Privacy Policy
GovernX · AIR Service · Effective date: 8 August 2026 · Version 1.0
1. Who We Are
GovernX ("we", "us", "our") operates the AIR service — an AI-powered WhatsApp lead-response platform for South African estate agents. This Privacy Policy explains how we collect, use, store, and protect personal information in compliance with the Protection of Personal Information Act, 4 of 2013 (POPIA).
2. Personal Information We Collect
We collect personal information only to the extent necessary to provide the AIR service.
2.1 From estate agents (subscribers)
- Identity: Full name, email address
- Contact: WhatsApp-linked phone number
- Billing: Payment status and subscription dates (we do not store card numbers — payments are processed by iKhokha)
- Usage data: Listing details you enter, viewing appointments, conversation logs between the AIR bot and your leads
2.2 From property leads (buyers / renters)
- Contact: WhatsApp phone number
- Communications: Messages exchanged with the AIR bot on behalf of your agent account
- Appointments: Name and scheduled viewing times where provided in conversation
2.3 Automatically collected
- Server logs (IP address, request timestamps, HTTP status codes) retained for 30 days for security purposes
- Application performance data via Azure Application Insights (anonymised telemetry)
3. Why We Collect Personal Information
| Purpose | Information used |
|---|
| Creating and managing your agent account | Name, email |
| Delivering the WhatsApp AI-response service | WhatsApp number, listing data, buyer messages |
| Processing subscription payments and enforcing billing | Email, subscription status, payment transaction IDs |
| Sending transactional emails (trial reminders, payment confirmations, expiry notices) | Name, email, subscription dates |
| Scheduling property viewings on your behalf | Buyer name, phone, preferred time |
| Security monitoring and fraud prevention | Server logs, request metadata |
| Improving the service | Aggregated, anonymised usage statistics |
4. Legal Basis for Processing
We process personal information on the following grounds under POPIA:
- Contract: Processing is necessary to perform your subscription agreement with us (agent account, billing, service delivery)
- Legitimate interest: Security monitoring, fraud prevention, service improvement
- Consent: Where we send marketing communications (you may opt out at any time)
- Legal obligation: Retaining financial records as required by South African law
Property leads (buyers) communicate with the AIR bot through your WhatsApp account. As a subscriber, you are responsible for ensuring that your use of AIR complies with applicable laws in your dealings with leads, including disclosing that an AI assistant may respond on your behalf.
5. Who We Share Personal Information With
We do not sell personal information. We share it only with the following third-party processors, under written agreements, to deliver the service:
| Processor | Purpose | Location |
|---|
| Microsoft Azure (App Service, PostgreSQL, Communication Services) | Hosting, database, transactional email | South Africa North / West Europe |
| Azure OpenAI Service (Microsoft) | AI-generated WhatsApp responses | West Europe |
| iKhokha | Payment processing | South Africa |
| WhatsApp / Meta | Message delivery via the Baileys WhatsApp Web API | Global |
We may disclose personal information where required by law, court order, or a regulatory authority with jurisdiction.
6. Cross-border Transfers
Some processing occurs outside South Africa, primarily on Microsoft Azure infrastructure in West Europe. These transfers take place under Microsoft's standard contractual clauses and data processing addenda, which provide equivalent protection to POPIA requirements.
7. Retention of Personal Information
| Category | Retention period |
|---|
| Agent account data (name, email) | Duration of subscription + 12 months after cancellation |
| Billing and transaction records | 5 years (as required by the Companies Act and SARS requirements) |
| WhatsApp chat transcripts | Duration of subscription + 12 months |
| Viewing appointments | 12 months from the appointment date |
| Server / access logs | 30 days |
| Application telemetry (anonymised) | 90 days |
When retention periods expire, personal information is securely deleted or anonymised.
8. Your Rights as a Data Subject
Under POPIA you have the right to:
- Access: Request a copy of the personal information we hold about you
- Correction: Request correction of inaccurate or incomplete information
- Deletion: Request deletion of your personal information (subject to legal retention obligations)
- Objection: Object to processing based on legitimate interest
- Withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior processing
- Lodge a complaint: Complain to the Information Regulator if you believe we have violated your rights
To exercise any right, contact our Information Officer using the contact form on this page. We will respond within 30 days.
Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
inforeg@justice.gov.za · +27 (0)10 023 5207
9. Cookies and Tracking
The AIR web application stores your agent ID in your browser's local storage solely to remember your session across visits. We do not use advertising cookies or third-party tracking pixels. Azure Application Insights may set session cookies for performance monitoring; this data is anonymised before any analysis.
10. Security
We implement appropriate technical and organisational measures to protect personal information, including:
- Encrypted connections (HTTPS/TLS) on all endpoints
- Encrypted data at rest on Azure infrastructure
- HMAC-SHA256 signature verification on all payment webhooks
- API keys and credentials stored as environment variables — never in code or logs
- Rate limiting on all public endpoints to prevent abuse
- Database access restricted to the application's private network
No method of transmission over the internet is completely secure. In the event of a data breach that is likely to prejudice you, we will notify you and the Information Regulator as required by POPIA.
11. Children
The AIR service is intended for professional estate agents. We do not knowingly collect personal information from persons under 18 years of age. If you believe a minor has submitted personal information to us, contact us immediately.
12. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will update the effective date at the top of this page and, where changes are material, notify registered agents by email at least 14 days before they take effect. Continued use of the service after the effective date constitutes acceptance of the revised policy.
PAIA Manual
Section 51 Manual — Promotion of Access to Information Act, 2 of 2000 · GovernX · Version 1.0 · 8 August 2026
This manual is published in compliance with Section 51 of the Promotion of Access to Information Act, 2 of 2000 (PAIA). PAIA gives effect to the constitutional right of access to information held by private bodies where such access is required for the exercise or protection of any right.
1. Introduction
PAIA requires every private body to compile a manual setting out the records it holds, how the public may request access to those records, and the grounds on which access may be refused. This manual applies to GovernX and all records held in connection with the AIR service.
2. About GovernX
Trading name: GovernX
Service: AIR — AI WhatsApp Lead Responder for South African Estate Agents
Nature of business: Software as a Service (SaaS) — artificial intelligence-powered WhatsApp automation for property rental agents
3. Information Officer
The Information Officer is responsible for encouraging compliance with PAIA, dealing with requests for access to records, and acting as the point of contact between GovernX and the Information Regulator.
4. Guide on How to Use PAIA
The South African Human Rights Commission (SAHRC) has published a guide on how to use PAIA, as required by section 10 of PAIA. This guide is available from the SAHRC:
South African Human Rights Commission
The Research and Documentation Department
Private Bag 2700, Houghton, 2041
Tel: +27 (0)11 877 3600 ·
www.sahrc.org.za
5. Records Available Without a PAIA Request
The following records are publicly available without a formal PAIA request:
- This PAIA Manual (available at /legal.html)
- Privacy Policy
- Cancellation Policy
- Service pricing information
6. Records Held by GovernX
GovernX holds the following categories of records:
6.1 Subscriber records
- Agent registration data (name, email address)
- Subscription and billing records (plan type, payment status, subscription dates)
- Payment transaction IDs (no card data — processed and held by iKhokha)
- WhatsApp session authentication data
6.2 Operational records
- Property listings entered by subscribers
- WhatsApp chat transcripts between the AIR bot and property leads
- Scheduled property viewing appointments
- Cold lead / prospecting records (scraped from public property portals)
6.3 Technical and security records
- Server access logs (IP address, request timestamps, HTTP status codes)
- Application performance telemetry (anonymised)
- System configuration and environment settings (secrets excluded)
6.4 Corporate and governance records
- Business correspondence
- Contracts and agreements with third-party processors
- Financial records
7. How to Submit a PAIA Request
A request for access to records must be made on PAIA Form C, which is available from the SAHRC or the Department of Justice and Constitutional Development.
Completed requests must be submitted to the Information Officer:
Your request must include:
- Your full name and contact details
- A description of the records you are requesting
- Your preferred form of access (electronic copy, inspection, etc.)
- Proof of identity (certified copy of ID)
- If requesting information on behalf of another person, proof of authorisation
- The right you are seeking to exercise or protect, and why access is required
8. Fees
A request fee of R50.00 (non-refundable) is payable before a request is processed, as prescribed by the Promotion of Access to Information Act Regulations.
If the request is granted, access fees are charged at the rates prescribed in the PAIA Regulations, which are available from the Department of Justice and Constitutional Development.
Where a requester is a personal requester seeking their own personal information, no request fee is charged.
9. Grounds for Refusal
GovernX may refuse a request for access to records on the following grounds, as set out in PAIA:
- Mandatory protection of privacy of a third party (sections 63–64)
- Mandatory protection of commercial information of a third party (section 65)
- Mandatory protection of certain confidential information of a third party (section 66)
- Mandatory protection of safety of individuals and property (section 67)
- Mandatory protection of records privileged from production in legal proceedings (section 67)
- Commercial information of the private body itself (section 68)
- Research information of the private body (section 69)
- The record does not exist or cannot be found (section 23)
10. Remedies if a Request is Refused
If your request is refused (or you receive no response within 30 days, which is deemed a refusal), you may:
- Apply to court for relief under section 78 of PAIA
- Complain to the Information Regulator under section 74 of POPIA
Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
inforeg@justice.gov.za · +27 (0)10 023 5207
Cancellation Policy
GovernX · AIR Service · Effective date: 8 August 2026 · Version 1.0
1. Overview
GovernX offers two subscription plans for the AIR service. Cancellation terms differ by plan. Please read the terms applicable to your plan before requesting cancellation.
Month-to-Month
R499 / month
2. Month-to-Month Plan
2.1 Notice period
Cancellation of a month-to-month subscription requires a minimum of one (1) full calendar month's written notice, submitted to GovernX before the start of the next billing period.
Example: If your billing date is the 1st of each month and you submit written notice on 15 October, your subscription continues through November (the full notice month) and terminates on 30 November. You will not be charged from 1 December.
2.2 Access during notice period
You retain full access to the AIR service throughout the notice period. Your WhatsApp session remains active and the service continues to respond to your leads.
2.3 Refunds
No refunds are issued for partial months or unused days within a paid period. All subscription fees are charged and earned at the start of each billing cycle.
Month-to-month summary: Submit written notice at least 1 month before your next billing date. Full access continues through the notice period. No partial refunds.
3. Annual Plan
3.1 No refunds
Annual subscriptions are non-refundable. When you subscribe to an annual plan, the full annual fee is charged at the start of the subscription period. No refunds — partial or full — are issued if you cancel before the end of the annual term.
3.2 Access for the full annual term
If you cancel an annual subscription, you will continue to have access to the AIR service for the full remainder of your paid annual term. Your WhatsApp session will remain active and fully functional until the final day of your paid period.
Example: If your annual subscription was activated on 1 March 2026 and you request cancellation on 1 August 2026, you retain full access until 28 February 2027. No further charges will be made after that date.
3.3 Non-renewal
Cancellation of an annual plan means your subscription will not renew at the end of the annual term. You will receive a renewal reminder email approximately 7 days before your term ends. You are not required to give advance notice — simply do not pay the renewal invoice.
Annual plan summary: No refunds under any circumstances. You keep full access for the remainder of the paid year. No automatic renewal without payment.
4. Effect of Cancellation
When your subscription ends (at the close of the notice period for monthly, or at the end of the annual term):
- Your WhatsApp session will be deactivated and the AIR bot will stop responding to leads
- You will no longer be able to add or manage listings through the platform
- Your account data (chat history, viewings, listings) will be retained for 12 months in accordance with our Privacy Policy, after which it will be securely deleted
- You may request a data export before the retention period expires by contacting us
5. How to Cancel
To cancel your subscription, send a written cancellation request by email:
Please include in your message:
- The email address registered to your account
- Your plan type (monthly or annual)
- Your intended cancellation date (monthly subscribers)
We will confirm receipt and your cancellation date within 2 business days. A cancellation is not effective until you receive written confirmation from GovernX.
6. Reactivation
You may reactivate a cancelled account at any time by subscribing again at the then-current pricing. If your account data has not yet been deleted under the retention schedule, your previous listings and chat history will be restored. No setup fee applies.
7. Price and Plan Changes
GovernX reserves the right to change subscription pricing. For month-to-month subscribers, at least 30 days' advance notice of a price increase will be given by email before the change takes effect. For annual subscribers, price changes apply only upon renewal — your locked-in annual rate will not change during your paid term.
For any questions about this policy, your subscription, or the cancellation process: