1. Who the responsible party is
SEVEN TWENTY DEGREES (Pty) Ltd, registration number 2023/212025/07, incorporated in the Republic of South Africa, is the "responsible party" as defined in section 1 of POPIA. The responsible party has appointed an Information Officer under section 56 of POPIA (see section 7 below).
2. What we collect and why
We collect the minimum information needed to run the site and serve you what you've asked for. Concretely, that is:
- Newsletter subscriptions. When you submit the subscribe form we collect your email address, and — only if you provide them — your first name and the interest tags you've ticked. The lawful basis is your consent under POPIA section 11(1)(a) and, for direct marketing by electronic communication, section 69, supported by the double opt-in we run at the point of subscription.
- Contact messages. When you submit the contact form we collect the name, email address, topic and message body you send. Lawful basis: consent (s 11(1)(a)) and, where applicable, steps to enter into a contract at your request (s 11(1)(b)).
- Web server request logs. Our web server records standard request logs (IP address, timestamp, user-agent, URL requested, referrer, response code). These are retained for operational security and abuse handling. Lawful basis: legitimate interest of the responsible party (s 11(1)(f)) balanced against your reasonable expectations; logs are not joined to subscriber or contact records.
We do not run third-party analytics, tracking pixels, advertising cookies or behavioural profiling on this site. We do not sell personal information.
2a. Client-side geolocation lookup
When you load any page on this site, a small JavaScript file runs in your browser and makes a single request to ipapi.co (operated by Kloudend, Inc.) to retrieve the country your IP address is associated with. This is used to determine service availability in your region. The request is made by your browser directly to ipapi.co; we do not receive or store the result ourselves. ipapi.co's handling of your IP address is governed by its own privacy policy. You can block this request using browser privacy controls; doing so does not affect your ability to read the site.
3. Where your data lives
Subscriber and contact information is held in a PostgreSQL database hosted on a VPS physically located in the Republic of South Africa, operated by the responsible party, and mirrored to Zoho (Zoho Corporation) for newsletter delivery and contact-record handling once the delivery pipeline is live. Zoho processes data in accordance with its own data-processing terms and with the standard contractual protections required under POPIA Chapter 9 for cross-border transfer. Web server logs are held on the same VPS and are not transferred to third parties in the ordinary course.
4. Retention
Subscriber records are retained while you remain subscribed, and for up to 12 months after you unsubscribe so that we can evidence consent and comply with reasonable audit requests. Contact messages are retained for up to 36 months unless you request earlier erasure. Web server logs are retained for up to 12 months.
5. Sharing with third parties
Personal information is not sold, traded or disclosed to third parties except: (a) to Zoho, as the newsletter and contact-CRM operator, strictly to deliver the service you requested; (b) where we are legally required to disclose under South African law or a valid court order; and (c) to the extent necessary to protect the rights, property or safety of the responsible party, its users, or the public.
6. Your rights under POPIA
You have, under POPIA, the right to: request confirmation of whether we hold personal information about you and to access it (s 23); request correction or deletion of information that is inaccurate, excessive, out of date, misleading or obtained unlawfully (s 24); object to processing, including opting out of direct marketing, free of charge and at any time (ss 11(3) and 69); and lodge a complaint with the Information Regulator. Requests are to be sent to the Information Officer (section 7). We will respond within a reasonable period and, where POPIA specifies a timeframe, within that timeframe. Some requests (for example, a Form 2 access request under POPIA section 18) may require you to complete the prescribed form; we will tell you if that is the case and help you through it.
7. Information Officer
Terence Grenfell, Information Officer as contemplated in POPIA section 56, on behalf of SEVEN TWENTY DEGREES (Pty) Ltd.
Postal address: 52 Wilkes Road, Prestbury, Pietermaritzburg
Email: admin@720degree.co.za
8. Information Regulator
The Information Regulator (South Africa) supervises POPIA compliance. If you are dissatisfied with how we have handled your information, you may lodge a complaint with: Information Regulator, JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 — inforegulator.org.za.
9. Changes to this notice
This interim notice is dated 20 April 2026. We will publish a full POPIA-compliant policy at this URL before the newsletter delivery pipeline begins sending at subscriber scale. Material changes will be announced to existing subscribers by email.