Privacy Policy | humble.OS

HUMBLE PRIVACY POLICY

Last updated: September 2026

INTRODUCTION
1. For purposes of this Privacy Policy, Humble, we, us or our means Humble Software (Pty) Ltd, registration number 2012/114432/07, with its principal place of business at 10th Floor, Firestation – Rosebank, 16 Baker Street, Rosebank, Johannesburg, 2196. This Privacy Policy explains how we collect, use, store, share and otherwise process Personal Information when you visit or use our Website or Software, purchase or use our Products, request delivery, collection, support, maintenance, repair, replacement or warranty assistance, communicate or transact with us, or otherwise have a business relationship with us.
2. We process Personal Information in accordance with POPIA and other applicable Law. Depending on the circumstances, we may process Personal Information either as a responsible party or as an operator, as those terms are contemplated in POPIA. Where we determine the purpose and means for which Personal Information is processed, we act as the responsible party.
3. Where you use the Software to collect, store or otherwise process Personal Information relating to your customers or other persons, you will ordinarily determine the purpose for which that Personal Information is processed, and we may process it on your behalf as an operator. In those circumstances, you are responsible for ensuring that you have a lawful basis for collecting and processing the Personal Information, and we will process it in accordance with the Software and Product Supply Agreement, your lawful instructions and applicable Law.
DEFINITIONS
1. For purposes of this Privacy Policy:
  1. Account means a unique account created for you to access or use the Software or any part or functionality of the Software.
  2. Device means any computer, mobile phone, tablet, point-of-sale device or other device through which the Website or Software may be accessed or used.
  3. Law means any applicable law, statute, regulation, subordinate legislation, binding code, directive, order or other legal requirement, as amended or replaced from time to time.
  4. Merchant means the person or entity that enters into the Software and Product Supply Agreement with Humble and, where applicable, whose details are recorded in the Software and Product Order Form.
  5. Operator has the meaning given to that term in POPIA.
  6. Personal Information has the meaning given to that term in POPIA and includes information relating to an identifiable living natural person and, where applicable, an identifiable existing juristic person.
  7. POPIA means the Protection of Personal Information Act 4 of 2013, as amended from time to time.
  8. Product means any hardware, equipment, device, accessory or other physical product purchased by you from us, including point-of-sale devices, tablets, computers, printers, scanners, cash drawers and related equipment or accessories.
  9. Responsible Party means a public or private body or any other person which, alone or in conjunction with others, determines the purpose of and means for processing Personal Information.
  10. Software means the Humble point-of-sale software and related software applications, features and functionality made available by Humble to you.
  11. Software and Product Supply Agreement means the agreement concluded between Humble and the Merchant governing the Software and Products supplied by Humble.
  12. Special Personal Information has the meaning given to that term in POPIA.
  13. Third-Party Service Provider means any third party that provides products or services to Humble or in connection with the Website, Software or Products, including an Operator where applicable. This may include hosting, cloud, software, integration, connectivity, billing, debit order, support, maintenance, courier, delivery, repair, manufacturer, supplier, professional and other service providers.
  14. Usage Data means information collected automatically through the use of the Website or Software or generated by the systems and infrastructure used to provide them, including Device information, IP address, browser information, access times, usage activity and diagnostic information.
  15. User means any person authorised or permitted by a Merchant to access or use the Software or any functionality made available through the Software on the Merchant’s behalf.
  16. Website means Humble’s website at humbleos.co.za and any related web pages operated by Humble.
  17. you or your means, as the context requires, a Merchant, User or any other person whose Personal Information is processed by Humble.
PERSONAL INFORMATION WE COLLECT
1. The Personal Information we collect will depend on how you interact with us, the Software and Products you use or purchase, and the services you request from us.
2. This may include your name and surname, email address, telephone or mobile number, physical, delivery and billing address, business or company information, registration information, banking details, debit order mandate information and other payment information required to administer fees, invoices, debit orders, purchases and refunds, information provided as part of a Software and Product Order Form, free trial registration, sign-up or other onboarding process, Account and User information, and correspondence and communications with us, including complaints, queries and support requests.
3. Where applicable, we may also process Personal Information relating to your members, directors, shareholders, employees, representatives and Users.
4. Where you purchase, return or request support in respect of a Product, we may process the name and contact details of the person responsible for receiving or returning the Product, delivery, collection and return addresses, courier and tracking information, Product type, model and serial number, purchase and warranty information, details of faults, defects and technical issues, photographs, videos or other information supplied to demonstrate a fault, repair, replacement, assessment and maintenance records, and communications relating to the delivery, collection, assessment, repair, replacement or return of the Product.
5. Where you use the Software, we may process information relating to your business and use of the Software, including business and store information, product and pricing information, inventory information, sales and transaction information, transaction dates, times and values, User details, permissions and activity, reports and records generated through the Software, and other information entered into or processed through the Software by you or your Users.
6. Usage Data may include your IP address, browser type and version, Device type, operating system, unique Device identifiers, pages, features and functionality accessed, date and time of access, time spent on the Website or Software, Account and login activity, diagnostic information, error and performance information, and other technical information relating to the manner in which the Website or Software is accessed or used.
7. Certain functionality of the Software may require access to location information. Where applicable, and subject to the permissions available on your Device, we may process location information for purposes of providing the relevant functionality. You may be able to enable or disable access to location information through your Device settings, although certain functionality may not operate as intended if access to location information is disabled.
PURPOSE FOR PROCESSING PERSONAL INFORMATION
1. We may process Personal Information to assess and administer applications for the Software or Products; conclude and perform the Software and Product Supply Agreement; create and administer Accounts; authenticate Users and manage permissions; provide, operate, maintain, host and support the Software and its functionality; supply and process orders for Products; arrange the delivery and collection of Products; provide technical and customer support; assess, repair, maintain, replace or return Products; administer warranties; communicate with you regarding the Software, Products or your Account; and improve the functionality, stability, security and performance of the Software and Products.
2. We may also process Personal Information to issue invoices and statements; administer Fees, debit orders and other agreed methods of payment; reconcile amounts paid or outstanding; manage overdue amounts; maintain accounting and financial records; administer our contractual relationship with you; comply with applicable Laws and other legal obligations; institute or defend legal proceedings; investigate or respond to suspected unlawful conduct; and respond to any lawful request, notice, order or direction from a court, regulator, law enforcement agency, governmental authority or other competent authority.
3. Where permitted by POPIA, we may process Personal Information where necessary to pursue our legitimate interests, the legitimate interests of the data subject or those of a third party.
4. Where processing requires your consent, we will obtain your consent before processing the relevant Personal Information. You may withdraw your consent at any time, although we may continue to process Personal Information where another lawful basis for processing applies.
5. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal.
SPECIAL PERSONAL INFORMATION
1. Humble does not ordinarily require Special Personal Information in order to provide the Software or Products.
2. Where Humble does process Special Personal Information, we will only do so where the processing is permitted under POPIA.
FURTHER PROCESSING OF PERSONAL INFORMATION
1. Personal Information is collected for specific, explicitly defined and lawful purposes. We will only further process Personal Information where the further processing is in accordance with, or compatible with, the purpose for which the Personal Information was originally collected, or where the further processing is otherwise permitted under POPIA.
2. In determining whether further processing is compatible with the original purpose, we will consider the relationship between the original and further purposes, the nature of the Personal Information, the potential consequences of the further processing for the data subject, the manner in which the Personal Information was collected, and any relevant contractual rights and obligations. Further processing may also be permitted in circumstances contemplated in POPIA, including where you have consented to the further processing, the Personal Information is contained in a public record or has deliberately been made public, or the further processing is necessary to comply with Law, for legal proceedings, or for historical, statistical or research purposes subject to the requirements of POPIA.
SOURCES OF INFORMATION – HOW AND WHERE WE COLLECT PERSONAL INFORMATION
1. We may receive Personal Information from third parties where reasonably necessary in connection with our relationship with you or the provision of the Software or Products. Depending on the circumstances, these sources may include your authorised Users or representatives, Third-Party Service Providers, courier and logistics providers, Product manufacturers and suppliers, repair and technical service providers, billing or debit order service providers, professional advisers and publicly available records or registers. Where you provide us with Personal Information relating to another person, you are responsible for ensuring that you are lawfully entitled to provide that Personal Information to us and, where required, that the person has been appropriately informed of the processing.
2. Where Personal Information is not collected directly from you, we will provide information regarding the source from which it was obtained where required by POPIA. Where the collection or provision of particular Personal Information is required or authorised by a specific Law, we will provide information regarding that Law where required under POPIA.
HOW WE SHARE PERSONAL INFORMATION
1. We may share Personal Information with Third-Party Service Providers where reasonably necessary to provide the Software, Products or related services, operate our business or fulfil the purposes described in this Privacy Policy.
2. This may include providers of hosting and cloud infrastructure, software and integrations, technical support, billing and debit order services, courier and logistics services, Product manufacturing, supply, repair and maintenance services, security and fraud-prevention services, and professional, legal, audit and accounting services.
3. We may also disclose Personal Information where required or permitted by Law, including to courts, regulators, law enforcement agencies, government departments and tax authorities, or to our professional advisers where reasonably necessary to establish, exercise or defend our legal rights.
HOW WE SECURE YOUR PERSONAL INFORMATION
1. The security and confidentiality of Personal Information are important to us. We take appropriate and reasonable technical and organisational measures to protect Personal Information in our possession or under our control against loss, damage, unauthorised destruction, unlawful access and unauthorised processing.
2. We take reasonable steps to identify reasonably foreseeable internal and external risks to Personal Information, establish and maintain appropriate safeguards against those risks, verify that those safeguards are effectively implemented and update them where necessary in response to new risks or identified deficiencies. Access to Personal Information is restricted to authorised persons who require access for legitimate purposes.
3. Where an Operator processes Personal Information on our behalf, we require the Operator, by written agreement, to establish and maintain appropriate security measures and to treat the Personal Information as confidential. Where we become aware of a security compromise affecting Personal Information, we will take the steps required under POPIA, including notifying the Information Regulator and affected data subjects where required.
THE RETENTION OF PERSONAL INFORMATION
1. We will retain Personal Information only for as long as is necessary to achieve the purpose for which it was collected or subsequently processed, unless a longer retention period is required or authorised by Law, reasonably required for a lawful purpose connected with our functions or activities, required in terms of an agreement, or consented to by the data subject. The applicable retention period may depend on contractual, tax, accounting, warranty, support, repair, regulatory, security and record-keeping requirements, as well as any actual or potential legal claims or disputes.
2. We may retain Personal Information after termination of the Software and Product Supply Agreement where permitted or required by Law. Once the Personal Information is no longer required and we are not otherwise entitled to retain it, we will destroy, delete or de-identify it in a manner that prevents its reconstruction.
TRANSFER OF PERSONAL INFORMATION OUTSIDE SOUTH AFRICA
1. We or our Third-Party Service Providers may use systems or infrastructure located outside South Africa. We will only transfer Personal Information outside South Africa where the transfer is permitted under POPIA, including where the recipient is subject to a law, binding corporate rules or binding agreement that provides an adequate level of protection; you have consented to the transfer; the transfer is necessary for the performance of a contract between you and us or for pre-contractual measures taken at your request; the transfer is necessary for the conclusion or performance of a contract concluded in your interests; or another lawful basis for the transfer applies.
2. Where appropriate, we will take reasonable steps to ensure that recipients of Personal Information outside South Africa maintain appropriate confidentiality, data protection and information-security safeguards.
HOW WE USE YOUR PERSONAL INFORMATION FOR MARKETING
1. We may use your Personal Information to market our Software, Products and related goods or services to you where permitted by Law.
2. Marketing may take place by email, SMS, WhatsApp, telephone or other electronic communication. Where consent is required for direct marketing by electronic communication, we will obtain the required consent before sending the relevant marketing communication.
3. You may object to or opt out of direct marketing at any time by using the unsubscribe or opt-out mechanism in the communication or by contacting us
AUTOMATED DECISION-MAKING
1. We do not currently use Personal Information to make decisions based solely on automated processing that produce legal consequences for you or affect you to a substantial degree. If we introduce such automated decision-making in future, we will do so only in accordance with POPIA and will implement the safeguards required by Law.
CHILDREN’S PERSONAL INFORMATION
1. The Website, Software and Products are not directed at children, and we do not intentionally require children to provide Personal Information in order to subscribe to or use the Software or purchase Products. Personal Information relating to a child may, however, be entered into or processed through the Software by you. Where we process such information on your behalf, you are responsible for ensuring that the processing complies with POPIA, including obtaining any consent or authorisation required by Law. Where we process children’s Personal Information for our own purposes, we will only do so where permitted by POPIA.
YOUR RIGHTS
1. Subject to POPIA and other applicable Law, you may request confirmation, free of charge, as to whether we hold Personal Information about you and may request access to that Personal Information. You may also request the correction or deletion of Personal Information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully, or request the destruction or deletion of a record of Personal Information where we are no longer authorised to retain it.
2. Where permitted by POPIA, you may object on reasonable grounds to the processing of your Personal Information and may object at any time to processing for direct marketing purposes. Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent will not prevent us from continuing to process Personal Information where another lawful basis for processing applies.
3. You may raise a concern or complaint regarding our processing of Personal Information by contacting us using the details set out below. You also have the right to lodge a complaint with the Information Regulator. Where POPIA or its Regulations prescribe a form for exercising a particular right, the applicable prescribed form should be used. The Information Regulator currently publishes prescribed forms for objections, correction or deletion requests and direct marketing consent.
COOKIES
1. Our Website may use cookies and similar technologies. A cookie is a small file or piece of information stored on or accessed through your Device when you visit a website. We may use cookies to enable Website functionality, remember preferences, understand how the Website is used, improve Website performance, maintain security and prevent or detect misuse or fraud.
2. You can control certain cookies through your browser or Device settings. Disabling certain cookies may affect the functionality or performance of the Website. Where consent is required for the use of a particular cookie or similar technology, we will obtain that consent as required by Law.
3. Google Ads measurement. We use Google Ads (Google LLC, account AW-982445166) to measure Website visits and successful 14-day trial signups and help optimise our advertising. Where permitted, Google receives browser and device information, IP address, page information, advertising click and cookie identifiers, and a random conversion reference. We do not send signup names, email addresses, telephone numbers or passwords to Google, and enhanced conversions and advertising personalisation are not enabled.
4. Google Ads tags are blocked for visitors in the EEA, United Kingdom and Switzerland, and where location cannot be determined. We have not connected the existing Zoho consent banner to Google advertising: accepting Zoho tracking does not authorise Google Ads tracking. Where consent is required, Google Ads measurement remains off until an advertising-specific consent flow is available; no blocked signup events are replayed later. Elsewhere, measurement is enabled unless you opt out or your browser signals Global Privacy Control or Do Not Track. You can disable it using Advertising settings in the Website footer; the refusal is stored in your browser and applies immediately across open tabs. Clearing browser storage or changing device removes that saved refusal. If advertising consent is added later, we will retain the visitor's choice, time and the notice version shown, preserve acceptance evidence on withdrawal, and provide a way to change the choice. See Google's privacy policy for its handling of information.
LINKS TO OTHER WEBSITES
1. The Website or Software may contain links to websites or services operated by third parties. We do not control those websites or services and are not responsible for their availability, content, security or privacy practices. Your use of a third-party website or service will be subject to the terms and privacy practices of that third party, and you should review the applicable privacy policy before providing Personal Information directly to it.
INFORMATION QUALITY
1. We take reasonably practicable steps to ensure that Personal Information in our possession or under our control is complete, accurate, not misleading and updated where necessary, having regard to the purpose for which it is processed. You should notify us if your Personal Information changes or if you become aware that Personal Information held by us is inaccurate.
FAILURE TO PROVIDE PERSONAL INFORMATION
1. The provision of certain Personal Information is voluntary. However, some Personal Information may be required in order for us to process an application, conclude or perform the Software and Product Supply Agreement, create or administer an Account, provide the Software, supply, deliver, collect, repair or replace a Product, administer billing or debit orders, provide support or comply with applicable Law.
2. If you do not provide Personal Information that is reasonably required for these purposes, we may be unable to process your application, conclude the relevant agreement or provide the applicable Software, Product or service.
CHANGES TO THIS PRIVACY POLICY
1. We may update this Privacy Policy from time to time to reflect changes in our business, Website, Software, Products, processing activities or applicable Law. The latest version will be made available on our Website and will indicate the date on which it was last updated.
CONTACT US
1. Questions, requests or complaints regarding this Privacy Policy or our processing of Personal Information may be directed to:

Humble Software (Pty) Ltd
10th Floor, Firestation – Rosebank
16 Baker Street
Rosebank
Johannesburg
2196

Email: (>>>)

Requests relating to the exercise of rights under POPIA or PAIA may also be directed to our registered Information Officer at:

Information Officer: [insert name/designation]
Email: [insert Information Officer email address]

INFORMATION REGULATOR
1. If you are not satisfied with how Humble has dealt with your Personal Information or your complaint, you may lodge a complaint with the Information Regulator (South Africa).

Information Regulator (South Africa)
Woodmead North Office Park
54 Maxwell Drive
Woodmead
Johannesburg

Telephone: 010 023 5200

General enquiries: enquiries@inforegulator.org.za

POPIA complaints: POPIAComplaints@inforegulator.org.za