Responsible party: HOM (Pty) Ltd
Law: Protection of Personal Information Act 4 of 2013
Section 1

About this policy and who we are

Plain language: This policy explains what personal information HOM handles across its estate app, management tools, websites and service-provider services.

HOM (Pty) Ltd (“HOM”, “we”, “us”) operates a private estate intelligence platform in South Africa. This policy applies to homeowners, occupants and household members, estate managers and team members, service providers and applicants, website visitors, and people who communicate with us.

“Personal information” and “processing” have the meanings in the Protection of Personal Information Act 4 of 2013 (“POPIA”). This policy should be read with our Terms of Service and any notice shown when information is collected.

Section 2

When HOM or an estate decides how information is used

An estate, body corporate or homeowners association generally decides why its resident roll and estate-governance information is processed. For that information the estate is ordinarily the responsible party and HOM operates the platform on its instructions. Contact your estate manager first about the accuracy of an estate roll, levy standing, unit records or an estate decision.

HOM is a responsible party for information it uses for its own purposes, including account administration, supplier applications and vetting, marketplace operation, billing, support, product safety, communications and legal compliance. In some activities HOM and an estate may each have responsibilities under POPIA.

Section 3

Personal information we collect

Depending on how you use HOM, we may process:

  • Identity, account and estate details: name, email, telephone or WhatsApp number, role, estate, unit or erf number, household or joint-owner details, recipient groups, verification and onboarding status, levy standing and voting weight. Estate rolls may include an identity or registration number; the platform also uses verification information supplied during sign-in or onboarding.
  • Supplier and business details: company and trading name, registration, VAT and tax references, contact people, postal and physical addresses, website, service categories and areas, qualifications, insurance, identity and company documents, vetting status, rates, reviews, application declarations and signature records.
  • Bookings, marketplace and financial records: requests, quotes, appointments, invoices, transaction references, wallet and payout records, disputes, refunds and supplier banking details needed for EFT payouts. Payment-card details are entered with the relevant payment processor rather than stored by HOM.
  • Estate and governance activity: broadcasts, survey answers, polls, meeting eligibility, proxies, votes, attendance, documents, comments and audit records. For a survey marked anonymous, the platform does not attach member identity or unit number to the response; identified surveys do.
  • Content and communications: messages, support correspondence, reviews, recommendations, uploaded images, videos, voice notes, documents and their metadata.
  • Location: a supplier’s service or business location and, when the supplier enables location-based dispatch features, location coordinates and update time. The app may use a resident’s device location to show nearby providers.
  • Device and usage information: IP address, user agent, device or app information, sign-in and consent timestamps, notification token and preferences, delivery status, feature interactions, event and audit logs, and security or diagnostic information.
  • Information from others: estates and their managers, household invitees, people recommending a provider, public business sources such as Google Places and provider websites, and payment or communications providers.

Please do not upload information about another person unless you are authorised to do so and they have been appropriately informed.

Section 4

How and why we use information

We process information only where there is a lawful basis under POPIA, which may include performing a contract, complying with law, protecting a legitimate interest of HOM, an estate, a user or the public, carrying out an estate’s lawful instructions, or consent where consent is appropriate. We do not rely on blanket consent for every activity.

Purposes include verifying and administering accounts; linking members to an estate and household; providing chat, surveys, meetings, voting, broadcasts and management tools; listing and vetting suppliers; enabling bookings, quotes, reviews, payments and payouts; delivering support and transactional messages; preventing misuse and investigating disputes; keeping audit and consent records; producing estate and platform reporting; improving services; and meeting tax, accounting and other legal duties.

We use contact details for marketplace offers or other direct marketing in line with your preferences and applicable law. You can withdraw a marketing opt-in or object to direct marketing at any time using an unsubscribe method where provided, changing relevant preferences, or emailing popia@homio.co.za. Service and account messages may still be necessary.

Section 5

App permissions and notifications

The HOM app asks for permission only when a feature needs it. Camera or photo-library access lets you choose or take profile, service-request and chat images. Microphone access lets you record a voice note. Location access supports nearby-provider maps and location-based supplier dispatch. Notification permission allows push alerts; we store the push token and delivery preferences needed to address those alerts.

You can refuse or later disable a permission in your device settings. The related feature may then be unavailable. Selecting and uploading media sends that content to HOM’s hosted storage. Device operating systems and map services may independently process device or location information under their own terms.

Section 6

Who receives information

We disclose information only as reasonably needed for the purposes above, including to:

  • your estate, authorised estate managers and team members, according to their roles;
  • homeowners and suppliers involved in a request, quote, booking, review, message, dispute or transaction;
  • service providers supporting hosting and object storage (Replit and its infrastructure providers), email (Resend), SMS (BulkSMS), push notifications (Expo), mapping, geocoding and public business data (Google), and payment processing;
  • OpenAI or Anthropic where an authorised feature generates survey insights or questions, meeting content, or procurement assistance; and
  • professional advisers, auditors, regulators, courts, law-enforcement bodies or a purchaser of the business where lawfully required.

Service providers may process only the information needed for the service they perform. We do not sell personal information.

Section 7

Payments and banking information

Marketplace payments may be processed by PayGate, while supplier onboarding payments use PayFast. The checkout or payment notice will identify the processor that applies. The processor receives payment and transaction information under its own privacy terms. HOM receives transaction references, status, amount and reconciliation details, but does not store payment-card details.

For supplier EFT payouts, HOM processes account-holder, bank, account type, account number, branch and, where supplied, SWIFT details. Do not send banking details through ordinary chat or email unless specifically instructed through an approved process.

Section 8

Surveys, governance and assisted features

Survey creators choose whether a survey is anonymous or identified. Anonymous responses are stored without a member ID or unit number; the answer content itself may still identify someone if they type identifying details. Governance records may need to preserve eligibility, proxies, votes, notices, minutes and an audit trail so that an estate can administer and evidence a lawful process.

Some authorised tools send relevant text to AI service providers to suggest survey questions, summarise survey results, assist with meeting content or support procurement analysis. Outputs can be incomplete or inaccurate and are intended to assist, not replace, human decisions. Users should avoid including unnecessary personal or confidential information in prompts or free-text responses.

Section 9

Storage and international transfers

HOM and its service providers may host or process information outside South Africa. This can occur when we use international hosting, object-storage, email, SMS, push, mapping, payment or AI providers. Where POPIA applies to a cross-border transfer, we take steps appropriate to the circumstances, such as using a recipient subject to comparable protection, a binding agreement, another permitted safeguard, or consent where legally required.

Section 10

How long we keep information

We retain personal information only for as long as reasonably needed for the purpose for which it was collected, an estate’s documented instructions, dispute or audit needs, and tax, accounting, governance or other legal obligations. Retention therefore differs by record type and context.

When information is no longer required, we delete, de-identify or restrict it as appropriate. Account closure or an estate ending its subscription does not always require immediate deletion: transaction, governance, consent, fraud-prevention, backup or legal records may need to remain for a lawful period. We do not claim that every category is removed by an automatic deletion job.

Section 11

Your choices and POPIA rights

Subject to POPIA and any lawful limitation, you may ask whether we hold your information, request access, ask us to correct or delete information, object to certain processing, request restriction where appropriate, or withdraw consent where processing actually relies on consent. You may also object to direct marketing at any time.

Practical access, correction or deletion request
Email popia@homio.co.za with your full name, the email or mobile number used for HOM, your estate and unit (if applicable), whether you are a resident, manager or supplier, and what you want accessed, corrected or deleted. If the request concerns estate-roll or governance data, you may also contact your estate manager. We may ask for enough information to verify your identity and authority before acting. We will explain if law or another person’s rights prevent us from fulfilling all or part of a request.

There is no need to use an in-app deletion feature. A clear email request is sufficient to begin the review. Requests are handled within the periods required by applicable law; this policy does not promise a fixed turnaround where the law does not set one.

Section 12

Children

HOM accounts and supplier applications are intended for people aged 18 or older. The platform is not directed to children. An estate or household user should not add a child’s personal information unless there is a lawful reason and the competent person or another lawful basis permits it. If you believe a child’s information was provided improperly, contact popia@homio.co.za.

Section 13

Security, incidents and policy changes

HOM uses reasonable technical and organisational measures appropriate to the information and risks involved, including access controls, audit records and safeguards used by our hosting and service providers. No internet service is completely secure, and this policy does not guarantee that an incident cannot occur.

If personal information is accessed or acquired by an unauthorised person, we will investigate and give notices to the Information Regulator and affected data subjects as required by POPIA, taking account of lawful grounds for any delay.

We may update this policy as services, providers or law change. We will post the current version here and change the effective date. Where a change materially affects how we use information or your rights, we will provide an appropriate additional notice.

Section 14

Contact us or lodge a complaint

For privacy questions, rights requests, objections or deletion requests, contact HOM’s Information Officer function at popia@homio.co.za. General enquiries may be sent to hello@homio.co.za.

You may lodge a complaint with South Africa’s Information Regulator. Current complaint forms and contact channels are available at inforegulator.org.za. You do not have to contact HOM before approaching the Regulator, although we welcome the opportunity to address your concern.