1. Introduction

Hoopoe Solutions (Pty) Ltd t/a myCAhub (“myCAhub”, “we”, “our” or “us”) respects your privacy and is committed to protecting Personal Information in accordance with the Protection of Personal Information Act, 4 of 2013 (“POPIA”).

This Privacy Policy explains how we collect, use, process, store and protect Personal Information when you join or participate in the myCAhub Clubhouse WhatsApp Community.

This Privacy Policy applies to:

• Every current or future myCAhub Clubhouse WhatsApp Community;
• Community announcement groups;
• The myCAhub CA(SA) FAQ Centre;
• Tax, CPD, career, social, networking and other subgroups; and
• Any replacement, duplicate or successor Community operated by myCAhub.

By joining or participating in the Community, you acknowledge that your Personal Information may be processed as described in this Privacy Policy.

2. When We Collect Personal Information

We may collect Personal Information when you:

• Join or request to join the Community;
• Accept or use a WhatsApp invitation link;
• Participate in a group or subgroup;
• Send a message, question, answer, comment, voice note, image, link or document;
• Respond to a poll, survey, competition or giveaway;
• Contact an administrator, moderator, contributor or community lead;
• Report misconduct or submit a complaint;
• Communicate with myCAhub through WhatsApp, email, social media or another channel; or
• Interact with Community announcements, links, events or sponsored content.

3. Personal Information We May Collect

Depending on how you participate in the Community, we may collect or have access to:

• Your telephone number;
• Your WhatsApp profile name;
• Your profile photograph;
• Your status or “about” information;
• Messages, questions, answers and comments;
• Voice notes, images, documents and links;
• Poll, survey, competition or giveaway responses;
• Your participation in particular groups or subgroups;
• Reactions and engagement information;
• Information provided when contacting an administrator or myCAhub;
• Reports, complaints or moderation records; and
• Any other information that you voluntarily share in the Community.

We may also maintain basic administrative records relating to membership, warnings, removals, reported conduct, complaints and enforcement of the Community rules.

Please do not share identity numbers, tax numbers, banking information, passwords, payslips, confidential employer or client information, private financial information or other unnecessary sensitive information in the Community.

4. How We Use Personal Information

We may process Personal Information to:

• Administer and operate the Community;
• Approve, manage, restrict or remove members;
• Communicate with members;
• Manage groups and subgroups;
• Answer questions and facilitate discussions;
• Moderate messages and enforce Community rules;
• Investigate complaints, misconduct, fraud or abuse;
• Protect members, administrators, contributors and community leads;
• Prevent unauthorised advertising, scraping, copying or misuse;
• Manage competitions, surveys, events, promotions and giveaways;
• Develop and improve myCAhub products and services;
• Create Community reports, summaries and insights;
• Create content for the myCAhub CA(SA) FAQ Centre;
• Comply with legal and regulatory obligations; and
• Protect or enforce myCAhub’s legal, commercial and intellectual-property rights.

We will process Personal Information only where permitted under POPIA and only to the extent reasonably necessary for the relevant purpose.

5. Questions, Messages and FAQ Content

Questions, answers, discussion topics, poll responses, suggestions, feedback and other Community contributions may be reviewed and used by myCAhub to identify common questions and develop:

• Content for the myCAhub CA(SA) FAQ Centre;
• FAQ questions and answers;
• Research Packs;
• Articles and newsletters;
• Community summaries;
• Infographics and social media content;
• Polls and surveys;
• Educational and training resources;
• Databases and knowledge bases; and
• Other existing or future myCAhub products and services.

Where reasonably possible, information used in public-facing content will be anonymised or de-identified so that the member is not directly identified.

We may retain anonymised, aggregated, edited, incorporated or derivative information after a member leaves or is removed from the Community.

Further provisions regarding the use, licensing and ownership of Community content are contained in the myCAhub Clubhouse WhatsApp Community Terms and Conditions.

6. WhatsApp and Visibility to Other Members

The Community operates through WhatsApp, which is a third-party platform operated independently of myCAhub.

Depending on WhatsApp’s functionality and your privacy settings, other members may be able to see your:

• Telephone number;
• Profile name;
• Profile photograph;
• Status or “about” information;
• Messages and reactions; and
• Participation in particular groups or subgroups.

By joining the Community, you acknowledge that this information may be visible to other members.

Your use of WhatsApp is also subject to WhatsApp’s own terms, privacy policy, security measures and platform practices.

Although myCAhub prohibits unauthorised copying and sharing, we cannot guarantee that another member will not screenshot, copy, forward, record, save or disclose information posted in the Community.

You should therefore avoid posting information that you would not be comfortable being seen or retained by other members.

7. Sharing of Personal Information

myCAhub does not sell members’ Personal Information.

We may share or allow access to Personal Information where reasonably necessary with:

• Community administrators and moderators;
• Authorised community leads, contributors and contractors;
• Technology, hosting, storage or communications service providers;
• Professional advisers;
• Security or fraud-prevention service providers;
• Regulators, courts or law-enforcement authorities where required or permitted by law; and
• Other persons where you have provided consent or instructed us to do so.

These parties may only process Personal Information for the relevant service, authorised purpose or legal obligation.

Some service providers, including WhatsApp and other technology providers, may process information outside South Africa.

Where myCAhub itself transfers Personal Information across borders, we will take reasonable steps to ensure that the transfer is handled in accordance with POPIA.

8. Sponsored Content and Commercial Partners

myCAhub may publish sponsored posts, advertisements, partner messages, affiliate or referral links, competitions, promotions, special offers and other commercial content in the Community.

A sponsor or commercial partner does not automatically receive members’ telephone numbers, profile information, messages or other Personal Information merely because it sponsors content or enters into a commercial arrangement with myCAhub.

We may share anonymised or aggregated Community information with sponsors or commercial partners, such as general membership, reach or engagement information, provided that individual members are not directly identified.

Personal Information may only be shared with a sponsor or commercial partner where:

• You have provided consent;
• You have chosen to engage directly with the sponsor or commercial partner;
• It is reasonably necessary to administer a competition, event, promotion, giveaway or offer in which you choose to participate; or
• The sharing is otherwise permitted or required by law.

Where you follow a sponsor’s link, submit information to a sponsor or contact a sponsor directly, that sponsor’s own privacy policy and practices will apply.

9. Security of Personal Information

myCAhub takes reasonable technical and organisational measures to protect Personal Information against loss, misuse, unauthorised access, alteration or disclosure.

These measures may include:

• Limiting administrator access;
• Restricting access to authorised persons;
• Using password-protected accounts and devices;
• Reviewing suspected misuse or security incidents;
• Removing or restricting members who breach Community rules; and
• Anonymising or de-identifying information used in public-facing content where reasonably possible.

However, no WhatsApp group, messaging platform or online service can guarantee absolute security.

myCAhub cannot control the security of another member’s device or prevent every unauthorised screenshot, recording, forwarding, copying or disclosure by another person.

10. Retention of Personal Information

We retain Personal Information only for as long as reasonably necessary for the purposes described in this Privacy Policy, to comply with legal obligations or to protect our legitimate rights.

As a general guideline:

• Membership and contact information may be retained while you remain a member and for a reasonable period afterwards;
• Messages and Community records may remain within WhatsApp in accordance with WhatsApp’s functionality and the settings of individual members;
• Moderation, complaint, warning and enforcement records may be retained where reasonably necessary;
• Questions and contributions used to create myCAhub resources may be retained in anonymised, edited, incorporated or derivative form;
• Anonymised and aggregated Community information may be retained indefinitely; and
• Information may be retained for longer where required by law or reasonably necessary in connection with a complaint, dispute, investigation or legal claim.

Leaving the Community does not automatically remove messages previously sent to the Community or copies already received, saved or retained by other members.

11. Your Rights Under POPIA

Subject to applicable law, you may:

• Ask whether myCAhub holds Personal Information about you;
• Request access to your Personal Information;
• Request correction of inaccurate, incomplete or outdated information;
• Request deletion of Personal Information where legally appropriate;
• Object to certain processing;
• Withdraw consent where processing is based on consent; and
• Submit a complaint to the Information Regulator.

These rights are subject to lawful limitations. For example, myCAhub may retain information where required by law, reasonably necessary to protect legal rights or already converted into properly anonymised information.

Privacy requests may be submitted to info@myCAhub.co.za.

We may request reasonable proof of identity before processing a privacy request.

12. Minors

The Community is intended primarily for adults, students and professionals aged 18 or older.

We do not knowingly invite children under the age of 18 to participate without appropriate authorisation.

Where we become aware that a child’s Personal Information has been collected inappropriately, we will take reasonable steps to remove or delete it where required.

13. Changes to This Privacy Policy

myCAhub may update this Privacy Policy from time to time.

Material changes may be communicated through:

• A Community announcement;
• A message posted in a group or subgroup;
• The myCAhub website;
• Email; or
• Another reasonable communication method.

The “Last Updated” date displayed at the top of this Privacy Policy will indicate when the latest version took effect.

14. Contact Us

Questions, requests or complaints regarding this Privacy Policy or the processing of Personal Information may be submitted to:

Hoopoe Solutions (Pty) Ltd t/a myCAhub

Email: info@myCAhub.co.za

You can access the myCAhub Clubhouse WhatsApp Community Terms and Conditions here.