Privacy Policy
1. INTRODUCTION
This Privacy Policy sets out how ALPHA PACK CANNA CLUB (PTY) LTD (“we”, “us”, or “our”) processes personal, operational, and health-related information. As a fully compliant, registered private entity operating in South Africa, we are committed to the highest standards of data integrity, member confidentiality, and transparency required by the Protection of Personal Information Act (POPIA), the Medicines and Related Substances Act (Act 101 of 1965), and global mobile application platform standards.
2. DATA COLLECTION & SPECIAL PERSONAL INFORMATION
We process information concerning your health, membership declarations, and mobile app usage. Health data is classified as “Special Personal Information” under Section 26 of POPIA.
- Consent: We process this data only with your explicit, informed consent provided during your private club or mobile app registration.
- Purpose: This information is collected solely for member verification, age compliance (21+), internal safety monitoring, and fulfilling member-specific allocations within the club space.
- Mobile App Data: In addition to membership data, the Alpha Pack mobile application collects:
- Account Details: Name, email, phone number, and delivery/physical address for club allocations (EFT/COD).
- Identifiers: We collect Device IDs and User IDs to manage your secure sessions and deliver push notifications.
- Usage Data: We track product interactions within the app to optimize our member catalog and lounge offerings.
3. THIRD-PARTY OPERATORS & APP SERVICE PROVIDERS
In terms of Section 21 of POPIA, we engage with verified third-party “Operators” (e.g., secure data hosting platforms, compliance infrastructure, or delivery networks).
- Binding Agreements: All Operators are subject to strict data processing contracts requiring them to maintain robust, medical-grade security safeguards.
- Breach Notification: In line with Section 21(2), any Operator who suspects an unauthorized data compromise must notify us immediately upon discovery. We manage all subsequent reporting protocols in strict accordance with Section 22 of POPIA.
- App Service Providers: We utilize trusted third-party Software Development Kits (SDKs) to enhance your mobile experience:
- OneSignal: Used to deliver essential membership updates, notifications, and club alerts via push notifications.
- Google AdMob & Facebook: Used for app analytics, performance tracking, and to provide relevant advertisements. These parties may collect device-level identifiers.
4. REGULATORY REPORTING & COMPLIANCE
As a compliant entity operating in a regulated sector, we maintain legal obligations that may supersede certain standard data deletion requests:
- Safety Reporting: We are required to track safety metrics and adverse events. This operational data may be retained in line with statutory frameworks.
- Traceability: We maintain strict distribution and allocation tracking records to ensure product traceability, safety, and recall capabilities within our private ecosystem.
5. DATA RETENTION & DE-IDENTIFICATION (SECTION 24)
- Retention: We retain member compliance records for the minimum period required by applicable South African laws, typically a minimum of 5 years.
- De-identification: You may request that your personal records be corrected or de-identified under Section 24 of POPIA. Upon a valid request, we will scrub all direct personal identifiers. Any remaining analytical data will be completely anonymized for internal safety and regulatory reporting.
6. SECURITY SAFEGUARDS
We implement enterprise-grade technical and organizational security measures, including:
- End-to-end encryption for sensitive data streams.
- Strict internal access controls limited solely to authorized compliance and administrative staff.
- Continuous security monitoring and regular system reviews.
7. APP TRACKING & ACCOUNT DELETION
- App Tracking: We comply fully with Apple’s App Tracking Transparency (ATT) framework. If you opt-in via the app prompt, we use device identifiers for analytics and advertising purposes. You can opt-out or modify your permissions at any time via your device’s iOS settings.
- Account Deletion: Members have the right to delete their accounts. You can request account and data deletion directly through the App Settings menu or by emailing customercare@alphapackcannabis.club. We will process your request within 7 days, subject to the legal regulatory retention requirements outlined in Section 5.
8. INFORMATION OFFICER & COMPLIANCE
For any queries regarding your data privacy, or to submit a Section 24 Request, please contact our designated Information Officer:
Name: Lonwabo Nyhonyha
SAHPRA License No: S2100014148
Email: customercare@alphapackcannabis.club
Physical Address: 34 Peter Place, Bryanston Ext 7, Johannesburg, Gauteng, 2060
