Privacy Policy

1. Two different roles

It matters which hat we're wearing.

This policy covers the first. The second is governed by your service agreement.

2. What we collect

3. Why we process it

• To respond to your enquiry and provide a quotation
• To deliver the services you've engaged us for
• To invoice you and collect payment
• To communicate with you about your services
• To send you information about our services, where you have consented or where we have a legitimate interest and you have not objected
• To improve this website and our services
• To comply with our legal and tax obligations

4. Lawful basis

We process personal information where it is necessary to conclude or perform a contract with you, where we are legally obliged to, where we have your consent, or where it serves a legitimate interest that does not override your rights.

5. Who we share it with

We do not sell personal information. We share it only with service providers who help us operate:

We may also disclose information where required by law, or to professional advisers under confidentiality.

6. Transfers outside South Africa

Some of the providers above process information outside South Africa, principally in the United States and the European Union. Where information is transferred cross-border, we do so in accordance with section 72 of POPIA — relying on the recipient being subject to binding rules or an agreement providing an adequate level of protection, or on your consent where applicable.

7. How long we keep it

• Enquiries that don't become clients: 24 months, then deleted
• Client records: for the duration of the relationship and 5 years afterwards, to meet tax and record-keeping obligations
• Financial records: 5 years, as required by law
• WhatsApp conversation history: 12 months

8. Security

We apply reasonable technical and organisational safeguards: access controls and multi-factor authentication on all systems, encrypted transmission, restricted access on a need-to-know basis, and vetting of the service providers we use. No system is perfectly secure, but we take this seriously and we will notify you and the Information Regulator of any breach affecting your information, as POPIA requires.

9. Your rights

Under POPIA you may:

• Ask what personal information we hold about you
• Ask us to correct or delete information that is inaccurate, irrelevant, excessive, out of date or unlawfully obtained
• Object to processing, on reasonable grounds
• Withdraw consent, where processing is based on consent
• Unsubscribe from marketing at any time — every message includes an opt-out
• Complain to the Information Regulator

To exercise any of these, email hello@smartgrowthlocal.com. We respond within 30 days. There is no charge, except a prescribed fee for certain access requests.

10. Cookies

This site uses cookies that are necessary for it to function. You can block or delete cookies in your browser settings; the site will still work, though some parts may not behave as expected.

11. Complaints

If you're unhappy with how we've handled your information, please contact us first — we'd rather fix it. You also have the right to complain to:

12. Changes

We may update this policy from time to time. The current version is always at /privacy/, with the date of last update at the top.