Privacy Policy

1. Introduction

Refiloe Radebe (Pty) Ltd (“Refiloe,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you:

• Visit our website at refiloe.africa
• Use our WhatsApp AI assistant service for personal trainers
• Interact with us through any other channels

This policy applies to personal trainers (“Trainers”) who use our service, their clients (“Clients”) who interact with the Refiloe system, and visitors to our website (“Visitors”).

2. Information We Collect

2.1 Website Visitors

When you visit our website, we may collect:

Automatically Collected Information:

• IP address and approximate location
• Browser type and version
• Device type and operating system
• Pages visited and time spent on each page
• Referral source (how you found us)
• Interactions with our website (clicks, scrolls, form submissions)

Information You Provide:

• Contact form submissions (name, email, message)
• Feature suggestions and feedback
• Any other information you voluntarily provide

Cookies and Tracking:

• Analytics data (via Google Analytics 4)
• Advertising data (via Meta Pixel, TikTok Pixel, LinkedIn Insight Tag, Google Ads, Twitter/X Pixel)
• A/B testing data for pricing optimization

For details on cookies, please see our Cookie Policy.

2.2 Personal Trainers (Service Users)

When you register for and use Refiloe, we collect:

Account Information:

• Full name
• WhatsApp phone number
• Email address (if provided)
• Business name and details
• Service pricing and packages
• Working hours and availability
• Profile information

Service Configuration:

• Payment gateway details (PayFast merchant ID, etc.)
• Booking preferences
• Automated message templates
• Workout program templates
• Custom settings and preferences

Usage Data:

• Interaction history with Refiloe AI
• Features used and frequency
• Client management activities
• Booking and payment activities
• Analytics and performance metrics

2.3 Clients of Personal Trainers

When trainers add clients to Refiloe, or when clients interact with the system, we collect:

Client Profile Information:

• Name
• WhatsApp phone number
• Fitness goals and preferences
• Health information (if provided for fitness assessment)
• Starting measurements and progress data

Training Data:

• Assigned workout programs
• Exercise history and progress
• Session bookings and attendance
• Payment history
• Habit tracking data

Communication Data:

• Messages exchanged with the Refiloe AI assistant
• Booking confirmations and reminders
• Progress updates and check-ins

2.4 Payment Information

We facilitate payments between trainers and clients but do not store full payment card details. Payment processing is handled by third-party providers:

• PayFast (South Africa): Processes payments securely under their own privacy policy
• Additional payment providers may be added for other regions

We may store:

• Transaction records (amount, date, status)
• Payment method type (not full card details)
• Invoice and receipt information

3. How We Use Your Information

3.1 To Provide Our Services

• Operate the Refiloe WhatsApp AI assistant
• Process bookings, payments, and communications
• Generate workout programs and track progress
• Send automated reminders and notifications
• Provide customer support

3.2 To Improve Our Services

• Analyze usage patterns to enhance features
• Conduct A/B testing for pricing and user experience
• Debug issues and improve system performance
• Develop new features based on user needs

3.3 For Marketing and Communications

• Send service updates and announcements
• Provide relevant information about new features
• Display targeted advertisements (website only)
• Conduct remarketing campaigns to website visitors

3.4 For Legal and Security Purposes

• Comply with applicable laws and regulations
• Protect against fraud and unauthorized access
• Enforce our terms of service
• Respond to legal requests

4. Legal Basis for Processing

Depending on your location, we process your information based on:

• Contractual Necessity: To provide our services to trainers and facilitate their client relationships.
• Legitimate Interests: To improve our services, ensure security, and conduct marketing (where balanced against your rights).
• Consent: For marketing communications, non-essential cookies, and processing sensitive health information.
• Legal Obligation: To comply with applicable laws, including POPIA (South Africa), GDPR (EU), and other regional data protection laws.

5. Information Sharing and Disclosure

We do not sell your personal information. We may share information in these circumstances:

5.1 Service Providers

We use trusted third-party services to operate Refiloe:

5.2 Trainer-Client Relationship

• Trainers can view their clients' fitness data, workout progress, and booking history
• Clients can view their assigned workouts and their own progress data
• We facilitate communication between trainers and clients through the platform

5.3 Legal Requirements

We may disclose information if required by law, court order, or government request, or to:

• Protect our rights and property
• Prevent fraud or illegal activity
• Ensure user safety

5.4 Business Transfers

If Refiloe is involved in a merger, acquisition, or sale of assets, your information may be transferred to the new entity. We will notify you of any such change.

6. International Data Transfers

Refiloe operates from South Africa. Your information may be transferred to and processed in countries where our service providers operate, including:

• United States (cloud infrastructure)
• European Union (certain services)

We ensure appropriate safeguards are in place for international transfers, including:

• Standard contractual clauses
• Adequacy decisions where applicable
• Service provider certifications and commitments

7. Data Retention

We retain your information for as long as necessary to provide our services and fulfill the purposes described in this policy:

When data is no longer needed, we securely delete or anonymize it.

8. Your Rights

Depending on your location, you may have the following rights:

8.1 All Users

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your information (subject to legal requirements)
• Opt-out: Unsubscribe from marketing communications

8.2 South African Residents (POPIA)

Under the Protection of Personal Information Act, you have the right to:

• Request confirmation of whether we hold your personal information
• Request access to your personal information
• Request correction or deletion of your information
• Object to processing of your information
• Lodge a complaint with the Information Regulator

8.3 European Residents (GDPR)

Under the General Data Protection Regulation, you additionally have the right to:

• Data portability (receive your data in a structured format)
• Restrict processing
• Object to automated decision-making
• Withdraw consent at any time
• Lodge a complaint with your local supervisory authority

8.4 Exercising Your Rights

To exercise any of these rights, contact us at:

We will respond within 30 days (or sooner if required by applicable law).

9. Data Security

We implement appropriate technical and organizational measures to protect your information:

• Encryption of data in transit (TLS/SSL)
• Encryption of data at rest
• Secure authentication systems
• Regular security assessments
• Access controls and monitoring
• Employee training on data protection

However, no system is completely secure. We cannot guarantee absolute security of your information.

10. Children's Privacy

Refiloe is designed for use by personal trainers and their adult clients. We do not knowingly collect information from children under 18 years of age.

If a trainer works with minor clients, the trainer is responsible for obtaining appropriate parental/guardian consent and ensuring compliance with applicable laws.

If you believe we have collected information from a child under 18 without appropriate consent, please contact us immediately.

11. Third-Party Links

Our website and service may contain links to third-party websites or services. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

12. Marketing Communications

12.1 How to Opt Out

You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link in our emails
• Contacting us directly
• Replying “STOP” to WhatsApp marketing messages

12.2 Service Communications

Even if you opt out of marketing, we may still send you essential service communications (e.g., security alerts, booking confirmations, payment receipts).

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes:

• We will update the “Last Updated” date
• We will notify you via email or through the service
• We may request renewed consent where required

Your continued use of our services after changes are posted constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

Summary Table