Privacy Policy

Service: Gentle Wellness, a free wellness newsletter for South African adults aged 60 and over.

Responsible party: Gentle Wellness

Address: Protea Valley, Cape Town, 7530, South Africa

General enquiries: support@gentlewellness.co.za

Privacy and data requests: privacy@gentlewellness.co.za

What you give us

Your email address

Required. It is the only thing you have to give us in order to subscribe.

Which version of our sign-up page you used

We record whether a subscription came from the page written for the person doing the activities, or the page written for someone signing up a parent. We use it to understand which explanation works better. It is not used to treat you differently.

Feedback, if you send it

Every newsletter has feedback links. If you use them we record:

• whether you found the activities too easy, about right, or too hard
• anything you type into the comment box
• which edition of the newsletter you were responding to

What we record automatically

Whether you opened an email, and what you clicked

Each newsletter contains a small invisible image. When your email program loads it, we record that the email was opened. When you click through to an activity, we record which activity it was.

This is recorded against you individually, not just as a total. We are telling you plainly because a policy that called this “anonymous analytics” would be misleading. We use it to see which activities people actually do, and to stop sending to addresses that never open anything.

Your IP address, briefly

Our servers see your IP address when you visit the website, and we use it to limit how many times the same visitor can submit a form. We also pass it to a bot-checking service when you submit feedback (see section 6). We do not build a profile from it.

What we do not collect

• Your name, unless you type it into a comment
• Your phone number
• Your home address
• Payment details — the service is free and we have no way to take money
• Health or medical information
• Identity or passport numbers

We let people sign up a parent or relative, because for many families that is the only realistic way this reaches the person it is meant for. If someone gave us your address, this section is the important one for you.

What we tell you, and when

POPIA section 18 says that when we get your information from someone other than you, we have to tell you. That confirmation email does exactly that: it says what we hold (your email address), that somebody asked us to send you the newsletter, what we will send, and how to refuse.

What the person who signed you up can see

• Whether you confirmed
• Whether you opened anything
• Which activities you tried
• Anything you write in feedback

Nothing is reported back to them. This is a newsletter, not a monitoring service. If they want to know how you are getting on, they have to ask you.

If you did not want this

Ignore the confirmation email and nothing happens. If you would rather we deleted the record immediately, or you want to know who entered your address, email privacy@gentlewellness.co.za and we will tell you and remove it.

If you are the one signing someone up

You are telling us you have their permission to give us their address. Please actually ask them first — they will get an email from us either way, and it is a much better email to receive if they are expecting it.

Sending the newsletter

• Three emails a week: Monday, Wednesday and Friday mornings
• A confirmation email when you first subscribe
• Occasional service notices, such as a change to this policy

Working out what to send

• Seeing which activities get opened and clicked, and sending more of what works
• Reading feedback about whether activities are pitched at the right level
• Noticing addresses that never open anything, so we can stop emailing them

Writing the words

We use an automated writing tool to draft each newsletter's subject line and its opening and closing paragraphs, working from the wellness activities we have chosen for that day.

What we never do

• Sell, rent or trade your information
• Use it for advertising, ours or anyone else's
• Pass it to marketers
• Use it for anything not described in this policy

Legal obligations

We may use or disclose your information where South African law requires it, in response to a valid legal process, or to protect our rights and prevent abuse of the service.

Consent

We rely on your consent, which you give by confirming your subscription. You can withdraw it at any time by unsubscribing, and every email we send carries the link. Withdrawing consent does not affect anything we did before you withdrew it.

Direct marketing

POPIA section 69 and the Electronic Communications and Transactions Act govern unsolicited electronic messages. We only email people who have confirmed their own subscription, every message identifies us and carries a one-click unsubscribe, and we never pass addresses to anyone else for their own marketing.

Legitimate interest

We rely on legitimate interest for a narrow set of things: keeping the service running, preventing abuse of our forms, and measuring whether the newsletter is worth sending. You can object to this — see section 11.

Suppliers who process it for us

We use a small number of suppliers to run the service. We describe them by what they do rather than by name, so that this policy stays accurate if we change supplier. Each is bound to use your information only for what we have asked them to do.

Want the actual names? Ask. Email privacy@gentlewellness.co.za and we will tell you exactly who we are using and where they are, as at the date you ask.

Legal disclosure

We may disclose your information where:

• South African law requires it
• we receive a valid court order or similar legal process
• it is necessary to protect our rights or prevent fraud
• you have asked us to

Your subscriber record is stored in South Africa. Some processing happens outside the country, as set out in section 6:

• Email delivery is handled from the European Union, which has data protection law comparable to POPIA.
• Bot checking on the feedback form passes your IP address to a provider operating internationally.
• Newsletter wording is drafted by a provider operating internationally, which receives no personal information.

POPIA Chapter 9 allows these transfers where the recipient is subject to comparable protection or is bound by contract to protect the information. We do not transfer your information anywhere else without telling you.

POPIA section 14 says we must not keep personal information longer than we need it. This is what we hold and for how long.

What we do

• The whole site is served over an encrypted connection (HTTPS)
• The database is not reachable from the public internet
• Administrative pages require a login, and are not linked from the public site
• Only the people who run the service can reach subscriber data
• Administrative logins and data exports are logged
• We keep the software and its dependencies up to date

What we are honest about

What we never do

• Sell your email address
• Share your information with marketers
• Send you things you did not ask for
• Use your data for anything outside this policy

POPIA section 22 requires us to act if personal information is accessed by someone who should not have it. If that happens:

• We notify the Information Regulator as soon as reasonably possible after establishing what happened.
• We notify you directly, by email to the address we hold for you, unless the Regulator or the law tells us to delay in order not to hinder an investigation.
• We tell you what information was involved, what we believe the consequences are, what we are doing about it, and what you can do to protect yourself.
• We publish a notice on this website if we cannot reach affected people individually.

If you think something has gone wrong — you have had a strange email that appears to be from us, for instance — please tell us at privacy@gentlewellness.co.za. We would much rather investigate a false alarm than miss a real one.

These rights are free to exercise. Email privacy@gentlewellness.co.za and we will respond within 30 days. We may ask you to confirm you control the email address in question, which is usually just a reply from it.

Ask what we hold about you

We will send you everything: your record, the newsletters we sent you, what you opened and clicked, and any feedback you gave. Formal access requests are handled under the Promotion of Access to Information Act.

Correct something that is wrong

Tell us and we will fix it. To change your address, unsubscribe the old one and subscribe the new one, or ask us and we will move it.

Have it deleted

Ask, and we permanently delete your record together with your delivery history, opens, clicks and feedback, within 30 days. This is not the same as unsubscribing, which stops the emails but keeps the record.

Object to how we use it

You can object to processing we base on legitimate interest. POPIA provides a prescribed form for this, which we will send you on request — but an email saying what you object to is enough for us to act on.

Get a copy you can take elsewhere

We will send your information as a CSV or JSON file.

Complain

Please try us first — most things are a misunderstanding we can fix the same day. If we do not resolve it, you may complain to the Information Regulator:

What happens then

1. You stop receiving newsletters immediately.
2. We show you a page confirming it. We do not send a follow-up email.
3. Your record is marked as unsubscribed and kept for 30 days, in case you did it by accident and want to come back.
4. After 30 days your email address is replaced automatically, as described in section 8.
5. If you would rather it went sooner, email privacy@gentlewellness.co.za and we erase it outright, usually the same week.

Gentle Wellness is written for adults aged 60 and over, and you must be 18 or older to subscribe. We do not knowingly collect information from children.

If you believe a child has subscribed, tell us at privacy@gentlewellness.co.za and we will delete the record.

On the website

The public pages of this website do not set advertising or analytics cookies. There is no Google Analytics, no advertising network and no cross-site tracking. You do not need to accept a cookie banner here because there is nothing to accept.

The bot check on the feedback form is provided by an outside supplier and may set its own cookie in order to tell a person from a script. The administrative area, which only we can reach, uses a login.

In the emails

Our newsletters contain a small invisible image that tells us the email was opened, and the activity links tell us what you clicked. Section 2 explains what we do with that.

We will update this policy as the service changes. If the change is material:

• We email everyone who is subscribed.
• The change takes effect 30 days after we tell you.
• If you are not happy with it, unsubscribe before then.

The date at the top of this page always shows when it was last changed. Minor corrections — fixing a typo, clarifying a sentence — are made without notice and do not change what we do with your information.

How quickly we reply:

• General questions: within 7 days
• POPIA requests (access, correction, deletion, objection): within 30 days

Postal address: Protea Valley, Cape Town, 7530, South Africa

Complaining to the regulator