1. INTRODUCTION
FusionSplice (“FusionSplice”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your Personal Information in compliance with the Protection of Personal Information Act, 4 of 2013 (“POPIA”), and all applicable South African data‑protection laws.
This Privacy Policy explains:
a) What Personal Information we collect;
b) How we collect it;
c) How and why, we use it;
d) Our lawful basis for processing;
e) When and how we share it;
f) Cross‑border transfers;
g) Retention and deletion;
h) Your POPIA rights; and
i) How to exercise those rights.
By using FusionSplice.ai or any related services, you agree to this Privacy Policy.
2. DEFINITIONS
Definitions follow POPIA and include:
a) “Personal Information”: information relating to an identifiable natural or juristic person.
b) “Special Personal Information”: information relating to beliefs, race, health, biometrics, etc.
c) “Data Subject”: the person to whom Personal Information relates.
d) “Processing”: any operation involving Personal Information.
e) “Responsible Party”: the party determining the purpose and means of processing.
f) “Operator”: a third party who processes information for a Responsible Party in terms of a contract.
3. RESPONSIBLE PARTY INFORMATION
FusionSplice (Pty) Ltd
Registration Number: 2025/023693/07
Principal Place of Business: Studio 012, Unit B5, One Highveld, 5 Bellingham Street, Highveld, Centurion, Gauteng, South Africa, 0157
Information Officer Email: info@fusionsplice.ai
FusionSplice is the Responsible Party in terms of POPIA.
4. PERSONAL INFORMATION WE COLLECT
We may collect:
a) Identity Information (name, surname, ID verification if required)
b) Contact Information (email, mobile number, address)
c) Financial/Transactional Information (via secure third‑party gateways)
d) Usage and Technical Data (IP address, device, browser, logs, geolocation)
e) Cookies & Tracking Data
f) User‑Generated Content (reviews, uploads, posts)
g) AI‑Related Data (inputs and outputs submitted through AI features)
We do not intentionally collect Special Personal Information unless required by law or with explicit consent.
5. HOW WE COLLECT INFORMATION
We collect data:
5.1 Directly from you (account creation, payments, uploads, support)
5.2 Automatically (cookies, analytics tools, logs)
5.3 From Third Parties (payment providers, verification providers, public sources)
Cookies may be disabled but some features may not function correctly.
6. LEGAL BASIS FOR PROCESSING
We process information under the following POPIA grounds:
a) Consent
b) Contract performance
c) Compliance with law
d) Legitimate interests of Fusion Splice or the data subject
e) Protection of vital or legitimate interests
7. PURPOSES FOR PROCESSING
We process Personal Information to:
a) Verify identity and eligibility
b) Create and manage accounts
c) Provide platform services and content access
d) Communicate updates, purchases, or policy changes
e) Process payments and prevent fraud
f) Improve platform functionality and user experience
g) Conduct analytics and behavioural profiling (explained below)
h) Comply with legal obligations
i) Perform internal reporting and optimisation
j) Conduct direct marketing (with consent or existing‑customer exemption)
8. OPERATOR OBLIGATIONS
We use Operators to assist with processing (hosting, analytics, payment gateways, AI tools, communication services).
All Operators are required to:
a) Sign POPIA‑compliant Operator Agreements;
b) Maintain confidentiality and security safeguards;
c) Process only on our documented instructions;
d) Notify us immediately of any suspected breach.
FusionSplice remains ultimately responsible for lawful processing.
9. DISCLOSURE TO THIRD PARTIES
We may share information with:
a) Payment processors
b) Cloud hosting providers
c) Email/SMS communication service providers
d) Analytics and security partners
e) AI‑processing vendors (with human oversight)
f) Legal, regulatory, or government authorities
All Operators follow POPIA‑compliant safeguards.
10. CROSS‑BORDER TRANSFERS
Personal Information may be stored or processed outside South Africa.
Cross‑border transfers comply with POPIA s72 and are allowed only when:
a) The recipient jurisdiction has adequate data‑protection laws; or
b) Contractual safeguards ensure POPIA‑equivalent protection; or
c) You give explicit consent; or
d) Transfer is necessary to perform a contract.
11. RETENTION & DELETION
Information is retained:
a) While your account is active;
b) For 30 days after account closure unless law requires longer;
c) As required for tax, accounting, or legal compliance.
d) Data no longer required is securely deleted or de‑identified.
12. SECURITY SAFEGUARDS
Technical safeguards include:
a) SSL encryption
b) Access controls
c) Firewalls
d) Secure servers
e) Routine vulnerability testing
Organisational safeguards include:
a) Limited personnel access
b) Confidentiality undertakings
c) POPIA‑compliant security policies
d) Operator oversight
12.1 Detailed Data Breach Notification Process
In the event of a data breach, FusionSplice will:
a) Notify affected Data Subjects as soon as reasonably possible;
b) Notify the Information Regulator as required by POPIA;
c) Provide details of the nature of the breach, categories of data affected, consequences, remedial actions, and recommended mitigation steps for individuals.
13. COOKIES & TRACKING TECHNOLOGIES
Cookies may be used for:
a) Authentication
b) Remembering preferences
c) Improving performance
d) Security and fraud detection
• Analytics and behavioural pattern analysis
Users may manage cookies through browser settings.
14. BEHAVIOURAL PROFILING & ANALYTICS
FusionSplice may analyse aggregated or pseudonymized user behavior to:
a. Understand learning patterns
b. Improve content relevance
c. Detect fraudulent or suspicious behaviour
d. Enhance platform performance
Such profiling does NOT produce decisions with legal or significant effects.
15. DIRECT MARKETING
Direct marketing occurs:
a. Only with consent, or
b. For existing customers (related services only)
Opt‑out at any time via unsubscribe link or email to info@fusionsplice.ai.
16. CHILDREN’S INFORMATION
FusionSplice does not knowingly process information of children under 13 without competent‑person consent.
If collected unintentionally, information will be deleted upon discovery.
17. YOUR RIGHTS UNDER POPIA
You may:
a. Request access to your Personal Information
b. Request correction or deletion
c. Object to processing
d. Withdraw consent
e. Restrict processing
f. Lodge a complaint with the Information Regulator
g. Institute civil action for breaches
18. HOW TO EXERCISE YOUR RIGHTS
Submit requests to: info@fusionsplice.ai
We respond within 30 days unless extension is permitted.
Information Regulator:
POPIAComplaints@inforegulator.org.za
19. THIRD‑PARTY WEBSITES
FusionSplice is not responsible for third‑party content or their privacy practices.
20. AUTOMATED DECISION‑MAKING & AI
FusionSplice may use AI tools, but:
a. AI does not make decisions with legal or significant effects on you without human review.
b. AI processing complies with this Privacy Policy.
21. PAIA MANUAL REFERENCE
FusionSplice’s PAIA Manual, prepared under the Promotion of Access to Information Act, is available on request or via our website.
It explains records held and how Data Subjects may request access.
22. CHANGES TO THIS POLICY
We may update this Privacy Policy periodically.
Revised versions take effect upon publication.
23. CONTACT DETAILS
Information Officer
Email: info@fusionsplice.ai