Privacy Policy.

1. Introduction

Smukeliso Sourcing Solutions (Pty) Ltd (“we,” “us,” “our”) is committed to protecting your personal information in compliance with the Protection of Personal Information Act, 2013 (POPIA). This Privacy Policy explains how we collect, use, share, and protect your data.

2. Who We Are

Company: Smukeliso Sourcing Solutions (Pty) Ltd
Registration No: 2012/182035/07
Address: 155 West St, Sandown, Sandton, 2031
Information Officer: Zinhle Dube
Privacy Requests: consult@smukeliso.com

3. What Personal Data We Collect

We collect the following data depending on how you interact with us:

From the Procurement Maturity Diagnostic Tool

• Name
• Company name
• Work email address
• Phone number (optional)
• Industry sector
• Annual business revenue range
• IP address (used to detect your location)
• Assessment responses and procurement spend data

From Our Website Newsletter Signup

• Email address

From Contact Forms

• Name
• Email address
• Company name
• Message content

From Analytics & Cookies

• IP address
• Device information
• Pages visited
• Referrer information

4. Lawful Basis for Collection

We collect and process your personal information for the following purposes:

• Lead qualification (Diagnostic Tool)
• Marketing & Insights (Newsletter)
• Business communication (Contact Forms)
• Website optimisation (Analytics)

We rely on your explicit consent and the performance of a contract as our lawful bases for processing.

5. Third Parties & Data Sharing

We do not sell your personal information. We share data only with the following trusted service providers who assist us in delivering our services:

• Resend — Email service (United States)
• Google Sheets — CRM (United States)
• Google Analytics — Analytics (United States)
• Vercel — Website hosting (United States)
• Coupa — Strategic partner (United States)

All service providers are based in the United States. Cross-border data transfers comply with Section 72 of POPIA and are governed by Data Processing Agreements that provide POPIA-equivalent protections.

6. Data Retention Periods

We retain your personal information only for as long as necessary:

• Diagnostic submissions: 3 years
• Newsletter subscribers: Active subscription + 30 days post-unsubscribe
• Contact form submissions: 2 years
• Assessment & spend data: 1 year post-engagement
• Google Analytics data: 14 months (GA platform default)

After these periods, data is securely deleted or anonymised.

7. Your Rights Under POPIA

You have the right to:

• Access: Request a copy of your personal information held by us
• Correction: Request corrections to inaccurate or incomplete data
• Deletion: Request deletion of your personal information
• Objection: Object to the processing of your data for marketing purposes
• Opt-out: Unsubscribe from communications at any time

To exercise any of these rights, contact our Information Officer at consult@smukeliso.com.

8. Cookies & Tracking

We use cookies to enhance your website experience and analyse site performance. A cookie banner discloses all cookies we use and allows you to accept or reject them before any non-essential cookies are set.

9. Security Measures

We protect your data using the following measures:

• HTTPS encryption for all data in transit
• Secure storage with role-based access controls
• Regular backups via Vercel infrastructure
• Breach notification protocol (24-hour internal notification)

While we implement reasonable security measures, no system is entirely free from risk.

10. Data Breach Notification

If we discover a data breach that poses a risk to your rights and freedoms, we will notify you and the Information Regulator of South Africa as required by POPIA Section 22, without unreasonable delay.

11. Contact & Complaints

Email: consult@smukeliso.com
Address: 155 West St, Sandown, Sandton, 2031

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Regulator of South Africa:

• Website: www.inforegulator.org.za
• Email: complaint@inforegulator.org.za

12. Policy Updates

We may update this Privacy Policy from time to time. Changes will be effective upon publication on this website. We encourage you to review this page periodically.