Privacy Policy, Administrator / Data Processing Terms & POPIA

Effective date: 1 October 2026 | Version: 1.1

Accentronix CC (“Accentronix”, “we”, “us” or “our”) provides access-control products, mobile applications, cloud services and technical support. This policy explains how personal information is handled through those services and our website, and how you can exercise your privacy rights.

Our privacy obligations are governed by South Africa’s Protection of Personal Information Act 4 of 2013 (POPIA) and other laws where applicable. Using our services does not, by itself, provide blanket consent to every form of processing.

This document combines our privacy notice with the contractual Administrator and Data Processing Terms below. The privacy sections explain how information is handled. The Administrator and Data Processing Terms establish the obligations of Accentronix, the site organisation and its administrators when those terms are accepted. Merely visiting this page does not constitute contractual acceptance. Administrator acceptance does not provide consent on behalf of residents, visitors or dependants where their own consent, or consent from a competent parent or guardian, is required.

Contact our Information Officer

For privacy enquiries, access requests, corrections, deletion requests or complaints, contact our registered Information Officer through:

• Email: [email protected].
• Telephone: +27 21 330 5016.
• WhatsApp: +27 63 631 0314.
• Online: Contact Accentronix.
• Address: 2 Windhoek Street, Arauna, Brackenfell, 7560, Cape Town, South Africa.

Our support team operates every day of the year. We normally aim to handle correction and deletion requests within 24 hours, subject to reasonable identity verification, the scope of the request and applicable retention obligations. If more time is needed, we will explain the reason and expected timeframe. This service target does not limit your statutory rights.

Responsibilities of site organisations, administrators and Accentronix

For resident and visitor access-control information, the estate, property owner or other organisation operating the site generally determines who may be enrolled, what access they receive and why their information is processed. In this policy, we call that organisation the “site organisation”. It generally acts as the responsible party under POPIA, and its authorised administrators manage enrolment, permissions and removal on its behalf. The actual processing activity determines the allocation of responsibilities.

Accentronix processes site-managed information on the site organisation’s behalf to operate and support the access-control service. In this role, Accentronix acts as an operator and processes information according to authorised instructions and applicable law. Accentronix provides the technical service; the site organisation determines and administers its site-specific access policies.

The site organisation is responsible for ensuring that it and its authorised administrators:

• Establish a lawful basis for collecting and using resident and visitor information, and collect only information necessary for justified site purposes.
• Provide affected individuals with the necessary site-specific privacy information, including the site organisation’s identity, privacy contact details, collection purposes, required information and consequences of not providing it.
• Obtain and retain evidence of consent or another applicable authorisation where required, including for biometric processing and children’s information. Where parental or guardian consent is relied upon, establish that the person giving it has the necessary legal authority.
• Authorise administrators, keep enrolment details and permissions accurate, and promptly remove or update access when appropriate.
• Determine and justify site-specific retention requirements within the service’s available settings and agreed arrangements, subject to applicable law.
• Handle site-related privacy requests, objections and disputes about enrolment, eligibility and access, with technical assistance from Accentronix where necessary.
• Protect information in their own possession, including downloaded records, exported images and administrator credentials, and ensure that their staff and appointed service providers use it lawfully.

Accentronix remains responsible for its own operator obligations, including confidentiality, appropriate security safeguards, processing within authorised instructions, implementing agreed retention and deletion arrangements, and managing the providers and integrations it engages. Accentronix may decline or suspend instructions reasonably believed to be unlawful and seek clarification from the site organisation.

The Administrator and Data Processing Terms below form the written operator agreement when accepted by an authorised representative on behalf of the identified site organisation. They address authorised processing, security, retention, service providers, international processing, incident handling and privacy assistance. A separate paper agreement is not required solely because acceptance takes place electronically. Additional expressly agreed site-specific arrangements may supplement these terms. Neither acceptance nor the allocation of responsibilities transfers statutory obligations away from either party.

Accentronix is separately a responsible party for information it processes for its own purposes, such as customer administration, subscriptions, billing, technical support and the operation and security of its own business systems.

Requests concerning site-managed information may be directed to the site administrator or to Accentronix using the privacy contact details in this policy. Where a request falls within the site organisation’s responsibility, we will refer it promptly and provide appropriate assistance. Disputes about site access rules or eligibility should be directed to the site organisation; Accentronix assists with technical issues. These arrangements do not restrict your statutory rights or remove Accentronix’s own privacy and security obligations.

What information we process

Personal information includes information that identifies you directly or can reasonably be linked to you. Where applicable, it also includes information about identifiable businesses.

Depending on the services involved, we process:

• Contact and registration details: names, mobile numbers, site and device associations, access permissions and authentication records. Resident app activation uses a mobile number, not an email-based account. Email addresses may be processed separately for business, subscription or support purposes.
• Visitor and access records: invitations, selected visitor contact details, OTP-related records, credentials, gate events and timestamps, and information linking a visit to its host.
• Licence-scanning records: names, ID and driving-licence numbers, number plates, vehicle and licensing particulars, photographs and document images captured from driving licences and vehicle licence discs.
• Facial-recognition information: enrolment photographs and facial templates associated with the relevant resident or dependant.
• Technical records: device identifiers, connectivity and diagnostic information, IP addresses, software versions and service events where relevant to operating and supporting our systems.
• Business and transaction records: customer details, subscriptions, invoices, payment references and related administration.
• Support records: messages, tickets, attachments, relevant diagnostics and recorded technical-support calls.

Device data, facial templates and other coded records are still personal information when they can be linked to an identifiable person.

How we obtain and use information

Information comes from you, your authorised site administrator, a person inviting you to visit, your selected contacts, our connected devices and service providers involved in delivering the service.

We use relevant information to activate and administer services, authenticate users, apply access permissions, deliver invitations and OTPs, process subscriptions and payments, provide support, diagnose faults, protect systems and maintain reliable services.

For access-control installations, visitor and scanner records support security-incident investigations, identity verification on later visits and tracing a vehicle, its driver and the person being visited when dealing with unauthorised parking. The site organisation must assess which information is necessary for those purposes; these purposes do not automatically justify collecting every available field at every installation.

We also process records where necessary to meet legal obligations or establish, exercise or defend legal rights. Long-term trend analysis uses anonymised statistics as described below.

Depending on the activity, the lawful justification may be performance of a contract with you, a legal obligation, protection of your legitimate interests, our or another party’s legitimate interests, or your consent. Legitimate interests must be balanced against your rights. Additional requirements apply to biometric and children’s information. When we act as an operator, processing must remain within the site organisation’s lawful authority and instructions.

Where consent is the basis, you may withdraw it without affecting earlier lawful processing. We will explain any effect on the relevant service. Supplying information for access control does not authorise unrelated marketing.

Mobile app activation and permissions

An administrator first adds your mobile number to an authorised site or device. You then receive instructions to install and activate the app. Your number must remain active on at least one Accentronix site or device for app access to continue. When no active associations remain, app access is deactivated.

The app uses the following permissions for the specified functions:

Permission	Purpose and handling
Camera	Taking enrolment photographs for facial recognition. Submitted facial information is processed as explained below.
Contacts	Selecting a visitor for an invitation or OTP. Only the selected contact is sent; your entire address book is not uploaded.
Location	Security checks during initial app registration only. Location is processed on the phone and is not sent to Accentronix’s servers. It is not used for ongoing location tracking.
Bluetooth or nearby devices	Communicating with compatible access-control hardware to provide Bluetooth access functions.

You can manage permissions in your phone’s settings. Refusing a permission may prevent the associated feature from working. A mobile number and an authorised site or device association are necessary for resident app activation; other information is required only for the relevant service or feature. Your site organisation must explain any site-specific requirements and the consequences of not providing information.

Facial recognition and dependants

Residents enrol by taking a selfie in the Accentronix app. The site organisation’s authorised administrators manually approve enrolment before facial access is activated. The site organisation must establish the applicable lawful authorisation and provide the required enrolment notice before processing begins. Where consent is relied upon, it must obtain and retain evidence of that consent; administrator approval alone does not replace it. Enrolment photographs and/or facial templates are held in the cloud and on the relevant gate terminals to enable identification and access checks. Biometric information receives special protection under POPIA.

Residents may decline facial enrolment. Alternative methods can include tags, PINs, remotes or app access, but their availability depends on the estate’s enabled features and installed hardware. Contact the estate before declining or withdrawing enrolment to establish the access arrangements available to you.

Parents can use the app’s “load a dependant’s face” function under their own profile. A person submitting a child’s information must have the legal authority to do so. Processing a child’s information requires an applicable legal authorisation, such as prior consent from a competent parent or guardian, and biometric processing has additional requirements. The fact that a profile is labelled as a parent’s profile does not itself establish that authority. The site organisation is responsible for establishing the applicable authorisation and retaining evidence of any required consent from a competent parent or guardian. The person submitting a dependant’s information must provide accurate information about their authority.

You can select “Delete face” in the app. An administrator can also delete a face or remove the user from the access-control list. These actions remove the affected facial information from the live cloud system immediately and send deletion instructions to the relevant terminals. Connected terminals apply the deletion. An offline terminal retains its locally stored facial information and may continue to grant access until it reconnects and automatically applies the pending deletion.

If a facial terminal remains offline, local removal currently requires an authorised administrator or installer to factory-reset the terminal. A factory reset affects the terminal as a whole and can interrupt access for other users; it must be coordinated with the site organisation and, where needed, Accentronix support. The site organisation must arrange appropriate interim access controls where immediate revocation is required. A cloud deletion request must not be treated as confirmation that an offline terminal has already removed its local information.

Residual copies may remain in encrypted production disaster-recovery backups for up to 30 days. Facial deletions are reapplied following restoration of the production service so that previously deleted faces do not become active again through that restoration. Separate internal testing and debugging copies are described under “Internal testing and debugging”; their handling is not covered by the 30-day production-backup limit.

Where facial processing relies on consent, you can withdraw it through these controls or by contacting your site administrator or our Information Officer. The site organisation manages the resulting access arrangements, and Accentronix provides the relevant technical assistance. This policy explains the processing; it does not replace any consent or notice required at enrolment.

Removing your device access and requesting deletion

To remove yourself from a device in the app:

1. Select All Devices.
2. Select the device you want to remove yourself from.
3. Select the red Delete X icon.

This immediately removes the selected device association, its access permissions and the affected facial information from the live cloud system. Removal on the physical device depends on it receiving and applying the update. An offline terminal may continue to grant access using its locally stored information until it reconnects and applies the pending deletion. The offline-terminal and factory-reset arrangements above apply. This does not remove your other active device associations. App access ends when your mobile number has no remaining active site or device associations.

Removing access is different from immediately erasing historical records. Records linking your identity to past access events are retained for the remaining applicable period, up to 12 months, to preserve the access audit trail. They are then deleted or anonymised. Removal does not restart the retention period for historical events. Facial information follows the cloud, terminal, production-backup and internal testing-copy arrangements described in this policy.

For a broader deletion request, including removal of personal information across services, email [email protected] or use our other contact channels. Provide your registered mobile number and enough detail to identify the request. You do not need to reinstall the app or use a prescribed phrase to contact us.

After reasonable verification, we will handle the request with the relevant responsible party where necessary, including checking relevant internal testing and debugging copies, and explain any information that remains subject to lawful retention or technical deletion dependencies. Uninstalling the app alone does not request deletion. Privacy requests do not automatically cancel separate service contracts or remove existing payment obligations.

Support calls and AI assistance

Technical-support telephone calls are recorded for quality assurance and retained for 90 days. Accentronix does not record or store intercom calls or video streams. If you prefer written support, use our email, WhatsApp or online contact channels.

We use the OpenAI API to summarise support tickets, prepare draft replies for staff, respond directly to customers and inspect device diagnostics. Customers are informed when they are interacting with AI and can request assistance from a person.

Before sending information to the AI provider, our support tools replace email addresses and mobile numbers with reference keys. This reduces direct exposure of those identifiers but does not fully anonymise the material. Other personal details in message text or attachments may still be included. Please avoid submitting information unrelated to your support request.

We use standard API data settings. OpenAI states that API data is not used to train its models by default unless a customer opts in. Standard settings do not mean zero retention: abuse-monitoring logs may contain customer content and are ordinarily retained for up to 30 days, with exceptions, and additional storage depends on the features used. See OpenAI’s API data controls. Our own support tickets and conversations are retained for 90 days after their last activity.

AI assistance does not remove our responsibility for handling personal information appropriately.

Access to information and service providers

Within our access-control services, estate administrators and Accentronix support staff have access to resident and visitor records and associated images. Access is restricted according to their authorised responsibilities.

Contracted providers process relevant information to support hosting, storage, communications, support telephony, AI assistance, payments and business administration. Their technical processing is separate from the user access permissions described above. We remain responsible for the providers and integrations we engage within the scope of our obligations.

Information may also be disclosed to professional advisers, regulators, courts or law-enforcement bodies where lawfully required or justified, or in a business transaction subject to appropriate confidentiality and lawful processing requirements.

We do not sell personal information or share it with third parties for their own advertising or marketing.

Hosting and international processing

Our core access-control systems are hosted in South Africa and Europe. All categories of core access-control information may be processed in these regions, including resident and visitor details, access records, facial photographs and templates, and children’s information where the selected service processes it. Providers and locations within these regions may change according to system requirements and service quality. Multiple locations support service continuity, contingency arrangements and load balancing.

Production disaster-recovery backups and our internal development servers are located in South Africa. Communications, support, AI, payment and business-administration providers may separately process relevant information outside South Africa and Europe under their applicable service arrangements. The regional description of core hosting is not a promise that every supporting provider processes information only in those regions.

We describe providers by service category rather than publishing an infrastructure or supplier inventory. Categories include cloud hosting and storage, communications delivery, support systems and telephony, AI assistance, payments and business administration. The AI service specifically described in this policy remains identified in the support section. Our Information Officer can provide information relevant to a particular service about recipients, processing countries and applicable safeguards. Security-sensitive infrastructure details may be withheld where lawful; this does not limit required privacy disclosures or access rights.

Provider relationships use the applicable standard service and hosting agreements and any data-processing provisions incorporated into them. The existence of a standard hosting agreement does not, by itself, establish that every POPIA requirement has been met. Accentronix must assess the applicable terms, recipient protections and onward-transfer arrangements and obtain any additional safeguards required for the processing concerned. The contractual duties in the Administrator and Data Processing Terms apply when selecting or changing providers.

International transfers must satisfy section 72 of POPIA, for example through adequate protection under applicable law or a binding agreement, or another permitted transfer basis. The level of protection depends on the particular country, recipient and applicable safeguards; a location described simply as “Europe” does not establish adequacy on its own. Transfers of biometric or children’s information require particular care. Where section 57 requires prior authorisation from the Information Regulator, that authorisation must be obtained before the affected processing proceeds. Acceptance of this policy or administrator terms does not replace it.

Provider changes must remain within lawful instructions and applicable safeguards. Where a change requires an updated notice, contractual authority, consent or regulatory authorisation, the relevant requirement must be met before the affected processing begins. Your use of our services is not blanket consent to unrestricted overseas transfers.

Internal testing and debugging

Accentronix uses copies of real service information, including facial information, on internal development servers in South Africa for testing, fault investigation and debugging. Access is restricted to authorised Accentronix personnel. These copies are separate from the live cloud service and production disaster-recovery backups. Testing and debugging copies may be unencrypted at rest. The encryption statements for production storage and production backups do not extend to all development copies.

Development environments are usually refreshed from recent backups. In normal practice, older development copies are replaced and information that has disappeared from the source will generally no longer be present in development copies after approximately 90 days. This describes the usual refresh practice, not a verified automatic deletion deadline. Refreshing from a recent backup does not remove older records that are still lawfully present in that backup.

Deletion from the live cloud system must not be assumed to remove an existing development copy immediately. Privacy requests must be assessed against relevant development copies as well as production records. Contact our Information Officer if removal from these copies is required; we will assess and implement applicable deletion requirements and explain any lawful retention or technical dependency.

Internal testing remains subject to lawful purpose, necessity, security and retention requirements. Site-managed information may be used only within the site organisation’s lawful authority and instructions. This disclosure does not authorise unrestricted reuse of facial information or children’s information, unrelated product research, or retention merely because a copy is convenient for development. Information that is no longer necessary or lawfully retained must be deleted or de-identified; development refresh cycles do not override that obligation.

Retention and backups

Our normal retention arrangements are:

Information	Retention or deletion arrangement
Identifiable gate events, visitor records and associated scanner records	Up to 12 months, after which they are deleted or anonymised.
Active resident profiles and permissions	While the relevant access association remains active. After removal, identity-linked historical records remain only for the applicable audit-retention period.
Facial enrolment information	Retained for the enabled facial-access function. Live cloud deletion is immediate; terminal deletion depends on connectivity. Production-backup and development-copy arrangements are separate, as explained above.
Support tickets and conversations	90 days after last activity.
Technical-support call recordings	90 days.
Core-system disaster-recovery backups	Encrypted production backups are created daily and retained for up to 30 days. This limit does not include separate development or debugging copies.
Internal testing and debugging copies	Normally refreshed from recent backups; superseded information generally disappears within approximately 90 days in ordinary practice, not a guaranteed deletion deadline. See the dedicated section above.
Anonymised trend statistics	Up to three years. These are separate from identifiable recovery backups.
Billing, transaction and legal records	For the period required or lawfully justified by the relevant accounting, tax, contractual or legal purpose.

Retention is subject to necessity and applicable legal requirements. A specific incident, dispute or legal obligation may justify retaining relevant records beyond the normal period; this is not a reason to retain all records indefinitely. For site-managed records, the site organisation must justify its retention requirements and provide lawful instructions within the service’s available settings and agreed arrangements. Accentronix implements those arrangements; instructions do not authorise indefinite or otherwise unlawful retention.

Deleted information may persist temporarily in encrypted production disaster-recovery backups pending their expiry. Separate copies used for internal testing and debugging follow the arrangements above. We reapply facial deletions after a production restore. Anonymised statistics must not reasonably identify an individual; replacing a name with a linkable reference alone is not anonymisation.

Security and automated access

Our app, administrator-portal and device communications with the cloud use HTTPS/TLS. Production cloud databases and stored photographs and facial templates are encrypted at rest, and production disaster-recovery backups are encrypted. Internal testing and debugging copies have the separate encryption limitations explained above.

Access by Accentronix personnel is restricted according to authorised responsibilities, and Accentronix staff use multi-factor authentication. This statement does not imply that every estate-administrator account or gate terminal uses multi-factor authentication. Encryption of facial information stored locally on gate terminals has not been verified across the deployed hardware; the production cloud encryption statement does not extend to those local copies. Site organisations must control physical access to their terminals and coordinate maintenance and access revocation.

We perform ongoing internal security testing and reviews as we introduce products and features and address faults. This is not a claim of independent penetration-test certification or a fixed external testing schedule. We assess risks and review safeguards as our services and threats change. No technology can guarantee absolute security.

Where there are reasonable grounds to believe personal information has been accessed or acquired without authorisation, we follow applicable incident-response and notification requirements. As a responsible party, we notify the Information Regulator and affected people as soon as reasonably possible, subject to lawful exceptions. For site-managed information processed in our operator role, we notify the site organisation immediately as required and assist with its response. The site organisation is responsible for the required notifications to the Information Regulator and affected individuals in its responsible-party role. Each party remains responsible for notifications arising from processing for which it is itself the responsible party.

Gate systems automatically apply configured access permissions and, where enabled, facial matching. Estate administrators approve facial activation. If an access decision affects you, contact your estate administrator for review or Accentronix for technical assistance. Applicable protections for significant decisions based solely on automated processing remain available.

Service messages and website cookies

Residents receive operational communications, such as invitations, OTPs, security alerts and service notices. We do not use resident contact details to send promotional messages.

Our website uses cookies needed for its operation. We do not use website analytics or advertising trackers. You can manage cookies through your browser settings, although blocking essential cookies may prevent parts of the website from working.

Your privacy rights

Subject to applicable legal conditions and exceptions, you may request confirmation that we hold information about you, access to that information, correction of inaccurate or outdated information, and deletion where processing or retention is no longer lawful or justified.

You may also withdraw consent where relied upon, object to qualifying processing on grounds relating to your circumstances, object to direct marketing, request restriction where provided by law, and exercise applicable rights concerning significant automated decisions. Additional rights may apply where another jurisdiction’s law governs the processing.

For site-managed information, contact your site administrator or our Information Officer using any of the channels above. The site organisation handles decisions within its responsibility, and Accentronix refers requests promptly and assists with locating, correcting or deleting records where appropriate. For information processed for Accentronix’s own purposes, we handle the request directly. We may reasonably verify your identity or authority before disclosing or changing records. We will explain the outcome and any lawful reason for retaining information or declining part of a request. Confirmation of whether we hold your information is free; any legally permitted access fee will be explained before it is charged.

You may complain directly to the Information Regulator of South Africa:

• Website: inforegulator.org.za.
• Email: [email protected].
• Telephone: +27 10 023 5200.
• Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191, South Africa.

Administrator and Data Processing Terms

1. Parties, scope and electronic acceptance

Accentronix CC offers these terms for its access-control services. The other contracting party is the estate, body corporate, property owner, company or other site organisation identified in the service registration or site record. The accepted record must identify that organisation and the site or sites covered. A trading name or site label should be supplemented by the organisation’s legal identity where necessary to identify the contracting party.

By expressly accepting these terms on behalf of that organisation, an authorised representative concludes an electronic agreement between the organisation and Accentronix. These terms include the written operator agreement contemplated in section 21 of POPIA. The representative confirms that they have authority to bind the organisation to these terms; having administrator or installer access does not, by itself, establish that authority.

Organisational acceptance may be completed once for the sites identified in that acceptance record. Additional administrators must accept the obligations applicable to their own use of the service. Acceptance for one organisation does not automatically bind another organisation or a site outside the accepted scope.

A person who does not have authority to bind the site organisation must arrange acceptance by an authorised representative. Acceptance by such a person may establish their individual administrator obligations, but is not a substitute for the organisation’s operator agreement. For existing installations, acceptance of the operator terms may be obtained through the service by an authorised representative; these terms do not retrospectively establish an agreement for earlier processing.

The accepted document is made available for subsequent reference. Accentronix retains a record identifying the accepting person, the site organisation, the sites covered, the acceptance date and time, and the version and exact terms accepted. The site organisation may request a copy through the contact details above.

2. Processing authorised by the site organisation

The site organisation appoints Accentronix as its operator for site-managed personal information used to provide the subscribed access-control services. The people concerned include residents, dependants, visitors, hosts and authorised administrators. The relevant information, purposes, functions, retention arrangements, hosting and disclosures are described in the privacy sections of this document and any expressly agreed site-specific arrangements.

The organisation authorises Accentronix to host and process that information to administer enrolment and permissions, distribute authorised credentials and facial information to relevant devices, deliver operational communications, maintain access records, provide support, diagnose faults and secure and recover the service. Necessary internal testing and debugging to maintain or repair the subscribed service may take place under the safeguards and limitations described above, only to the extent covered by the organisation’s lawful authority and instructions. This authorisation is limited to the selected services and lawful site purposes. It does not authorise unrelated marketing, sale of information or unrestricted use for Accentronix’s own purposes.

Instructions may be given through authorised service settings, administrator actions, supported resident self-service controls or other agreed written channels. The site organisation authorises implementation of the resident access-removal and facial-deletion controls described in this document. Changes outside supported settings must be agreed with Accentronix; an administrator cannot create a new processing purpose merely by uploading information or requesting a feature.

Accentronix must process site-managed information only with the organisation’s knowledge or authorisation, within these instructions and applicable law. If a legal obligation requires processing outside those instructions, Accentronix will inform the organisation where legally permitted. Accentronix may seek clarification or decline or suspend an instruction reasonably believed to be unlawful.

3. Site organisation responsibilities

The site organisation remains responsible for POPIA compliance in relation to the site-specific purposes and decisions it controls. It must:

• Establish and document a lawful basis for processing and assess whether the information collected is necessary and proportionate to the site purpose.
• Provide the required notices to residents, visitors, dependants and administrators, including at enrolment or collection where appropriate. Linking this document does not replace the site’s own identity, purposes, contact details and other necessary site-specific information.
• Obtain and retain evidence of consent or another applicable legal authorisation where required. This includes addressing the additional requirements for biometrics and children’s information and establishing the authority of any person acting for a child or another individual.
• Determine lawful access rules, enrolment eligibility, permissions and retention instructions; maintain accurate information; and promptly update or revoke access when appropriate. Where terminals are offline, arrange reconnection or authorised local intervention and appropriate interim access controls. A cloud removal does not confirm that an offline terminal has applied the change.
• Appoint and supervise authorised administrators, review their access and protect credentials, exports, images and other information held outside Accentronix’s managed systems.
• Handle privacy requests and complaints falling within its responsible-party role and cooperate with Accentronix in implementing lawful corrections, restrictions and deletions.
• Make the required regulator and individual notifications for incidents within its responsible-party role, with assistance from Accentronix where relevant.

These duties belong to the site organisation. Designating an employee, installer or managing agent as an administrator does not automatically transfer the organisation’s statutory responsibilities to that person or to Accentronix.

4. Administrator obligations

Each administrator must act within the authority granted by the site organisation, use the service only for authorised lawful purposes and follow the organisation’s privacy and access-control instructions. Administrators must not browse, export, disclose or use personal information for unrelated personal or commercial purposes.

Administrators must protect their login credentials, use available security controls, keep their contact details current and report suspected misuse, unauthorised access or incorrect permissions promptly to the site organisation and Accentronix. They must not submit facial information or enrol another person without the applicable authority. They must promptly give up administrator access when their authority ends.

5. Accentronix operator obligations

Accentronix must maintain appropriate, reasonable technical and organisational security measures as required by section 19 of POPIA, assess relevant risks, verify safeguards and update them as reasonably required. The security and backup arrangements described in this document form part of its obligations for the relevant services.

Accentronix must keep site-managed information confidential and restrict access by its personnel and service providers to authorised service purposes, except where disclosure is required by law. Personnel and providers given access must be subject to appropriate confidentiality obligations.

Accentronix must implement agreed lawful retention and deletion arrangements, provide reasonable assistance with site-related privacy requests and supply information reasonably needed by the site organisation to understand and assess the safeguards applying to the service. Any testing or inspection affecting shared infrastructure must be arranged in advance and protect other customers’ information and service availability.

Accentronix remains separately responsible for processing undertaken for its own purposes, including billing, customer administration, support and business-system security, as explained in the privacy sections.

6. Service providers and international processing

The site organisation authorises Accentronix to engage providers for the hosting, storage, communications, support, AI assistance and other service functions described in this document, to the extent relevant to the selected service. Accentronix must ensure that providers processing site-managed information are bound by appropriate written data-processing, confidentiality and security obligations. Engaging a provider does not remove Accentronix’s own obligations.

International processing must comply with POPIA, including applicable safeguards for onward transfers. Before engaging or changing a provider, Accentronix must assess whether the applicable standard agreements and any incorporated data-processing terms provide the required protections, and address any gaps. A standard hosting agreement alone must not be treated as proof of adequate safeguards. Core hosting is limited to South Africa and Europe under the arrangements described above; supporting providers are addressed separately. Any prior authorisation required under section 57 must be obtained before the affected processing proceeds. Acceptance of these terms authorises the described service arrangements within lawful instructions; it is not blanket consent by residents, visitors or children to overseas processing and does not waive any required transfer safeguards or regulatory authorisation.

Accentronix will provide information about the providers and safeguards relevant to the service on reasonable request. A material change to provider or international-processing arrangements will be communicated where appropriate or legally required. Where a change requires revised contractual authority or consent, that authority or consent must be obtained before the affected processing begins.

7. Security compromises and cooperation

Accentronix must notify the site organisation immediately when there are reasonable grounds to believe site-managed personal information has been accessed or acquired by an unauthorised person, as required by section 21(2) of POPIA. Notification must not be delayed solely to await completion of an investigation. Further information may be supplied as it becomes available.

Accentronix must take appropriate containment and remedial steps within its control and provide available relevant information and reasonable assistance for the organisation’s incident assessment and notification duties. The site organisation must keep its incident contact details current and respond promptly. Each party remains responsible for notifications concerning processing for which it is itself the responsible party.

8. Retention, ending access and termination

Processing continues for as long as needed to provide the relevant service and complete lawful return, deletion or retention arrangements. The retention and backup provisions above apply, together with any expressly agreed lawful site-specific arrangements.

When a site service ends, the organisation may request return of available site-managed information in a supported format and instruct lawful deletion. The parties must establish the practical closure arrangements, including access to site-owned devices, pending updates on offline terminals and relevant internal testing or debugging copies. An authorised factory reset may be required to remove information from an offline facial terminal that cannot receive the pending deletion. Ending a subscription alone must not be assumed to erase all historical records or local device copies immediately.

Accentronix must delete or de-identify information when its permitted retention ends, subject to applicable law and protected backup expiry. Any legally required retained information must remain protected and be used only for the purpose justifying its retention. The site organisation remains responsible for copies it or its administrators exported and for hardware or systems outside Accentronix’s control.

9. Responsibility, other agreements and changes

The allocation of duties in this document does not exempt Accentronix or the site organisation from their own statutory obligations. It does not make Accentronix responsible for the organisation’s independently chosen access rules or unlawful administrator conduct, nor make the organisation responsible for Accentronix’s own failure to meet its obligations.

These operator terms supplement applicable service and subscription agreements. Any expressly agreed site-specific variation must be recorded and comply with applicable law. No conflicting contractual provision may be relied upon to reduce statutory privacy obligations. These terms are governed by South African law.

Publishing a revised privacy notice does not, by itself, establish acceptance of materially changed contractual obligations. Accentronix will obtain the organisation’s acceptance of material changes to these Administrator and Data Processing Terms before relying on those changes, unless an existing valid agreement lawfully provides another applicable variation procedure. Individual administrators must accept material changes to their own obligations where necessary.

10. Registration acceptance wording

For the authorised representative accepting on behalf of the site organisation, the registration checkbox must expressly identify this document and the organisation and sites covered. The acceptance wording is:

“I have read the Privacy Policy and agree to the Administrator and Data Processing Terms on behalf of the site organisation identified in this registration. I confirm that I am authorised to bind that organisation and accept its responsibilities for lawful enrolment, privacy notices, required authorisations, access management and other site-controlled processing. I also agree to comply with the administrator obligations applicable to my use of the service.”

Additional administrators joining an organisation that has already accepted the operator terms may accept their individual obligations using:

“I have read the Privacy Policy and agree to the administrator obligations in the Administrator and Data Processing Terms. I confirm that the site organisation has authorised me to administer the sites assigned to me.”

Neither checkbox gives consent on behalf of residents or visitors or removes Accentronix’s own obligations. A person without authority to bind the organisation must use the additional-administrator process and arrange organisational acceptance by an authorised representative where it is not already recorded.

Changes to this policy

We may update the privacy sections as our services and legal requirements change. We will publish the current version and effective date here, provide additional notice where appropriate or required, and obtain fresh consent where necessary. Changes to the contractual Administrator and Data Processing Terms follow the acceptance and variation provisions above.