law requires disclosure — for example in response to a court order, a regulator’s lawful request, or a criminal investigation.
• With verifiers and referees you have named, but only for the purpose of confirming the information you provided.

Wakamoso does not sell your personal information. Wakamoso does not give your information to any third party for that party’s independent commercial use.

7. The Wakamoso Ethics Review Office

Every questionnaire fielded on the Wakamoso Platform — whether by Wakamoso itself or by a Tenant — must be approved by the Wakamoso Ethics Review Office before it reaches you. The Office assesses each questionnaire against the Wakamoso Ethics Framework v1.0, which includes POPIA checks, methodological checks, respondent-welfare checks, and tenant-type-specific checks.

Ethics review is human-led with AI assistance. Our Ethics Assessor AI agent produces the first-pass assessment; our Deputy Information Officer reviews it, modifies or overrides it where appropriate, and signs the decision. An independent Advisory Panel of external members audits a sample of decisions twice a year. We disclose AI assistance on every assessment record.

8. Where your information is stored and processed

Wakamoso hosts its data in the Amazon Web Services Cape Town region. By default, your personal information does not leave South Africa. Where a cross-border transfer takes place (for example, if a Tenant is incorporated outside South Africa and we share their questionnaire responses with them), we do so only under one of the Section 72 grounds — adequacy decision, binding corporate rules, contractual safeguards, or your specific consent. Cross-border transfers, where they occur, are described in the relevant questionnaire’s privacy notice.

9. How long we keep your information

We keep your personal information for as long as you have a Wakamoso account, plus five (5) years from the date you last updated your data, after which the account is automatically deleted unless you have re-engaged. We keep individual questionnaire responses for the same period. After deletion, anonymised and aggregated outputs that have been incorporated into ward-level evidence are retained indefinitely because they can no longer be linked to you.

Where the law requires us to keep specific records for longer (for example, fraud-prevention or audit-trail records), we keep those records for the period the law requires.

10. How we keep your information secure

We protect your information using industry-standard measures, including encryption in transit (TLS 1.2 or higher) and at rest (AES-256), role-based access control with multi-factor authentication, quarterly access reviews, security training for all personnel, an Incident Response Plan, and audit logging. Full details are in the Wakamoso Information Security Policy v1.1. We host within AWS Cape Town and apply NIST 800-88 secure disposal.

11. Your rights under POPIA

As a data subject you have the following rights. You can exercise any of these rights at any time.

• Right to access — confirm whether we hold your information, and receive a copy of it.
• Right to rectification — ask us to correct any inaccurate or incomplete information.
• Right to deletion — ask us to delete your information, subject to legal retention obligations.
• Right to object — object to specific processing activities.
• Right to withdraw consent — withdraw your Wakamoso POPIA Opt-In consent at any time.
• Right to lodge a complaint — with the Information Regulator at https://inforegulator.org.za.

You can exercise these rights through the Wakamoso mobile application, or — if you do not have access to the app — by following the Wakamoso Subject Access Request Procedure v1.0. The SAR Procedure is published alongside this Policy and is available on request.

12. Children

Wakamoso does not knowingly collect personal information from anyone under 16 without the consent of a competent person (a parent or legal guardian). Where we discover that we have collected information from a child without the required consent, we delete it as soon as we become aware.

13. Marketing communications

Wakamoso may send you communications about platform updates, opportunities, and services that may be relevant to you. You can opt out of marketing communications at any time — through the app’s settings, via the unsubscribe link in any email, or by replying STOP to a WhatsApp marketing message. Opting out of marketing does not affect service and questionnaire messages that you have consented to receive.

14. Cookies and similar technologies

The wakamoso.africa website uses minimal cookies for site analytics and session continuity. We do not use cookies to track you across other websites. The Wakamoso mobile application uses standard mobile telemetry to maintain your session, prevent abuse, and improve the platform.

15. Changes to this Policy

Wakamoso may amend this Policy. When we do, we will publish the new version at https://wakamoso.africa/privacy-policy/, update the version number and effective date, and notify you of material changes through the Wakamoso mobile application or via WhatsApp. Where a change materially alters how we process your information, we will ask you to re-confirm your consent before the change takes effect for your account.

16. Contact us

If you have any question about this Policy, your information, or how we process it, please contact:

• Information Officer: Mélani Prinsloo, Chief Executive Officer
• Deputy Information Officer: Michael Matthews, Chief Information Officer
• Email: info@wakamoso.africa
• Postal address: 14 King Street, Irene, Centurion 0062, South Africa
• IR Registration Number: 2026-018959

17. Governing law

This Policy is governed by the laws of the Republic of South Africa, including the Protection of Personal Information Act, No. 4 of 2013.