Privacy Policy

Aligned to the Stocklink-SA ESL Subscription Agreement
Last updated: 03/01/2026

1. Introduction

This Privacy Policy explains how Polyfarm Technologies (Pty) Ltd (“Polyfarm”, “we”, “us”, “our”) collects, uses, and protects personal information in accordance with the Protection of Personal Information Act, 4 of 2013 (POPIA).

This policy applies to Customers and authorised users of the Stocklink-SA Electronic Shelf Label (ESL) platform and related services, as governed by the Stocklink-SA Electronic Shelf Label (ESL) Subscription Agreement (“Agreement”).

2. Personal Information We Collect

In the course of providing the Service under the Agreement, we collect and process limited business-related personal information, including:

• First name
• Surname 
• Company email address
• Physical service address (store or business location)
   

This information is collected solely for operational, contractual, and service delivery purposes.

We do not collect:

• Consumer or shopper data
• Identity numbers
• Payment card details
• Personal residential addresses (unless the Customer’s business operates from such address)
   

3. Purpose of Processing

Personal information is processed strictly to enable Polyfarm to perform its obligations under the Agreement, including:

• Creating and managing authorised user accounts
• Authenticating users and controlling access to the Service
• Communicating service, support, and operational notices
• Scheduling, commissioning, deploying, and supporting Devices at Customer service locations
• Managing Device status, replacements, recoveries, and terminations
• Maintaining audit logs, platform security, and service integrity
   

Processing is carried out on the lawful basis that it is:

• Necessary to perform a contract (the Agreement), and/or 
• With the data subject’s consent, and/or 
• In Polyfarm’s legitimate business interests, as permitted by POPIA
   

4. Data Storage and Cross-Border Processing

Personal information is stored and processed using Google Firebase, a service provided by Google Cloud Platform. This may involve processing outside the Republic of South Africa. Polyfarm ensures that all such cross-border processing complies with Section 72 of POPIA, and that appropriate contractual, technical, and organisational safeguards are in place.

5. Security Safeguards

Polyfarm implements appropriate, reasonable technical and organisational measures to protect personal information, including:

• Encrypted data transmission (HTTPS/TLS) 
• Role-based access control
• Secure authentication mechanisms 
• Restricted administrative access 
• Segregation of Customer environments
   

6. Retention of Information

Personal information is retained only for as long as necessary to:

• Fulfil contractual obligations under the Agreement
• Provide ongoing support and Device lifecycle management 
• Meet legal, accounting, or audit requirements

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

7. Sharing of Personal Information

Polyfarm does not sell or trade personal information. Personal information may be shared only with:

• Operators (such as Google Firebase) strictly for Service operation 
• Approved contractors or service partners involved in Device deployment or support, under confidentiality obligations
• Regulatory or law enforcement authorities where required by law
   

8. Data Subject Rights (POPIA)

In accordance with POPIA, data subjects have the right to:

• Request access to their personal information 
• Request correction or deletion of information 
• Object to the processing of personal information
• Withdraw consent where processing is based on consent 
• Lodge a complaint with the Information Regulator (South Africa)
   

9. Information Regulator

Complaints may be lodged with:

The Information Regulator (South Africa)
Website: https://www.justice.gov.za/inforeg/

10. Relationship to the Subscription Agreement

This Privacy Policy must be read together with the Stocklink-SA Electronic Shelf Label (ESL) Subscription Agreement. Where personal information is processed to perform obligations under the Agreement, such processing is deemed necessary for contractual performance.

11. Changes to This Policy

Polyfarm may update this Privacy Policy from time to time. The most current version will always be available on Polyfarm’s website.

12. Contact Details

For privacy-related enquiries:

Company: Polyfarm Technologies (Pty) Ltd
Email: solutions@polyfarm.co.za