Privacy notice
What we collect, why we collect it, how long we keep it — and how to tell us to delete it.
In force: [DATE] Last updated: [DATE] Version: 1.0
Earth Buddies is a small, family-run business. We collect as little about you as we can get away with, we use it only for the thing you asked us to do, and we don't sell it to anybody — ever.
This notice sets that out properly, because the Protection of Personal Information Act 4 of 2013 (POPIA) requires us to, and because you're entitled to know.
Who we are
POPIA s18(1)(b)Earth Buddies is the responsible party for the personal information described here. That means we decide why it's collected and what happens to it, and we carry the legal responsibility for it.
Our Information Officer
POPIA s55–56Every business in South Africa must have an Information Officer. Ours is Brad Cassell, registered with the Information Regulator as section 55(2) requires.
If you have a question about your information, want a copy of it, want it corrected, or want it deleted, he's the person to write to: brad@earthbuddies.pro. We aim to reply within 10 working days, and we never charge you for asking.
To do before launch: if Brad isn't registered yet, that's a legal requirement independent of this page. It's free, through the Regulator's portal at eservices.inforegulator.org.za. Delete this box once it's done.
What we collect, and why
POPIA s10, s13, s18(1)(a) & (c)Section 10 says we may only collect what is adequate, relevant and not excessive for the purpose. This is the whole list.
Section 12 requires us to collect directly from you, and we do — apart from the server records above, which your browser generates automatically when it requests a page.
What happens when you press Submit
POPIA s19, s21, s72This site has three forms: the enquiry form, the Subscribe here box beneath it, and the welcome pop-up that appears once on your first visit. All three are delivered by Netlify Forms, the built-in form service of the company that hosts this website. When you press Submit or Subscribe:
- The form posts over an encrypted (HTTPS) connection to Netlify.
- Netlify stores the submission and notifies Brad, who reads it in the Netlify dashboard.
- Netlify acts as our operator under section 21 — it processes on our written instruction and may not use your information for its own purposes.
- Netlify's servers are outside South Africa. See Information that leaves South Africa.
- Each form carries a hidden anti-spam field. If you can see it, don't fill it in — it catches bots and collects nothing about you.
- Both sign-up points feed one mailing list. We record which one you used, and nothing more.
- The welcome pop-up appears once per visit. Closing it sets a marker that lasts only as long as that browsing tab, so it won't follow you from page to page. If you press No thanks, that's recorded permanently and we stop asking altogether. Both markers stay on your device; we never see either.
The site used to open your own email programme to send an enquiry. That's gone — nothing on this site sends mail from your device any more.
Children at our classes
POPIA s34, s35(1)(a), s35(3)The law here is strict, and we follow it. Section 34 prohibits a business from processing a child's personal information at all, unless one of a short list of exceptions applies. The one we rely on is section 35(1)(a): the prior consent of a competent person — the parent or legal guardian.
- Nothing about a child goes through this website. The classes enquiry form asks only for an age band and a headcount, never a child's name or details.
- We will not sign a child up on the child's own say-so. A parent, guardian, school or venue books, and consent is given at that point.
- When a class is actually booked we ask for the child's first name and age only. Never a surname, ID number, home address or school record.
- All correspondence goes to the parent, guardian or school — never directly to a child.
- Section 35(3)(c) says we must not encourage a child to disclose more about themselves than the purpose reasonably needs. We don't.
- We don't photograph or film children for our website or social media unless the parent or guardian has given separate, specific, written permission. You can withdraw it at any time and we take the image down.
As a parent or guardian, you can at any time
- Ask to see everything we hold about your child.
- Tell us to stop using it, and we stop.
- Tell us to delete it, and we delete it.
Write to brad@earthbuddies.pro.
Allergies and medical notes
POPIA s26, s27(1)(a), s32, s4(5)Allergy and medical information is special personal information under section 26. When it concerns a child, section 4(5) means the special-information rules and the children's rules apply at once — the strictest combination in the Act. We treat it accordingly.
- We ask because of the garden, not out of curiosity. Classes involve soil, compost, worms, bees, seeds, nuts and plant sap. We need to know about a bee-sting or nut allergy before a child has their hands in a bed.
- Never through this website. We ask at booking, directly, with a separate consent each time — not bundled into anything else.
- We rely on your explicit consent under section 27(1)(a), given by the parent or guardian.
- Only the person running the class sees it. Section 32(2) requires everyone who handles it to be under an obligation of confidentiality, and they are.
- We keep it for the run of the class series and no longer, unless you ask us to hold it for a future booking.
- We never use it for anything else — not marketing, not profiling, not statistics.
If there's a medical emergency during a class we'll use this information to help your child and brief emergency services. That's the only circumstance in which we'd pass it on without asking you first.
When it's your choice to give it
POPIA s18(1)(d) & (e)Section 18 requires us to tell you whether giving us information is voluntary or mandatory, and what happens if you don't. It's always voluntary. Here's the honest consequence of holding each one back:
- No email or phone number — we have no way to answer your enquiry.
- No delivery address — we can't send you an order.
- No description of your space — we can't design or quote a garden.
- No allergy or medical note — we'll still take the booking. We'd simply run the class on the assumption that we haven't been told about any allergy, and we'd ask you to weigh that up.
- No newsletter sign-up — nothing happens at all. It has no effect on anything else you buy or book with us.
No law compels us to collect any of this. We ask because the work needs it.
Card payments
POPIA s19, s105–106Card payments are handled by [PAYMENT GATEWAY NAME], a registered South African payment provider.
- Your card number, expiry date and CVV go directly to the gateway over an encrypted connection.
- Earth Buddies never sees them, never receives them and never stores them. We couldn't hand them over if we wanted to.
- What we get back is confirmation that the payment succeeded or failed, a reference number, and the last four digits so we can match a payment to an order.
- Sections 105 and 106 make it a criminal offence to misuse an account number. Nobody at Earth Buddies will ever phone, email or WhatsApp you asking for your card number, PIN, CVV or a one-time password. If someone does, it isn't us.
- The gateway is its own responsible party for the card data it holds, under its own privacy notice: [LINK TO GATEWAY PRIVACY POLICY].
Information that leaves South Africa
POPIA s72Some of the services above run on servers outside South Africa. Section 72 allows this only on specific grounds. Ours are:
- Netlify (United States) — hosting and form submissions, under a binding data processing agreement upholding standards substantially similar to POPIA's, per section 72(1)(a).
- WhatsApp / Meta (United States and Ireland) — where you've chosen to contact us that way, the transfer is necessary to do the thing you asked, per section 72(1)(c).
- [MAILING LIST PROVIDER] — under its data processing agreement, and with your consent to receive the newsletter, per section 72(1)(a) and (b).
Children's information and allergy or medical notes are not transferred outside South Africa. They never touch the website, and section 57(1)(d) would require prior authorisation from the Information Regulator before any such transfer. We don't make one.
How long we keep it
POPIA s14Section 14(1) says a record may not be kept longer than is necessary for the purpose it was collected for. When a period ends, section 14(5) requires us to delete it in a way that can't be reconstructed — and we do.
Dormant records
POPIA s14(1) & s14(4)A record you're no longer using is a record we no longer need. Section 14(4) says we must destroy or de-identify it as soon as we're no longer authorised to keep it — so we don't wait for you to ask.
- Enquiries go dormant after 12 months of no contact, and are deleted automatically.
- Saved delivery addresses go dormant after 24 months without an order, and are deleted automatically.
- Newsletter subscribers who haven't opened anything in 24 months get one email asking whether they'd like to stay. No reply means we remove you.
- Aftercare client files go dormant 2 years after the last visit, and are deleted.
Where we're legally obliged to keep something for longer — invoices, for instance — we keep only the part the law requires and delete the rest.
Deleting your information
POPIA s24(1), s14(4)–(5)You can ask us to delete everything we hold about you, at any time, for any reason or none.
Email brad@earthbuddies.pro with "Delete my information" in the subject line. A plain sentence is enough — you don't need a form, a lawyer or an explanation.
It's free, and we act on it within 30 days.
What happens then
- We confirm it's really you asking. That protects you, not us.
- We delete what we hold so it can't be reconstructed, as section 14(5) requires — not just hidden or archived.
- We tell our providers to do the same with anything they hold on our behalf.
- We write back and confirm it's done, as section 24(4) requires.
The one thing we can't delete
If you've bought something from us, the invoice has to stay for 5 years. That's the Tax Administration Act, not our choice, and section 14(1)(a) recognises it. We'll tell you exactly what's being kept, why, and when it goes. Everything else around it — your phone number, delivery notes, correspondence — we delete.
How we keep it safe
POPIA s19- The whole site is served over HTTPS, so anything you type reaches us encrypted.
- Card details never touch our systems at all.
- Email, hosting and cloud accounts holding customer information use strong, unique passwords and two-factor authentication.
- Only Brad, Rodney and Eric have access, and each only to what their job needs. Allergy and medical notes go to the person running that class and no further.
- Section 19(2)(c) asks us to verify regularly that safeguards are working. We review them at least once a year, and after any incident.
No system is perfectly secure, and we won't pretend otherwise. What we can promise is that we take it seriously and we'll tell you promptly if something goes wrong.
Newsletters and WhatsApp
POPIA s69Section 69 prohibits unsolicited electronic marketing. So:
- We only add you to the mailing list if you tick the box asking us to, or if you're already a customer and we're telling you about our own similar products — which section 69(1)(b) permits, and which you can stop at any moment.
- At most one email a fortnight, and usually less. Seasonal planting notes, what we're building, and the occasional special offer.
- The tick-box is never pre-ticked and never bundled with anything else. Section 1 defines consent as voluntary, specific and informed — a pre-ticked box is none of those.
- Section 69(2) says that where consent is required, we may approach you only once to ask for it — and not at all if you've already withheld it. We read that as governing messages we send to you. The welcome pop-up is different: it only appears because you came to our site, and it sends you nothing.
- Even so, pressing "No thanks" is treated as consent withheld and we stop asking permanently. If you simply close the pop-up without answering, we take that as "not now" and may mention it again on a later visit.
- We never email or message you to ask for consent. The only place we ask is on this website, where you can ignore it.
- Section 69(4) requires every marketing message to identify the sender and give you a way to stop it. Every newsletter says plainly who it's from and carries a one-click unsubscribe. No hoops, no "are you sure", no login.
- We don't send marketing over WhatsApp. We use it to answer enquiries you've started. We won't add you to a broadcast list unless you've specifically asked.
- Unsubscribing never affects anything else — your order, your aftercare visits and your class booking all carry on as normal.
Your rights
POPIA s5, s11(3), s23, s24Section 5 gives you these. They're free to exercise, and using them costs you nothing with us.
- Ask what we hold. Section 23(1)(a) makes confirmation free. We'll also give you a copy in a form you can actually read. If a copy involves real work, section 23(3) says we must give you a written cost estimate first — and you can then decide.
- Correct it. Under section 24, if something's wrong, out of date, incomplete or misleading, tell us and we'll fix it — and tell anyone we'd passed the wrong version to.
- Delete it. See Deleting your information.
- Object. Section 11(3) lets you object at any time on grounds relating to your situation. Once you object, section 11(4) means we stop.
- Withdraw consent. Section 11(2)(b) lets you take it back whenever you like. That doesn't undo what was lawful before you withdrew it.
- Opt out of marketing at any time, instantly.
- Not be subject to automated decisions. Section 71 protects you from decisions made solely by machine. We make none — a person reads every enquiry.
- Complain — to us first if you're willing, and to the Information Regulator whether or not you come to us first.
How to ask
Email brad@earthbuddies.pro. A plain email is fine. If you'd rather use the official forms, objections go on Form 1 and correction or deletion requests on Form 2 of the POPIA Regulations, available from inforegulator.org.za.
Our PAIA manual
As a private body we keep a manual under section 51 of the Promotion of Access to Information Act, setting out the records we hold and how to request them. Available on request from Brad [or link it here once published].
If something goes wrong
POPIA s22If we have reasonable grounds to believe someone has got hold of your personal information without authorisation, section 22 requires us to notify both the Information Regulator and you, as soon as reasonably possible.
Section 22(5) says that notice must tell you enough to protect yourself. So we'll tell you in writing what happened, what it could mean for you, what we've done about it, what we suggest you do, and who was responsible if we know. We would not quietly sit on it.
Complaining to the Regulator
POPIA s74, s18(1)(h)(v)If you think we've mishandled your information, please tell us first — we'd genuinely rather fix it. But section 74 entitles you to go straight to the Information Regulator, and you need neither our permission nor our involvement.
Information Regulator (South Africa)
Section 75 requires complaints to be in writing — but it also obliges the Regulator to help you put it in writing if that's difficult for you.
Changes to this notice
If we start doing something new with personal information, we'll update this page and change the date at the top before we do it — not after. If the change is significant and we have your email address, we'll tell you directly rather than expecting you to notice.
Earlier versions are available from Brad on request.