life.file Privacy Policy

Last updated 17 JUNE 2021

When you interact with us, you share Personal Information that we use to make available and improve our services to you.  We respect your privacy and are committed to protecting your Personal Information. We want to be transparent with you about how we collect and use your Personal  Information in making available (i) the life.file website at www.lifefile.co.za (the Site) and (ii) any related services as described in our Terms of Use (collectively, the Services). 

This Privacy Policy aims to tell you more about: (i) your privacy rights (ii) how the law protects you and (iii) what information we collect about you, why we collect it, and how you can update, manage, export, and delete any information that you may provide through the Services. 

The Privacy Policy is also intended to meet our regulatory duties in terms of the  Protection of Personal Information Act, 2013 (POPIA).  The POPIA definition of Personal Information includes: information about an individual or business (data subject), from which the data subject is either directly identified or can be identified.  Some examples of Personal Information are a data subject’s name, contact details, identity number and IP address.

We review this Privacy Policy regularly. Occasionally, we may need to make changes or additions to this policy that may affect how we handle your data. We will indicate on this page when the policy has last changed. For the latest version, please refer here.

Who we are

The Services are provided by LIFE FILE TECHNOLOGIES (PTY) LIMITED, a company incorporated in South Africa with a registration number of 2021/631543/07 and trading as ‘life.file’.  Any mention of “life.file”, “we”, “us” or “our” in this Privacy Policy, refers to this registered company.  We are the responsible party that controls the processing of your Personal Information when you use the Services.  

How to contact us

You can contact us by emailing hello@lifefile.co.za or following the steps provided on our website here, if you have any questions, comments or concerns regarding our use of your Personal Information.

Under certain circumstances, by law, you have the right to:

• Request access to, and receive a copy of, your Personal Information and check if we are lawfully processing it. 

• Report incomplete or inaccurate information, and request the correction of the Personal Information that we hold about you. 

• Object to the processing of your Personal Information. 

• Request that any or all of your Personal Information is deleted or removed if there is no longer a lawful reason for us to process it. 

• Request the transfer of your Personal Information that you initially provided consent for us to use or where we have used this information to perform a contract with you.

• Withdraw your consent for us to process your Personal Information. 

If you want to exercise any of the rights described above, please contact us by sending an email to hello@lifefile.co.za. 

You will not have to pay a fee to request whether or not we hold personal information about you. However, if you require a record or a description of the Personal Information that we hold, including information about any third parties that we have shared or who have access to your Personal Information, we may charge a reasonable fee before we are able to comply with your request.  We will communicate the exact fee before complying with your request. 

We may need to request specific information from you to help us confirm your identity and your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We will only comply with any request regarding Personal Information once we are certain of the identity of the person making the request.

We would like to send you information about our products and services, which may be of interest to you. We will only send you marketing messages if you have registered as a user of the Site, or when you tick the relevant boxes at certain times when engaging with us.

If you have consented to receive such marketing from us, you can opt out at any time by following the steps outlined at the end of the email, usually by clicking “UNSUBSCRIBE”.

We will also send notifications of changes to our terms and conditions and policies, updates, security alerts, and support and administrative messages regarding the Services to the email addresses used by you to register for the Services.

Why do we collect your Personal Information? 

We will only use your Personal Information for the purposes for which we collected it, as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose that you provided the Personal Information to us.

In respect of each of the purposes for which we use your Personal Information, POPIA requires that we have a legal basis for that use. Most commonly, we will rely on one of the following legal bases:

• Where we have your specific consent to carry out the processing for the Purpose in question (Consent). 

• Where we need to perform a contract we are about to enter into or have entered into with you (Contractual Necessity).

• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (Legitimate Interests). 

• Where we need to comply with a legal or regulatory obligation (Compliance with Law).

What Personal Information we collect and how we use it

In the course of providing the Services, we collect the following personal information, either when it is provided to us by you, or where we derive it from your use of the Services:

• Identity Data (first name, surname):  We use this to create and authenticate your unique user profile on the Site.

• Contact details (email address): We use this to communicate with you; to authenticate you when you login to the Site; to help facilitate payments; and to help resolve account and technical issues experienced using the Services. If you sign up to life.file and do not complete a paid subscription, we may use these contact details to encourage you to take out a subscription to the Services.

• Summaries of conversations: We use this data that you provide to us when you report a problem or ask a question in respect of our Services or when you request further services from us. If you contact us, we may keep a record of that correspondence. We use this to help resolve account and technical issues experienced using the Services.

• Details of your subscription (type of subscription and  list of authorised contacts): We use this to provide you with the Services and to inform how we communicate with you. We use PayFast as our payment processor.

• Your geographical region and IP address: We use this to help resolve technical and account issues and to determine whether we can give you full access to the Services.

• Marketing preferences: We use this to determine whether and how we communicate with you to promote life.file.

• Log information: We may automatically collect and store certain information about your use of the Services in server logs, including internet protocol (IP) addresses, internet service provider, clickstream data, browser type and language, viewed and exited pages and date or time stamps. We use this to help resolve technical and account issues.

• Device information: We gather certain technical information from your use of our website by means of cookies and similar technologies. We use this to help resolve technical and account issues.

Additionally, we use the information for the purposes of research we undertake to understand how people use the Services in order to identify improvements we can make to the Services, how we promote it, and the range of services we offer. The research we produce is on an aggregated basis and does not identify you personally. We use it internally, and may also provide it to others. We also use some of the information for the purposes of keeping life.file and our communications with you secure from unauthorised access and attacks, and for reporting any unlawful activity. We may also need to process your information for the purposes of enforcing our Terms of Use.

We only collect Personal Information, on the terms set out in this policy, of children under the age of 18 with the explicit consent from their parent or guardian. If you are a parent or guardian of a child under the age of 18 who has provided consent for our collection of their Personal Information, you can at any time request us to tell you what we have about the minor child and also ask us to delete it at any time. We will ask you to prove your relationship to the child and, if you do so, you may (subject to applicable law) request access to and deletion of that child’s personal data.

If you give us information on behalf of someone else, such as when you enter the details of an authorised shared contact, you confirm that the other person has appointed you to act on their behalf and has agreed that you can: (i) give consent on their behalf to the processing of their personal data; (ii) receive on their behalf any data protection notices; and (iii) give consent to the transfer of their personal data, where relevant.

The life.file application has a feature to upload documents to your profile after a successful registration as a user of the Services. These documents are collected and stored on our external server hosted with Amazon Web Services (“AWS”), and may be shared with your authorised contact if you have provided consent for this sharing. We do not prescribe what the content of these documents are, and we also do not review the content of these documents to determine whether or not they contain special categories of Personal Information. POPIA defines special categories of personal information as any information relating to a person's religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric information or criminal behaviour. 

By uploading content that contains special categories of Personal Information, you are providing consent for us to store this information, and to share this information with your authorised contact. We do not have sight of these documents as they are stored securely and in an encrypted manner on AWS. We therefore encourage you to review all content of the documents to upload to the Site and consider whether or not they contain any special categories of Personal Information.  If you do not wish to share any information contained in the documents with your authorised contact, we recommend that you redact any sensitive information before uploading the document, or not upload the document at all.

Where we need to process your Personal Information either to comply with law, or to perform the terms of a contract we have with you, and you fail to provide that data when requested, it may affect the quality and level of service that we can provide to you. This may range from a lack of personalisation, and simple convenience (e.g. a lack of prefilled forms), all the way to not technically being able to provide a service. In this case, we may have to stop you using our Services. We will notify you if this is the case at the time.

Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site. Other than through our Site, our Services do not use cookies. Our Site uses the following types of cookies for the purposes set out below:

• Strictly Necessary Cookies

  These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and require you to re-enter your password after a certain period of time has elapsed to protect you against others accidentally accessing your account contents. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

• Functionality Cookies

  These cookies are used to recognise you when you return to our Site and allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site. We also use these cookies to obtain information about your visit, including page response times and download errors.

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the settings, help tools or edit facility). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

We also use Google Analytics to see how visitors to our Site interact with us. You can find out more information about how Google Analytics uses cookies and how to disable this function here.

Below we describe who we share your Personal Information with, what we share and why we share it.

• Service Providers

  We use a range of partners in order to provide our Services to you. These partners include those that:

  • enable us to manage our workflows;

  • process our accounting transactions;

  • manage our communications; and

  • facilitate payments.

• Professional advisers

  Our lawyers, bankers, auditors, and insurers provide consultancy, banking, legal, insurance and accounting services.

• Regulators and other authorities

  Authorities may require reporting of processing activities in certain circumstances

• Analytics Providers

  Our analytics providers will use this information for the purpose of evaluating your use of our Site, compiling reports on Site activity and providing other services relating to Site activity and internet usage. Our analytics providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on our analytics providers’ behalf.

We endeavour to ensure that people who share or transfer your Personal Information hold it subject to appropriate safeguards and controls. Whenever we do transfer your Personal Information out of South Africa, we ensure a similar degree of protection is afforded to it by those service providers.

We take your privacy seriously and as such we have policies and technical measures in place to safeguard and protect your personal information against unauthorised access, accidental loss, improper use and disclosure. We will also take all reasonable precautions to ensure that our staff, employees, and contractors who have access to information about you, have received adequate training, and that any third parties who have access to your personal information are required to be fully compliant with any applicable privacy laws.  We also limit access to your information only to people in our company, and to any third parties, who need to have access to the relevant information for the purposes set out in this Privacy Policy. 

We have put in place procedures to deal with any actual or suspected Personal Information breach.  We will notify you and help guide you through steps to mitigate any damage and stay better protected. In the event of any such breach, we have systems in place to work with the Information Regulator. In addition, in certain circumstances (e.g. where we are legally required to do so) we may notify you of breaches affecting your Personal Information.

We do our best to protect your personal data through various measures including: 

• password protection on all customer accounts;

• offering 2 step verification when registering a user account; 

• utilising a 256 Secure Sockets Layer Certificate to keep our Site secure; and

• encrypting data that is transferred and storing such data in a secure AWS cloud server.

More information on the security measures we adopt can be found here. 

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the Internet is not entirely secure.  For this reason, we cannot guarantee the security or integrity of any Personal Information that is transferred from you or to you via the Internet. If you have any particular concerns about your information, please contact us by sending an email to hello@lifefile.co.za.

We keep all of your personal information only as long as we need it for the purpose for which you gave us consent and as long as it is legally required if the latter requires us to keep it longer. We have policies in place which we review regularly to ensure that we do not hold on to unnecessary personal information and that we delete this information securely when we no longer need access to it.

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Information, please send an email to us at hello@lifefile.co.za. We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, POPIA  gives you the right to contact the Information Regulator.  You can contact the Information Regulator at inforeg@justice.gov.za.