Last Updated: 2 February 2026

1. INTRODUCTION 1.1. The Messenger Network (Pty) Ltd (“TMN”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal information. 1.2. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, the Wati platform (resold by TMN), and our associated services (collectively, the “Services”). 1.3. This Policy is drafted in compliance with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and, where applicable, the Consumer Protection Act 68 of 2008 (“CPA”).
2. DEFINITIONS For the purposes of this Policy: 2.1. “Personal Information” means information relating to an identified or identifiable natural or juristic person, as defined in POPIA (e.g., names, email addresses, phone numbers). 2.2. “Responsible Party” means the entity that determines the purpose and means for processing Personal Information (in many cases, You, the Client). 2.3. “Operator” means the entity that processes Personal Information on behalf of the Responsible Party ( TMN and its sub-processors like Wati/Clare.AI). 2.4. “Client” or “Subscriber” means the business entity contracting with TMN.
3. INFORMATION WE COLLECT We collect information to provide, improve, and secure our Services. 3.1. Information You Provide:

• Account Data: Company name, business address, VAT number, and billing details.
• User Data: Names, email addresses, and phone numbers of your team members (Administrative Users).
• End User Data: Content of messages, contacts, and media you upload or transmit via the WhatsApp Business API. 3.2. Automatically Collected Information:
• Usage Data: Log files, IP addresses, browser type, and operating system.
• Cookies: We use cookies to manage sessions, remember preferences, and analyze traffic.

4. HOW WE USE YOUR INFORMATION We use your Personal Information for the following purposes: 4.1. Service Delivery: To provision your WhatsApp Business account, manage subscriptions, and facilitate messaging. 4.2. Billing: To process payments and send invoices. 4.3. Communication: To send you service alerts, updates, and security notifications. 4.4. Legal Compliance: To comply with South African laws (e.g., RICA, SARS requirements) and enforce our Terms and Conditions. 4.5. Improvement: To analyze usage trends and improve the performance of the Platform.
5. DISCLOSURE OF INFORMATION We do not sell your Personal Information. We may share it with: 5.1. Service Providers: Specifically Clare.AI Limited (Wati), who operates the core platform infrastructure. We also use payment gateways (e.g., PayFast, Stripe) and cloud hosting providers. 5.2. Legal Authorities: If required by a subpoena, court order, or other legal process under South African law. 5.3. Business Transfers: In connection with a merger, sale of assets, or acquisition of all or a portion of our business.
6. CROSS-BORDER DATA TRANSFER 6.1. You acknowledge that TMN resells the Wati platform, which is hosted internationally. Therefore, Personal Information (including End User Data) may be transferred to and stored in countries outside of South Africa (e.g., Hong Kong, USA). 6.2. We ensure that such transfers comply with POPIA Section 72, typically by relying on binding agreements that uphold principles substantially similar to POPIA.
7. YOUR RIGHTS (POPIA) Under POPIA, you have the right to: 7.1. Access: Request a copy of the personal information we hold about you. 7.2. Correction: Request correction or deletion of inaccurate, irrelevant, excessive, or unlawfully processed information. 7.3. Objection: Object to the processing of your personal information in certain circumstances. 7.4. Complaint: Lodge a complaint with the Information Regulator (South Africa) if you believe we are interfering with your protection of personal information.

• Website: https://inforegulator.org.za/
• Email: POPIAComplaints@inforegulator.org.za

8. DATA SECURITY 8.1. We implement reasonable technical and organizational measures to protect your Personal Information against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure. 8.2. However, no internet transmission is 100% secure. You are responsible for securing your login credentials and the Personal Information of your own customers (“Data Subjects”).
9. DATA RETENTION 9.1. We retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law (e.g., tax records for 5 years). 9.2. Upon termination of your subscription, your data may be deleted from our active systems after a grace period, subject to our backup retention policies.
10. DIRECT MARKETING 10.1. We may send you marketing communications regarding our services. 10.2. In accordance with POPIA Section 69, we will only send electronic direct marketing to you if you are an existing customer or if you have consented (opted-in). You may opt-out at any time via the “Unsubscribe” link in our emails.
11. INFORMATION OFFICER If you have questions about this Policy or wish to exercise your rights under POPIA, please contact our Information Officer:

Information Officer: Xander Barnard Email: info@themessengernetwork.co.za               Phone: 2710 446 5788 Address: Corporate Park North, Parkhaven, Boksburg, 1459

12. CHANGES TO THIS POLICY We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Policy on our website and updating the “Last Updated” date.