Gizlilik Politikası

PRIVACY POLICY

DATE LAST MODIFIED: These Terms of Use and this Policy were last updated on 30 August 2025

  1. Interpretation

The headings of the clauses in this Agreement are for the purpose of convenience and reference only and shall not be used in the interpretation of, nor modify, nor amplify the terms of this Agreement, nor any clause hereof. Unless a contrary intention clearly appears:

1.1. Words importing:
1.1.1. Any one gender includes the other two genders;
1.1.2. The singular includes the plural and vice versa; and
1.1.3. Natural persons include created entities (corporate or unincorporated) and the state, and vice versa.

1.2. The following terms shall have the meanings assigned to them hereunder, and cognate expressions shall have corresponding meanings, namely:

1.2.1. “Agreement” means these Terms of Use and all documents incorporated by reference;
1.2.2. “App” means the mobile and online dating application known as Trumate, owned and operated by Trubase Technologies (Pty) Ltd, as updated from time to time, including any web-based derivatives thereof;
1.2.3. “Data Subject”, for the purposes of POPIA, means a User;
1.2.4. “ECTA” means the South African Electronic Communications and Transactions Act No. 25 of 2002;
1.2.5. “Information Officer” means the person appointed by us from time to time as contemplated by Part B of POPIA, currently being the person nominated in clause 11 below;
1.2.6. “Trumate” means Trubase Technologies (Pty) Ltd, a private company duly incorporated in terms of the laws of South Africa, and “we”, “us”, “our” and “ours” will have a corresponding meaning;
1.2.7. “Minor” means any person under the age of 18 (eighteen) years, and “child” will have the same meaning;
1.2.8. “PAIA” means the Promotion of Access to Information Act 2 of 2000, including all regulations promulgated thereunder;
1.2.9. “PAIA Manual” means the document contemplated by clause 10 below, which can be accessed upon request or via our website/app link: PAIA MANUAL 
1.2.10. “POPIA” means the Protection of Personal Information Act 4 of 2013, including all regulations, codes of conduct, compliance manuals, and guidelines that may from time to time be promulgated thereunder;
1.2.11. “Process” or “Processing” means operations and activities related to collecting, receiving, recording, organising, collating, storing, updating or modifying, retrieving, altering, consulting and using, disseminating, transmitting and sharing, deleting, and destroying personal information;
1.2.12. “Regulator” means the National Information Regulator established in terms of Part A of Chapter 5 of POPIA;
1.2.13. “Service” means the social and dating enabling service rendered by the App, which, inter alia, entails collecting your personal information and making the same available to third parties on the terms recorded herein;
1.2.14. “Terms of Use” means the provisions as contained in these terms of use;
1.2.15. “User” means a consumer who uses the App, and the terms “you”, “your”, and “yours” when used in these Terms of Use mean any user of the App, and “use”, “using”, and “used” mean the accessing of the App and viewing of the App’s content.

  1. Agreement and General Acceptance of the Policy

2.1. By accessing or using this App, you agree to the Privacy Policy and all applicable annexures and hyperlinks hereto, which form a legally binding agreement (“Agreement”). If you disagree, please exit this App immediately.

2.2. Access to and use of this App and the information, products, and services available through this App are subject to the Privacy Policy and to all applicable laws and regulations, including but not limited to the provisions of ECTA, POPIA, and PAIA, where applicable.

2.3. All content on this App belongs to Trumate, unless indicated otherwise. The content of advertisements belongs to the advertisers, but Trumate owns the compilation thereof. Any personal information you may upload to the App remains proprietary to you, but by using the App, you grant Trumate a limited license to make such information available to other users of the App (in accordance with your profile settings) and potential advertisers, subject to the terms of this Agreement. We deal with this aspect in more detail below. By using the App, you consent to us collecting, storing, disseminating, and using your personal information, subject to the terms and conditions recorded herein. Please make sure you fully understand the extent of the consent you give us. We strictly adhere to the provisions of POPIA and are here to assist you in fully understanding your rights under said Act.

2.4. This App may contain advertising and sponsorship. Advertisers and sponsors are responsible for ensuring that material submitted for inclusion in this App complies with all applicable laws and regulations. Trumate accordingly excludes, to the fullest extent permissible under law, any responsibility or liability for any error or inaccuracy appearing in advertising or sponsorship material.

2.5. Trumate may at any time, without notice, impose further and additional Privacy Policy relating to the use of this App. Your agreement to this Privacy Policy automatically binds you to the additional Privacy Policy.

2.6. The latest Privacy Policy will be posted on the App, and you should always review the policy before using the App to ensure that you have a current understanding of the Privacy Policy under which you are permitted to access this App. If you cannot access the Privacy Policy via the Internet, a copy of the most recent Terms of Use can be provided by e-mail upon request.

3. Children’s Information

3.1. The Trumate App is strictly intended for use by individuals who are 18 years and older. By creating an account, you confirm that you meet this age requirement.

3.2. We do not knowingly collect, process, or store the personal information of children under the age of 18. If we discover that we have inadvertently collected information from a person under 18, we will take immediate steps to delete such information.

3.3. Parents or legal guardians who believe that their child has provided personal information to Primarite without consent are encouraged to contact us promptly so that we may ensure such information is removed.

3.4. In line with POPIA and other applicable privacy legislation, Trumate reserves the right to request proof of age verification where necessary to maintain the integrity and safety of our platform.

  1. Personal Information

4.1. By creating a profile and using the Trumate App, you will be providing us with certain personal information about you. This information may include:
4.1.1. Your name, nickname, or chosen profile name;
4.1.2. Your email address;
4.1.3. Your location (general area, not precise address);
4.1.4. Your date of birth;
4.1.5. Your gender;
4.1.6. Your sexual orientation and/or relationship preferences;
4.1.7. Your interests and hobbies;
4.1.8. A description of yourself;
4.1.9. Your photos and/or images of yourself.

(Hereinafter referred to as “your personal information”).

4.2. You may further send messages, images, or other forms of content to other users via the Trumate App. If you do so, please bear in mind that such messages may contain additional information about yourself, which may include information relating to your religious and philosophical beliefs, race and ethnic origin, trade union membership, political views, health, or sex life. (Hereinafter referred to as “your private information”), which information is treated as special personal information in terms of the Protection of Personal Information Act, 2013 (“POPIA”).

4.3. For billing and subscription purposes, you may also provide us with your credit card details or other billing information reasonably required for you to transact on the Trumate App. This information will be kept strictly confidential and will not be disclosed to any third party without a lawful basis. Trumate will ensure that all financial information recorded is treated with the highest level of security.

4.4. In processing your personal and private information, Trumate adheres to all legislative requirements, including the principles of accountability, processing limitation, purpose specification, further processing limitation, information quality, openness, security safeguards, and data subject participation, as set out in clauses 8 to 25 of POPIA.

4.5. You provide us with this information voluntarily. Please note, however, that should you refuse to provide certain information, it may make it impossible for us to render some or all of the services available on the App, which may limit your full use and enjoyment of the App.

4.6. You always have the right, as provided for in POPIA, to:
4.6.1. Be notified of the information we collect from you and to be informed of any unauthorised access to your information;
4.6.2. Have access to your personal information held by us, and to request changes, corrections, or deletions thereof;
4.6.3. Object to the processing or use of your personal information (by completing the prescribed objection form as provided under POPIA), please use the following prescribed form to do so:  objection Form;
4.6.4. Object to any direct marketing practice;
4.6.5. Refuse the use of your personal information for direct marketing purposes without your consent;
4.6.6. Not be subjected to decisions made solely by way of automated processing;
4.6.7. Submit complaints to the Information Regulator; and
4.6.8. Institute civil proceedings as contemplated in section 99 of POPIA.

4.7. Trumate will not be held liable for any personal information that you disclose to a third party, including links that may be found on the App. You are advised to refer to the relevant third party’s privacy policy before disclosing any of your personal information.

4.8. The Trumate App may make use of cookies and tracking technology, whereby certain information you transmit while on the site or App is stored on your device. This allows the App to recognise you during future visits. Such technology is useful for gathering information such as browser type and operating system, tracking visitor numbers, and understanding how users interact with the App. Please note that personal information cannot be collected via cookie technology alone.

5. Consent to Processing

5.1. You consent to us processing your personal information for the following purposes:
5.1.1. Deliver and improve the Services;
5.1.2. Create and manage your account;
5.1.3. Provide you with user support and respond to your requests;
5.1.4. Facilitate and complete your transactions;
5.1.5. Communicate with you about our services, including order management and billing;
5.1.6. Analyse your profile, activity on the service, and preferences to recommend meaningful connections to you and recommend you to other users;
5.1.7. Show users’ profiles to one another;
5.1.8. Link the various devices you use to your profile;
5.1.9. Administer promotions, internal marketing and offers, contests, discounts, or similar advances;
5.1.10. Develop, display, and track content and advertising tailored to your interests;
5.1.11. Communicate with you by email, phone, social media, or mobile device about the Service;
5.1.12. Administer focus groups and surveys;
5.1.13. Conduct research and analysis of users’ behaviour to improve our services and content;
5.1.14. Develop new features and services for the App;
5.1.15. Address ongoing or alleged misconduct or breaches of these Terms and Conditions, both on and off-platform;
5.1.16. Perform data analysis to better understand and design countermeasures against these activities;
5.1.17. Retain data related to fraudulent activities to prevent against recurrences;
5.1.18. Comply with legal requirements;
5.1.19. Assist law enforcement;
5.1.20. Enforce or exercise our rights; and
5.1.21. Process your identification documents and related verification data through accredited third-party service providers for the purpose of validating your identity, preventing fraud, ensuring billing integrity, and complying with our obligations under the Protection of Personal Information Act, 2013 (“POPIA”). Such third-party providers are bound by confidentiality and data protection obligations consistent with POPIA.

5.2. As for your private information, you consent to us processing this information for the limited purpose of:
5.2.1. Investigating any complaints of infringement of another user’s rights or breach of the provisions of our Terms of Use, Privacy Policy, or other rules;
5.2.2. Enforcing our rights;
5.2.3. Aiding any criminal investigation; or
5.2.4. If subpoenaed in any civil proceedings.

5.3. We will not process your personal information beyond what is reasonably required for the aforesaid purposes.

5.4. You may at any time withdraw your consent for us to process your information. In this regard, please bear in mind that:
5.4.1. You need to advise us in writing;
5.4.2. You need to give us a reasonable time to process and give effect to your request; and
5.4.3. Your request may lead to the termination of the Service.

5.5. Please bear in mind that you may also at any time lodge an objection with us or the Regulator if you feel we are not processing your information lawfully.

 6. Cross-Collection Consent

By registering or logging into the Application using third-party services (including but not limited to Google, Facebook, or Apple), you expressly consent to the collection and use of certain information made available through those services, such as your name, profile photo, and verified contact details. Information will be imported at the time of registration and periodically updated only when you explicitly re-link your account. We will not engage in continuous, background collection of data from third-party platforms without your renewed consent. You are responsible for reviewing and managing your privacy settings on those third-party services.

7. Retention of Information

7.1. We will retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected or subsequently processed, unless a longer retention period is required or permitted by law.

7.2. In certain cases, we may retain specific personal information even after you have deleted your profile or stopped using our services. Such retention will be limited to the following purposes:
7.2.1. To enable the reactivation or restoration of your profile should you return within a reasonable timeframe;
7.2.2. To comply with legal, regulatory, or contractual requirements;
7.2.3. To prevent fraudulent or abusive conduct, including the creation of duplicate or prohibited accounts (for instance, where a profile has been permanently banned);
7.2.4. For internal research and development, provided such information is de-identified or aggregated so that it can no longer reasonably be linked to you.

7.3. Once personal information is no longer required for any lawful purpose, we will permanently delete or de-identify it as soon as reasonably possible, ensuring that it cannot be reconstructed in an intelligible form.

7.4. You may request in writing that we permanently delete the personal information we hold about you. We will honour such requests unless retention is required or otherwise lawfully permitted (for example, where your profile has been permanently banned or where we must comply with legal obligations). In such cases, we will delete all non-essential data and retain only the minimal identifiers strictly necessary for compliance. You may access the relevant request form here: Request Form.

 We retain your personal information only for as long as necessary to fulfil the purposes set out in this Agreement, to comply with legal obligations, to resolve disputes, and to enforce agreements. Deleted content may remain temporarily in our backup or archival systems for audit, fraud prevention, and lawful compliance purposes, but will not be used to recreate an active profile without your express consent. Once data is no longer required, it will be securely deleted or anonymised.

8. Advertising

We may present advertisements, sponsored content, and marketing communications within the Application. Such advertising may be tailored based on non-identifiable, aggregated, or anonymised data. Your personal and sensitive information, including private chats, orientation, or other sensitive disclosures, will never be shared with advertisers. We may, however, provide general demographic or usage trends (e.g., age ranges, location clusters, or app usage statistics) to advertisers and partners. You may opt out of personalised marketing within the settings of the Application.

9. Access to Information

You have the right to request access to the personal information we hold about you, as well as the right to request correction or deletion of such information, in line with the Promotion of Access to Information Act (PAIA) and the Protection of Personal Information Act (POPIA). Requests must be made formally through the contact channels provided in this Agreement. A reasonable fee may apply where permitted by law.

10. Security

We employ industry-standard administrative, technical, and physical safeguards to protect your personal information against loss, theft, unauthorised access, disclosure, alteration, or destruction. While we take all reasonable precautions, no system is entirely secure. You are responsible for maintaining the confidentiality of your login credentials, enabling two-factor authentication where offered, and ensuring the security of the devices you use to access the Application. We are not liable for breaches caused by your failure to secure your account or device.

11. How to Contact Us

If you have questions about this Privacy Policy, you can contact us via email at info@trumateapp.com