1. Information We Collect

1.1 Identity & Verification Information

To maintain platform integrity and comply with applicable law, Privé collects identity information for verification purposes. This may include:

• Full legal name
• Date of birth
• Government-issued identification documents (e.g., South African ID, passport, driver’s licence)
• Selfies or biometric photographs used to confirm identity against your identification document
• Nationality and country of residence
• Results from third-party identity verification and compliance checks

Verification is mandatory for: Gentlemen before booking or confirming any in-person date; and Muses before withdrawing any funds from the Platform.

1.2 Financial & Banking Information

To facilitate payments, reservations, tips, and withdrawals, Privé collects financial information, which may include:

• Bank account details (account holder name, bank name, account number, branch code)
• Payment card information (processed securely via third-party payment processors — Privé does not store full card numbers)
• Wallet balance and transaction history on the Platform
• Withdrawal requests and payout records

Banking and payment data is used exclusively for processing transactions and complying with anti-money laundering (AML) and financial regulatory obligations.

1.3 Account & Profile Information

When you create an account on Privé, we collect information you voluntarily provide, including:

• Username or display name
• Email address and password
• Profile photographs and other media you upload
• Personal preferences, interests, and profile descriptions
• Communication preferences

1.4 Usage & Technical Information

We automatically collect certain technical data when you use the Platform, including:

• IP address and device identifiers
• Browser type, operating system, and device type
• Pages visited, features used, and time spent on the Platform
• Log data and error reports
• Cookies and similar tracking technologies (see Section 8 below)

1.5 Communications

We may retain records of communications conducted through the Platform, including messages between users, support enquiries, and feedback submitted to Privé, for safety, moderation, and dispute resolution purposes.

2. How We Use Your Information

Privé processes your personal information only where we have a lawful basis to do so under POPIA. We use your information for the following purposes:

• Identity Verification: To confirm your identity before granting access to booking or withdrawal features, and to comply with legal verification obligations.
• Payment Processing: To process reservation fees, tips, premium content payments, and fund withdrawals via third-party payment providers.
• Platform Operations: To create and manage your account, facilitate introductions between users, and provide Platform features.
• Safety & Trust: To detect, investigate, and prevent fraud, abuse, prohibited conduct, and violations of our Terms of Service.
• Legal Compliance: To comply with applicable South African law, including POPIA, SARS tax obligations, AML regulations, and any lawful requests from competent authorities.
• Customer Support: To respond to enquiries, resolve disputes, and provide assistance.
• Platform Improvement: To analyse usage patterns and improve the functionality and user experience of the Platform.
• Communications: To send service-related notifications, policy updates, and (where you have consented) promotional communications.

3. Sharing of Your Information

Privé does not sell your personal information. We may share your information only in the following limited circumstances:

3.1 Third-Party Service Providers

We engage trusted third-party providers to assist with Platform operations, including:

• Identity verification and biometric confirmation providers
• Payment processors and banking partners
• Cloud hosting and data storage providers
• Fraud detection and compliance services

All third-party providers are bound by contractual obligations to process your data only as instructed by Privé and in compliance with applicable privacy laws.

3.2 Legal & Regulatory Disclosure

We may disclose your personal information where required or permitted by law, including:

• To comply with a court order, subpoena, or other lawful legal process
• To respond to lawful requests from the South African Police Service (SAPS), South African Revenue Service (SARS), or other competent authorities
• To enforce these Terms or investigate potential violations
• To protect the safety, rights, or property of Privé, its users, or the public

3.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our business, your information may be transferred to the acquiring entity, subject to equivalent privacy protections.

4. Data Retention

We retain your personal information for as long as your account is active or as required to fulfil the purposes described in this Policy. Specifically:

• Identity verification records are retained for the period required by applicable law and regulatory obligations, typically a minimum of five (5) years following account closure.
• Financial and banking records are retained for the period required under South African tax and financial regulations.
• Account and profile data is retained until you request deletion of your account, subject to any overriding legal retention obligations.

When personal information is no longer required, it is securely deleted or anonymised.

5. Data Security

Privé implements appropriate technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption of sensitive data in transit and at rest
• Secure access controls and authentication protocols
• Regular security assessments and monitoring
• Restricted staff access to personal information on a need-to-know basis

While we take reasonable steps to protect your information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you use the Platform at your own risk.

6. Your Rights Under POPIA

As a data subject under POPIA, you have the following rights in respect of your personal information held by Privé:

• Right of Access: You may request confirmation of whether we hold your personal information and request a copy thereof.
• Right to Correction: You may request correction of inaccurate, incomplete, or outdated personal information.
• Right to Deletion: You may request deletion of your personal information where we are no longer legally required or entitled to retain it.
• Right to Object: You may object to the processing of your personal information in certain circumstances.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact our Information Officer at the address provided in Section 10. We will respond within a reasonable time and in accordance with POPIA.

7. Cross-Border Data Transfers

Privé is operated from the Republic of South Africa. Where we engage service providers located outside South Africa, we ensure that any cross-border transfer of personal information complies with the requirements of POPIA, including ensuring that the recipient country or organisation provides adequate levels of protection.

8. Cookies & Tracking Technologies

Privé uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse usage. You may control or disable cookies through your browser settings; however, doing so may affect the functionality of the Platform. By continuing to use the Platform, you consent to our use of cookies in accordance with this Policy.

9. Minors

The Platform is intended solely for adults aged 18 years and older. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected information from a minor, we will take immediate steps to delete such information. If you believe a minor has provided information to us, please contact us immediately.

10. Contact & Information Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal information, please contact our designated Information Officer:

Privé — Information Officer
Email: privacy@prive.co.za
Postal Address: [Insert registered address, South Africa]

You also have the right to lodge a complaint with the Information Regulator of South Africa:

Information Regulator (South Africa)
Website: www.inforegulator.org.za
Email: inforeg@justice.gov.za

11. Amendments to this Policy

Privé may update this Privacy Policy from time to time. When we make material changes, we will notify you via email or a prominent notice on the Platform prior to the change becoming effective. Your continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms.