PRIVACY POLICY FOR COMUTA CONNECT

This privacy policy governs your use of the software application ComutaConnect (Application) for mobile devices that was created by Intellimali PTY (LTD). The Application is allows a account holder to view their balances, request vouchers, update details and make payments.

What information does the Application obtain and how is it used?

User Provided Information

The Application obtains the information you provide when you download and register the Application. Registration with us is mandatory. You will not be able to use the features offered by the Application unless you register the device.

When you register with us and use the Application, you generally provide (a) your account holder number, identity number, cell phone number and personal identification number (PIN); (b) information you provide us when you contact us for help, and; (c) information you enter into our system when using the Application, such as contact information.

We may also use the information you provided us to contact your from time to time to provide you with important information, required notices and marketing promotions.

Identity Verification and Fraud Prevention

The Application utilises the Smile ID SDK, which incorporates the TrueDepth API on iOS devices to enhance the security and reliability of our user identity verification process. The TrueDepth API, through ARKit, enables the collection of facial data, including 3D spatial orientation and facial expressions, to confirm the presence of a live individual during verification. This process helps prevent fraudulent activities by ensuring that the person verifying their identity is physically present and matches the provided identification documents.

The facial data captured through the TrueDepth API is processed entirely on your device and is not transmitted to our servers or any third parties. This approach also aligns with Apple's privacy guidelines, which emphasises on-device processing to protect user data. By proceeding with the identity verification process, you consent to the use of ARKit for this purpose. You may withdraw your consent at any time by closing your account. We will refund any funds deposited to your bank account.

Automatically Collected Information

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application.

Does the Application collect precise real time location information of the device?

This Application does not collect precise information about the location of your mobile device without your permission.

Do third parties see and/or have access to information obtained by the Application?

Only aggregated, anonymized data is periodically transmitted to external services to help us improve the Application and our service. We will share your information with third parties only in the ways that are described in this privacy statement.

We may disclose User Provided and Automatically Collected Information:

as required by law, such as to comply with a subpoena, or similar legal process;
when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
if Intellimali PTY (LTD) is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

What are my opt-out rights?

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at [email protected].

Data Retention Policy, Managing Your Information

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. If you would like us to delete User Provided Data that you have provided via the Application, please contact us at [email protected] and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

Children

We do not use the Application to knowingly solicit data from or market to children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information from our files within a reasonable time.

Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Changes

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and informing you via email or text message. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes. You can check the history of this policy by clicking here.

Your Consent

By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing," means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in South Africa.

Use of ARKit and TrueDepth Camera Data

Our app uses Apple's ARKit and TrueDepth camera APIs to support identity verification and fraud prevention. These technologies enable real-time facial mapping and liveness detection, ensuring that the person verifying their identity is present and matches their provided documents.

What We Collect
We access facial data from the TrueDepth camera, including 3D depth information and facial expressions, solely for the purposes of:

Confirming the presence of a live user
Matching the user to their ID for verification
Preventing fraud and impersonation

Data Usage and Storage

No TrueDepth data is stored or transmitted to our servers or third parties.
All facial data is processed locally on the device and is discarded immediately after the verification session.
We do not use TrueDepth data for marketing, advertising, or analytics.

This data is used exclusively for enhancing the security and reliability of our identity verification process. Our use of this data fully complies with Apple's privacy and security standards.

Contact us

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at [email protected].

Last updated: 5th June 2025