Privacy Policy

This Privacy Policy explains how Xava ("Xava", "we", "us" or "our") collects, uses, shares, protects and retains your personal information when you visit our website, complete our contact form, or use the Xava cashless tipping service. We are committed to processing your personal information lawfully, minimally and transparently, in line with South Africa's Protection of Personal Information Act, 2013 (POPIA).

1. Who we are

Xava is operated by Nerdcode (Pty) Ltd, trading as "Xava" (registration number 2015/238954/07), a company registered in South Africa and based in Gauteng. For the purposes of POPIA, Xava is the "responsible party" that determines how and why your personal information is processed.

2. Our data minimisation promise

We collect and keep only the personal information we genuinely need — nothing more. In practice that means:

3. The information we collect

Depending on how you interact with us, this may include:

Providing information via our contact form is voluntary.

4. Payments — what we never see

All tip payments are processed by a licensed South African payment provider on PCI-DSS-compliant infrastructure. Card capture, tokenisation and bank authentication happen entirely within the payment provider's secure hosted environment.

5. Why we process your information (purpose)

6. Our lawful basis

We process your personal information on the basis of your consent (which you give by submitting our form or registering), to take steps at your request before entering into a service relationship, to comply with our legal obligations (including financial-sector verification laws), and to pursue our legitimate interests in running and improving Xava — always balanced against your rights.

7. Sharing your information

We do not sell your personal information. We share it only with trusted service providers (operators) who help us run Xava — such as our payment provider and secure hosting/database providers — under appropriate confidentiality and data-protection terms, and with authorities where the law requires it.

8. Data retention — kept to a minimum

We keep personal information only for as long as it is needed for the purposes above, or as long as the law requires — whichever applies. As a guideline:

9. How we protect your information

We take reasonable, appropriate technical and organisational measures to safeguard your information against loss, unauthorised access and misuse, including:

No method of transmission is perfectly secure, but we work to protect your information at every step. If a data breach occurs that affects you, we will notify you and the Information Regulator as POPIA requires.

10. Your rights under POPIA

You have the right to:

To exercise any of these rights, contact us at queries@xava.africa.

11. Enquiries, complaints and disputes — our service levels

See our Terms of Use for more on how enquiries and disputes are handled.

12. Information Officer

Xava has an appointed Information Officer responsible for our POPIA obligations. You can reach the Information Officer regarding any privacy matter at queries@xava.africa.

13. Complaints to the Information Regulator

If you believe we have not handled your personal information lawfully, you may lodge a complaint with the Information Regulator (South Africa):

14. Cookies

Our website uses only essential functionality and does not currently use non-essential tracking cookies. If this changes, we will update this policy and seek your consent where required.

15. Changes to this policy

We may update this Privacy Policy from time to time. The latest version will always be available on this page, with the "Last updated" date revised accordingly.

16. Contact us

For any privacy questions, email queries@xava.africa.