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Privacy Policy

Last Updated: January 2026

1. Introduction

Combined Intelligence (Pty) Ltd ("we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use the Combined Intelligence platform and related services (the "Service").

We are domiciled in the Republic of South Africa and comply with the Protection of Personal Information Act 4 of 2013 ("POPIA") and other applicable data protection laws.

Your Privacy Matters: We collect only what we need, protect what we collect, and give you control over your data.

2. Responsible Party

For purposes of POPIA, the responsible party for your personal information is:

3. Personal Information We Collect

We collect the following categories of personal information:

3.1 Information You Provide Directly

3.2 Information Collected Automatically

3.3 Content You Upload

You retain ownership of all content you upload. We process this content solely to provide the Service to you.

4. How We Use Your Personal Information

We use your personal information for the following purposes:

Purpose Legal Basis (POPIA)
Providing and operating the Service Performance of contract
Processing payments and billing Performance of contract
Account management and authentication Performance of contract
Customer support and communications Performance of contract / Legitimate interest
Service improvement and analytics Legitimate interest
Security and fraud prevention Legitimate interest / Legal obligation
Legal compliance and dispute resolution Legal obligation
Marketing communications (with consent) Consent

5. AI Processing and Your Data

Important: Your documents and conversations are processed by AI systems to provide the Service. Understanding how this works is essential to your privacy.

5.1 How AI Processing Works

When you use AI Companions or content generation features:

5.2 Third-Party AI Providers

We use the following AI service providers to process your data:

These providers process data in accordance with their own privacy policies and data processing agreements we have in place with them. Data sent to these providers is used solely to generate responses and is not used to train their models without separate consent.

5.3 Data Minimization

We only send the minimum data necessary to AI providers to fulfill your requests. We do not share your account information, billing details, or other personal data unrelated to the specific AI query.

6. Data Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

6.1 Service Providers

We share data with trusted third parties who assist us in operating the Service:

All service providers are bound by data processing agreements requiring them to protect your information.

6.2 Legal Requirements

We may disclose your information when required by law, such as:

6.3 Business Transfers

If Combined Intelligence is involved in a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you of any such change.

6.4 With Your Consent

We may share your information for other purposes with your explicit consent.

7. International Data Transfers

Your personal information may be transferred to and processed in countries outside of South Africa, including the United States, where our AI providers and some infrastructure services are located.

When we transfer data internationally, we ensure appropriate safeguards are in place:

8. Data Security

We implement appropriate technical and organizational measures to protect your personal information:

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

9. Data Retention

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

After the retention period, data is securely deleted or anonymized.

10. Your Rights Under POPIA

As a data subject under POPIA, you have the following rights:

10.1 Right of Access

You may request confirmation of whether we hold your personal information and access to that information.

10.2 Right to Correction

You may request that we correct or update inaccurate or incomplete personal information.

10.3 Right to Deletion

You may request deletion of your personal information, subject to legal retention requirements.

10.4 Right to Object

You may object to the processing of your personal information for direct marketing purposes or on grounds relating to your particular situation.

10.5 Right to Data Portability

You may request a copy of your personal information in a structured, commonly used, machine-readable format.

10.6 Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time.

10.7 How to Exercise Your Rights

To exercise any of these rights:

We may need to verify your identity before processing your request.

11. Cookies and Tracking Technologies

We use cookies and similar technologies for the following purposes:

11.1 Essential Cookies

Required for the Service to function properly:

11.2 Analytics Cookies

Help us understand how users interact with the Service:

11.3 Managing Cookies

You can control cookies through your browser settings. Note that disabling essential cookies may affect Service functionality.

12. Children's Privacy

The Service is not intended for use by children under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately.

13. Third-Party Links

The Service may contain links to third-party websites. We are not responsible for the privacy practices of these websites. We encourage you to review their privacy policies before providing any personal information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

Your continued use of the Service after changes constitutes acceptance of the updated Privacy Policy.

15. Complaints

If you believe your personal information has been processed in violation of POPIA, you have the right to lodge a complaint with:

We encourage you to contact us first so we can try to resolve your concerns.

16. Contact Us

For questions about this Privacy Policy or our privacy practices, please contact us:

© 2026 Combined Intelligence (Pty) Ltd. All rights reserved.

Registered in the Republic of South Africa

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