Privacy Policy
Protection of Personal Information Act (POPIA) Compliant
Last updated: 1 January 2026
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IMPORTANT NOTICE Multi-Media Integrated Solutions (Pty) Ltd (trading as VelinX) is committed to protecting your personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA). This policy explains what personal information we collect, why we collect it, how we use it, and your rights as a data subject. |
1. Who We Are
Multi-Media Integrated Solutions (Pty) Ltd (trading as VelinX) (“VelinX”, “we”, “us”, “our”) is a technology company registered in the Republic of South Africa. We operate a vehicle WiFi monetisation platform that connects fleet operators, internet service providers (ISPs), and advertisers through a single intelligent network.
- Legal entity: Multi-Media Integrated Solutions (Pty) Ltd
- Trading as: VelinX
- Registration number: 2023/911229/07
- Physical address:Bekker Rd, Vorna Valley, Midrand, 1686
- Postal address: Bekker Rd, Vorna Valley, Midrand, 1686
- Email: privacy@velinx.co.za
- Website: www.velinx.co.za
2. Our Information Officer
In terms of POPIA, VelinX has appointed an Information Officer who is responsible for encouraging compliance with POPIA within our organisation and handling any requests or complaints from data subjects.
- Information Officer: [Name of Information Officer]
- Email: informationoffice@velinx.co.za
- Telephone: currently unavailable
The Information Officer has been registered with the Information Regulator of South Africa as required by POPIA.
3. Personal Information We Collect
3.1 Fleet Operators and Drivers
When you register as a fleet operator or driver on the VelinX platform, we collect:
- Full name and surname
- South African ID number or company registration number
- Contact details (email address, telephone number, physical address)
- Banking details for revenue payouts (EFT account information)
- Vehicle information (registration numbers, make, model, year)
- Operator permit or professional driving permit details
- Route and location data associated with your vehicles
- Earnings and payout records
- Device serial numbers and performance data
3.2 Advertisers
When you register as an advertiser on the VelinX platform, we collect:
- Company name and registration details
- Contact person name and details
- Billing information and payment details
- Campaign creative materials and targeting preferences
- Campaign performance and impression data
3.3 WiFi Passengers (End Users)
When a passenger connects to VelinX WiFi on a vehicle, we collect:
- Device identifiers (MAC address, device type — anonymised)
- Session data (connection time, duration, data consumed)
- Approximate location (suburb/corridor level only — not precise GPS)
- Aggregated usage statistics
We do NOT collect: name, email address, phone number, or any personally identifiable information from passengers without their explicit consent. Passengers connect anonymously.
3.4 Website Visitors
When you visit www.velinx.co.za, we collect information automatically through cookies and analytics tools. Please refer to our Cookie Policy (Document 5) for full details.
4. Purpose of Processing
We process personal information only for the following specific, lawful purposes:
- To register and manage your account on the VelinX platform
- To provide our services, including device installation, platform access, and revenue payouts
- To process and facilitate advertising campaigns and deliver verified impressions
- To process EFT payments and maintain financial records as required by law
- To monitor device health, connectivity, and network performance
- To communicate service updates, technical notices, and support responses
- To comply with legal obligations including POPIA, the ECT Act, and RICA
- To prevent fraud, security breaches, and unlawful activities
- To improve our services and develop new features based on usage patterns
- To enforce our Terms and Conditions and resolve disputes
5. Lawful Basis for Processing
We process personal information on the following lawful grounds as defined in POPIA:
- Consent — where you have given us specific, voluntary, and informed consent
- Contractual necessity — where processing is necessary to fulfil our contract with you
- Legal obligation — where we are required to process information to comply with the law
- Legitimate interest — where we have a legitimate business interest that is not outweighed by your rights
6. Data Sharing and Third Parties
We do not sell your personal information to third parties. We may share personal information with:
6.1 Service Providers
We use carefully selected service providers to help us deliver our platform. These include cloud hosting providers, payment processors, analytics platforms, and communication service providers. All service providers are bound by data processing agreements and may only use your information for the purpose of providing services to VelinX.
6.2 Legal Requirements
We may disclose personal information to law enforcement agencies, regulatory authorities, or courts when required to do so by applicable South African law, or where necessary to protect our legal rights or the safety of others.
6.3 Business Transfers
In the event of a merger, acquisition, or sale of all or a portion of our business, personal information may be transferred to the successor entity, subject to the same privacy protections.
7. International Transfers
Some of our service providers may store or process data outside of South Africa. Where this occurs, we ensure that adequate safeguards are in place as required by Section 72 of POPIA, including contractual protections equivalent to South African data protection standards.
8. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Our general retention periods are:
|
Data Category |
Retention Period |
Reason |
|
Operator account data |
7 years post-termination |
SARS tax compliance requirements |
|
Payment and payout records |
7 years |
Companies Act and SARS requirements |
|
Advertising campaign data |
3 years post-campaign |
Dispute resolution and audit |
|
Device and session logs |
24 months |
Technical support and fraud prevention |
|
Passenger WiFi session data |
90 days (anonymised) |
Aggregated analytics only |
|
Marketing consent records |
Until consent withdrawn |
POPIA consent documentation |
|
Support correspondence |
3 years |
Dispute resolution |
9. Your Rights as a Data Subject
Under POPIA, you have the following rights in relation to your personal information:
9.1 Right of Access
You have the right to request confirmation of whether we hold your personal information, and to receive a copy of that information. Requests can be made using our PAIA Form (see Document 7 — PAIA Manual).
9.2 Right to Rectification
You have the right to request that we correct any inaccurate, incomplete, or misleading personal information we hold about you.
9.3 Right to Erasure
You may request the deletion of your personal information where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and there is no other lawful basis), or where it has been processed unlawfully.
9.4 Right to Object
You have the right to object to the processing of your personal information where processing is based on our legitimate interests.
9.5 Right to Data Portability
Where technically feasible, you may request that your personal information be provided to you in a structured, commonly used, and machine-readable format.
9.6 Right to Withdraw Consent
Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before the withdrawal.
To exercise any of these rights, contact our Information Officer at informationofficer@velinx.co.za. We will respond within 30 days of receiving your request. We may need to verify your identity before processing your request.
10. Security
We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:
- End-to-end encryption for data in transit (TLS 1.3)
- Encryption of sensitive data at rest
- Role-based access controls with principle of least privilege
- Regular security assessments and penetration testing
- Employee training on data protection and information security
- Incident response procedures for security breaches
In the event of a data breach that is likely to prejudice your rights, we will notify you and the Information Regulator as soon as reasonably possible after becoming aware of the breach, in accordance with Section 22 of POPIA.
11. Marketing Communications
We will only send you marketing communications if you have provided explicit consent. You may unsubscribe from marketing communications at any time by clicking the unsubscribe link in any marketing email, by emailing unsubscribe@velinx.co.za, or by updating your communication preferences in your account dashboard.
12. Complaints
If you believe that we have processed your personal information in a manner that is inconsistent with POPIA, you are entitled to lodge a complaint with:
- Our Information Officer: informationofficer@velinx.co.za
- The Information Regulator of South Africa: inforeg@justice.gov.za | Tel: 010 023 5207
- Physical address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. We will notify registered users of material changes via email or in-platform notification. The current version of this policy is always available at www.velinx.co.za/privacy-policy.