SmartProp, Property Management (Pty) Ltd

Address: Portswood Road, V&A Waterfront, Cape Town, South Africa

Effective date: 20 January 2026

Version: 1.0

1) Purpose of this Privacy Policy

SmartProp, Property Management (Pty) Ltd (“SmartProp”, “we”, “us”, “our”) respects your privacy and is committed to protecting personal information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and other applicable laws.

This Privacy Policy explains how we collect, use, share, store, and protect personal information when you use our website, mobile apps, dashboards, and portals (collectively, the “Services”).

2) Who this policy applies to

This policy applies to personal information of:

• property owners, trustees, and scheme representatives;

• tenants, occupants, and prospective tenants (where applicable);

• visitors/guests (where applicable);

• managing agents and estate agents (where applicable);

• service providers/contractors; and

• any user of the Services.
  
  

3) Responsible Party and contact details

For POPIA purposes, SmartProp is the Responsible Party for personal information processed through the Services, unless we clearly indicate we act on written instructions of a client (for example, a body corporate or managing agent). In those cases, we may act as an Operator for specific processing activities.

Information Officer / Privacy Contact

Email: admin@smartprop.info

Phone: 061 302 2505

Address: Portswood Road, V&A Waterfront, Cape Town, South Africa

4) What personal information we collect

Depending on your relationship with SmartProp and which features you use, we may collect:

4.1 Identity and contact details

• Full name

• Email address and mobile number

• Physical address (where relevant to the property/scheme)

• Profile photo (if you upload one)

• Identification number/passport number (only if required for verification, compliance, or onboarding rules of a scheme/client)
  
  

4.2 Property and account information

• Unit/erf details, scheme/building name, and occupancy status

• Account credentials and authentication data (e.g., password hash, login/OTP metadata)

• Role and permissions (owner/tenant/agent/service provider)
  
  

4.3 Requests, forms, and operational data

• Maintenance requests, incident reports, issue tracking updates

• Notes, descriptions, and attachments you submit (photos/documents)

• Communications sent via the Services (messages, support requests)
  
  

4.4 Technical and usage information

• Device and app information (device type, OS version, app version)

• Log data (such as timestamps, IP address, crash logs, diagnostics)

• Cookies or similar technologies on our website (see section 12)
  
  

4.5 Special personal information

We do not intentionally request special personal information (as defined by POPIA) unless it is necessary for a specific lawful purpose and collected with appropriate safeguards. Please avoid sharing unnecessary sensitive information in open text fields.

5) How we collect personal information

We collect information:

• directly from you (registration, forms, uploads, support messages);

• from authorised scheme stakeholders (e.g., body corporate/managing agent) where they provide data needed to link you to a scheme/unit;

• automatically through your use of the Services (logs and diagnostics); and

• from service providers used to operate the Services (see section 9).
  
  

6) Why we process personal information (purposes)

We process personal information to:

• provide and operate the Services (including account creation and authentication);

• link users to the correct property/scheme and enable property management workflows;

• process requests and forms (maintenance, notices, reports, access-related requests where applicable);

• communicate with you about your account, service requests, and service updates;

• maintain audit trails where reasonably required for accountability and dispute resolution;

• prevent fraud, secure the Services, troubleshoot problems, and improve performance; and

• comply with legal obligations and respond to lawful requests.
  
  

7) Lawful bases for processing (POPIA)

We process personal information on one or more lawful grounds, including:

• Consent (where required, especially for direct marketing);

• Performance of a contract (to provide the Services you request or use);

• Legal obligation (where laws require retention or disclosure);

• Legitimate interests (operating a secure, functional property management platform), balanced against your rights; and/or

• Protection of a legitimate interest of you or another person (where applicable).
  
  

8) Firebase hosting and processing

SmartProp hosts and operates key parts of the Services using Google Firebase (which may include services such as Firebase Authentication, Firestore/Realtime Database, Cloud Storage, Cloud Functions, and analytics/diagnostics tools depending on configuration).

This means certain personal information may be processed on infrastructure operated by Google and may be stored or processed in data centres outside South Africa. We take reasonable steps to ensure appropriate safeguards are in place (see section 10).

9) When we share personal information

We share personal information only when necessary for the purposes described above, including with:

9.1 Scheme stakeholders and authorised parties

• Body corporates, managing agents, trustees, or authorised representatives connected to your property/scheme, where needed for legitimate management and operations.
  

9.2 Operators (service providers)

• Google/Firebase (hosting, authentication, storage, and related platform services)

• Communications providers (email/SMS), if used to send notifications and OTPs

• Support tooling providers, if used for ticketing and support operations

Operators are required to process information only on our instructions and to implement appropriate security measures.

9.3 Legal and compliance

• Regulators, law enforcement, courts, or other parties where disclosure is required or permitted by law.
  

9.4 Business transfers

If SmartProp undergoes a merger, acquisition, restructuring, or sale of assets, personal information may be transferred as part of that transaction, subject to lawful safeguards.

10) International transfers

Where personal information is transferred or processed outside South Africa (for example, via Firebase/Google infrastructure), we take reasonable steps to ensure the recipient is subject to laws, binding agreements, or safeguards that provide a level of protection substantially similar to POPIA.

11) Payments

If the Services enable payments, payment processing may be handled by third-party payment providers. SmartProp generally does not store complete card details (card number/CVV). We may store limited transactional references and status information needed for support and reconciliation.

12) Cookies and similar technologies (website)

Our website may use cookies and similar technologies to enable core functionality, remember preferences, support security, and understand usage to improve performance. You can control cookies through your browser settings, but blocking some cookies may affect functionality.

13) Data retention

We retain personal information only as long as necessary for the purposes in this policy, including:

• while your account is active and for a reasonable period thereafter;

• as needed for legal, accounting, audit, or dispute-resolution purposes; and

• as required by contracts with scheme stakeholders (where applicable).
  

Where possible, we delete, de-identify, or aggregate data once it is no longer needed.

14) Security safeguards

We use reasonable technical and organisational safeguards designed to protect personal information against loss, misuse, unauthorised access, disclosure, alteration, or destruction. These may include access controls, authentication, encryption in transit, secure cloud infrastructure, logging/monitoring, and confidentiality obligations for staff and contractors.

15) Your rights (data subject rights)

Subject to applicable law, you may:

• request access to your personal information;

• request correction or updating;

• request deletion (where appropriate);

• object to processing in certain circumstances;

• withdraw consent where processing is based on consent; and

• lodge a complaint with the Information Regulator (South Africa).
  

To exercise your rights, contact us using the details in section 3. We may need to verify your identity before acting.

16) Direct marketing

We will only send direct marketing where permitted by law and, where required, with your consent. You can opt out at any time using an unsubscribe option (where provided) or by contacting us at admin@smartprop.info.

17) Children’s privacy

The Services are intended for users who can lawfully engage with property management services or who are authorised by a guardian/representative. We do not knowingly collect personal information from children without appropriate authorisation. If you believe a child’s information has been provided improperly, contact us.

18) Third-party links and services

The Services may link to third-party websites or tools. We are not responsible for the privacy practices of third parties. Review their policies before providing information to them.

19) Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When changes are material, we will take reasonable steps to notify users through the Services or via email. The most current version applies from the posted effective date.

20) How to contact us

SmartProp, Property Management (Pty) Ltd

Portswood Road, V&A Waterfront, Cape Town, South Africa

Email: admin@smartprop.info

Phone: 061 302 2505