How we protect your information.

At a glance

If you'd rather skim than read fifteen pages.

• ✓ We collect what we need to deliver concierge, rides, stays, financial and cultural services — nothing more.
• ✓ Card details never touch our servers — payment providers tokenise them on our behalf.
• ✓ Profiling is opt-in. Marketing is opt-in. Partner sharing is opt-in. You can withdraw any of these at any time.
• ✓ You can export everything we hold about you in one click. You can request correction or deletion at any time.
• ✓ Cross-border servicing (the diaspora layer) uses Standard Contractual Clauses or adequacy assessments per destination.
• ✓ Our Information Officer is Richard Ngwenya, reachable at privacy@opulence.luxe.

1 · Who is the Responsible Party?

Opulence (Pty) Ltd ("Opulence", "we", "us") operates this platform and acts as the Responsible Party for the personal information you provide. Opulence Private Client services are delivered as juristic representative of Nisela Fund Managers, an authorised FSP — Nisela operates as a separate Responsible Party for regulated advisory records and you will receive a distinct disclosure from Nisela where applicable.

Information Officer (POPIA §55): Richard Ngwenya · privacy@opulence.luxe.
Deputy Information Officer: Refiloe Celeste Khumalo · dpo@opulence.luxe.

2 · What personal information we process

Category	Examples	Source
Identity & contact	Full name, email, phone, city, member reference	You · application form
Authentication	Password (stored as scrypt hash with per-account salt)	You
Membership	Tier, billing cadence, next billing date, paid-until date	Service operation
Service records	Concierge requests, travel/event briefs, Petals deliveries	You · Relationship Manager
Mobility	Pickup/drop-off, distance, fare, chauffeur, ratings, scheduled time	Service operation
Stays	Reservations, host listings, photographs you upload, guest reviews	You · hosts
Messages	Guest ↔ host messages (contact details never shared)	You · host
Financial	Payment provider reference, amount, status, description, currency — no card numbers	Payment provider
Behavioural	Time of requests, frequency, cadence — only if you opt in to profiling	Service operation
Technical	IP address, user agent, session token, audit timestamps	Your device

We do not collect special personal information (POPIA §26) — health, religion, biometric, race, political opinion — unless you explicitly volunteer it for a specific request (e.g. dietary restrictions for an event) under §27 grounds, and only for that single purpose.

3 · The eight POPIA conditions — how we comply

Condition 1 · Accountability (§8)

A designated Information Officer (§55) sets, reviews and enforces this notice. Material changes are versioned (current version —) and every consent is stamped with the policy version under which it was given.

Condition 2 · Processing limitation (§§9–12)

We only collect personal information that is adequate, relevant and not excessive. Our lawful bases (§11):

• · §11(1)(a) Consent — for profiling, marketing, partner sharing, and cross-border servicing.
• · §11(1)(b) Contract necessity — for delivering memberships, bookings, rides, stays, payments.
• · §11(1)(c) Legal obligation — POPIA, FAIS (where Nisela acts), tax retention, AML.
• · §11(1)(f) Legitimate interest — fraud prevention, security audit log, dispute records.

Direct collection (§12) — we collect from you. The only exceptions: payment status from your bank/card processor, and ride/stay activity reported by hosts/chauffeurs delivering the service.

Condition 3 · Purpose specification (§§13–14)

Each category in §2 is collected for an explicitly stated purpose. We retain records for as long as the lawful basis applies:

• · Active membership records — for the duration of membership + 5 years thereafter (tax + FAIS).
• · Payment records — 5 years (Tax Administration Act).
• · Audit log — 7 years for accountability records.
• · Behavioural / profiling data — purged within 30 days of withdrawing profiling consent.
• · Closed-account principal record — anonymised on deletion; transactional records retained only for legal obligation periods above.

Condition 4 · Further processing limitation (§15)

We will not re-use your information for a new purpose without first re-establishing a lawful basis — typically by asking you to opt in.

Condition 5 · Information quality (§16)

You can review and correct your profile at any time via the Privacy Rights Portal. We act on corrections within 7 business days; access requests within 30 days (POPIA §23).

Condition 6 · Openness (§§17–18)

This notice is our §18 disclosure. A formal Manual under the Promotion of Access to Information Act, 2000 (PAIA), is available from the Information Officer on request.

Condition 7 · Security safeguards (§§19–22)

Our technical and organisational measures (§19):

• · Passwords stored using scrypt with per-account salt and constant-time verification.
• · Session tokens signed with HMAC-SHA256, expiry-bound, secret rotated under change-management.
• · Per-IP rate limiting and per-account lockout after repeated failures.
• · Strict Content-Security-Policy, X-Frame-Options DENY, strict-origin Referrer-Policy, no inline scripts.
• · Origin-validated state-changing requests; parameterised SQL throughout (no string interpolation).
• · Photo uploads validated by MIME prefix and size-capped (3 MB).
• · Audit log of authentication, consent changes, staff-level changes and rights actions.
• · Card details never touch our servers — payment providers tokenise on our behalf.
• · §21 written operator agreements with every processor (Stripe, Yoco where applicable, hosting).
• · §22 notification to the Information Regulator + affected subjects within 72 hours of a confirmed compromise.

Condition 8 · Data subject participation (§§23–25)

Your rights, exercisable from the Privacy Rights Portal:

• · §23 Right of access — download a JSON archive of everything we hold on you.
• · §24 Right of correction — update your profile in seconds.
• · §24 Right of deletion — close your account; we anonymise the principal record.
• · §11(2) Right to withdraw consent — toggle profiling / marketing / partner sharing / cross-border at any time.
• · §5 Right to object to processing on §11(1)(d–f) grounds — write to the Information Officer.
• · §74 Right to lodge a complaint with the Information Regulator (South Africa).

4 · Automated decisions & profiling (§71)

Some service personalisation (recommended trips, room upgrades, cellar suggestions) uses algorithmic models trained on your prior activity — only if you opt in to profiling. Material decisions (whether to accept a booking, grant credit, refund a fare) are never fully automated: a human staff member reviews and decides. This meets POPIA §71 and aligns with GDPR Article 22.

5 · Sharing with third parties

Category	Recipient	Purpose	Basis
Payment	Stripe / Yoco	Card processing	§11(1)(b) contract
Hosting & storage	Cloud infrastructure provider	Application hosting	§11(1)(b) contract · §21 operator
Regulated FS	Nisela Fund Managers	Where you transact under their FSP	§11(1)(c) legal obligation
Marketing analytics	None unless you opt in	—	§11(1)(a) consent only
Curation partners	Estates / galleries / hosts	To fulfil your specific request	§11(1)(b) or §11(1)(a)

We never sell your personal information.

6 · Cross-border transfers (§72)

Our diaspora servicing layer (London, Dubai pop-ups; concierge requests routed to overseas partners) may require transferring your information outside South Africa. Where we do, we use one of the §72 grounds:

• · §72(1)(a) Adequacy — the destination has equivalent data-protection law (e.g. UK GDPR).
• · §72(1)(b) Standard Contractual Clauses with the receiving operator.
• · §72(1)(c) Your explicit consent (which you may withdraw at any time).

7 · Children

Opulence services are not offered to children under 18. If a child's information reaches us in error we will delete it on the first business day after we become aware (POPIA §35).

8 · Lodging a complaint

Please first email privacy@opulence.luxe and we will respond within 7 business days. You may also lodge a complaint with the Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg · POPIAComplaints@inforegulator.org.za.

9 · Changes to this notice

We will notify you in-app and by email of material changes. The current policy version is —, dated June 2026. Prior versions are archived against every member's consent timestamp.