Legal Document

Privacy
Policy

📅 Effective Date: 6 March 2026
🔄 Last Updated: 6 March 2026
🏢 Published by: CyberStudios (Pty) Ltd
Contents

CyberStudios (Pty) Ltd operates the Snaggle mobile application. This policy explains how we collect, use, and protect your personal information in compliance with the Protection of Personal Information Act 4 of 2013 (POPIA). By using the App, you acknowledge that you have read and understood this policy.

1
Who We Are — The Responsible Party

Under POPIA, the entity responsible for your personal information is:

Company NameCyberStudios (Pty) Ltd
Trading AsSnaggle
RegistrationRegistered in South Africa
Principal OfficeJohannesburg, Gauteng, South Africa
Emailsnaggle@cyberstudios.co.za
Websitewww.cyberstudios.co.za
Information OfficerThe Managing Director

2
Personal Information We Collect

2.1 Account & Identity Information
2.2 Usage & Activity Data
2.3 Device & Technical Data
2.4 What We Do NOT Collect

3
How We Collect Your Information

4
Legal Basis for Processing (POPIA)

Lawful GroundPurpose
Contractual necessityTo provide the App services you have contracted for
Legitimate interestsTo improve the App, detect fraud, and send relevant service communications
Legal obligationTo comply with POPIA, tax laws, and applicable South African legislation
ConsentTo send marketing communications (withdraw at any time by emailing us)
Protection of your interestsIn emergency situations to protect safety

5
How We Use Your Information

Service Delivery
Security & Compliance

We do not sell your personal information to any third party. We do not use your data for targeted advertising through third-party advertising networks.

6
How We Share Your Information

Within Your Organisation / Project

Your name, email, and project activity will be visible to the project administrator and authorised team members.

Service Providers (Operators under POPIA)
ProviderPurposeData Shared
AppwriteBackend infrastructure (auth, database, file storage)Account data, app content, files
Google (OAuth)Authentication via Google Sign-InName, email address, Google ID
Email ServiceTransactional email deliveryName, email address
AnalyticsAggregated app usage analyticsAnonymised usage data only
Crash ReportingError and crash diagnosisDevice type, OS, error logs
Legal Disclosure

We may disclose your personal information if required by law, court order, or valid legal process from South African regulatory authorities.

7
Cross-Border Transfers

Some service providers (Appwrite, Google) may process your data outside South Africa. Where data is transferred outside South Africa, we comply with Section 72 of POPIA through binding contracts, adequacy decisions, or consent.

8
Data Retention

Data CategoryRetention PeriodReason
Account & profile dataDuration of account + 3 years after deletionLegal disputes, regulatory compliance
Snag & project recordsDuration of project + 5 yearsNHBRC warranty periods, construction regulations
Digital handover sign-offs10 years from handover dateNHBRC Major Structural Defect warranty + buffer
Audit trail logs5 yearsLegal evidence, tamper-evident record
Support communications3 yearsDispute resolution
Anonymised analyticsIndefinitelyNon-personal — used for product development

9
Your Rights Under POPIA

Your RightWhat It Means
Right of AccessRequest a copy of personal information we hold about you (POPIA Section 23)
Right to CorrectionRequest correction of inaccurate or outdated personal information
Right to DeletionRequest deletion of your personal information (see our Deletion Policy)
Right to ObjectObject to processing of your information on legitimate interest grounds
Right to Withdraw ConsentWithdraw consent at any time without penalty
Right to ComplainLodge a complaint with the Information Regulator of South Africa

To exercise your rights: snaggle@cyberstudios.co.za — we respond within 30 days as required by POPIA.

Information Regulator of South Africa

10
Security of Your Information

In the event of a data breach that poses a risk to your rights, we will notify you and the Information Regulator as required by POPIA Section 22.

11
Cookies & Tracking

The Snaggle mobile app does not use browser cookies. The app uses session tokens stored locally on your device and anonymised crash/analytics SDKs. If you access Snaggle through a web browser (e.g. the resident portal), standard session cookies may be used. You may configure your browser to reject cookies.

12
Children's Privacy

Snaggle is a professional business application for adults in the construction and property industry. We do not knowingly collect personal information from persons under the age of 18. If you believe a minor has provided us with personal information, please contact snaggle@cyberstudios.co.za immediately.

13
Changes to This Policy

When we make material changes to this policy we will update the "Last Updated" date, display an in-app notification, and send an email notification for significant changes. Your continued use of the App after changes constitutes acceptance of the updated policy.

14
Contact Us

Organisation
CyberStudios (Pty) Ltd — trading as Snaggle
Information Officer
The Managing Director
Response Time
Within 30 days as required by POPIA