Privacy Policy

1. Who we are

Black Bar Technologies (Pty) Ltd (“Black Bar”, “we”, “us”) is a private company registered in the Republic of South Africa under registration number 2020/017308/07. Our trading address is 35 Glenroy Drive, Glenroy Park, Gqeberha, Eastern Cape, 6025. We are not registered for VAT. Our Information Officer is Masibulele Gqiza.

• Email: info@blackbartechnologies.co.za
• Telephone: +27 41 010 5035
• Privacy requests: info@blackbartechnologies.co.za (subject line “POPIA request”)

We act as the responsible party (POPIA) or controller (GDPR) for personal information collected through this website, our enquiries, quotations and our own client relationships. When we host or support a client system, we act as an operator (POPIA) or processor (GDPR) for the client’s data and process it only on the client’s documented instructions.

2. Information we collect

We collect only what we need for the purpose concerned:

• Enquiries and quotations: your name, email address, telephone number, company name, the service you are interested in, budget range and your message.
• VoIP number porting: documents you upload for number porting (such as letters of authority and account details) that your current provider requires.
• Client and supplier records: contact details, billing information, project correspondence and records needed to deliver and support the services you buy from us.
• Technical and security data: IP address, browser type, device type, pages visited, error logs and security events used to operate, secure and troubleshoot the website and our services.
• Marketing data: your email address and communication preferences where you have opted in to receive marketing.

We do not knowingly collect personal information from children, and this website is not directed at children.

3. Why we process it and our lawful basis

We process personal information only where a lawful basis exists under POPIA section 11 or, where GDPR applies, Article 6:

• Contract: to respond to your enquiry, prepare a quotation, deliver and support the services you request, and administer your account.
• Legitimate interests: to keep our website and systems secure, prevent fraud and abuse, improve our services, and maintain business records. We balance these interests against your rights.
• Consent: for non-essential cookies, advertising pixels and electronic marketing. You may withdraw consent at any time.
• Legal obligation: to comply with tax, accounting, company, consumer-protection and other applicable law.

We do not sell or rent personal information, and we do not use client data for advertising.

4. Cookies, analytics and advertising

Our website uses essential cookies required for security, load balancing and form submission. Where enabled, we may use the following non-essential tools, but only after you accept them in our cookie banner (or where another lawful basis applies):

Tool	Provider	Purpose	Typical duration
Google Analytics 4	Google LLC (United States)	Aggregated statistics about pages, sessions and approximate location so we can improve the site.	Up to 24 months
TikTok Pixel	TikTok Technology Ltd / TikTok Inc. (United States)	Measures the effectiveness of our advertising and records visit or lead events.	Up to 13 months
Consent preference	Black Bar (first party)	Remembers whether you accepted or rejected non-essential cookies.	12 months

You can accept all cookies, reject non-essential cookies, or change your choice at any time using the Cookie Settings link in our footer. Rejecting non-essential cookies does not affect your ability to use the website. You can also block or delete cookies in your browser. See our Cookie Policy for more detail.

5. Who we share information with

We share personal information only as needed:

• Hosting and IT providers: our website and email infrastructure are hosted on professional cloud infrastructure in the European Union (Hetzner Cloud, Germany), with supporting services in South Africa.
• Analytics and advertising providers: Google and TikTok, as described in section 4, where you have consented.
• Payment processors: PayFast (South Africa) for subscription and service payments. We do not receive or store your full card number.
• Network operators and suppliers: only as needed to deliver a service you have requested, such as a VoIP number port.
• Professional advisers and authorities: where required by law, court order, a regulator, or to establish or defend legal claims.

Where a provider processes personal information on our behalf, we put a written operator or processing agreement in place and require confidentiality and security obligations appropriate to the data.

6. Cross-border transfers

Some of our providers are located outside South Africa, including in the European Union and the United States. Where personal information is transferred out of South Africa, we rely on a lawful transfer mechanism under POPIA section 72, such as adequate protection, your consent, or necessity for the performance of a contract. Where GDPR applies to a transfer from the EEA to South Africa or another country, we use an appropriate safeguard such as the European Commission’s Standard Contractual Clauses. POPIA is not the subject of a general EU adequacy decision, so we do not treat POPIA and GDPR as automatically equivalent.

7. Security and breach notification

We apply reasonable technical and organisational measures, including encrypted connections (HTTPS/TLS), access controls, least-privilege access, logging and secure configuration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, we will notify the Information Regulator and affected data subjects as soon as reasonably possible after discovery, as required by POPIA section 22, and will take reasonable steps to contain and remediate the incident. Where GDPR applies, we will notify the competent supervisory authority without undue delay and, where required, affected individuals.

8. How long we keep information

• Enquiry and quotation records: up to 24 months, unless you become a client.
• Client, billing and tax records: for the duration of the relationship and for the period required by law (generally five years after the end of the tax year).
• VoIP porting documents: for the porting process and any period required by the relevant operator or regulator, then deleted or de-identified.
• Website security and server logs: up to 12 months, unless needed for an investigation.
• Analytics data: as set out in section 4, then deleted or aggregated.
• Marketing preferences: until you unsubscribe or withdraw consent, plus a suppression record so we do not contact you again.

When information is no longer needed, we delete it, de-identify it, or archive it securely where a legal retention obligation applies.

9. Your rights

Subject to applicable law, you have the right to:

• be notified that your personal information is being collected and why;
• request access to the personal information we hold about you;
• request correction or deletion of information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained;
• object to processing based on legitimate interests, and withdraw consent where processing is based on consent;
• request restriction of processing or portability where GDPR applies;
• lodge a complaint with the Information Regulator (South Africa) or, where GDPR applies, your local supervisory authority.

To exercise a right, email info@blackbartechnologies.co.za. We may ask you to verify your identity. We aim to respond within 30 days; POPIA requires a response within a reasonable time, and GDPR requires a response within one month (extendable by two months for complex requests). There is no charge for the first request, unless the law permits a fee for copies or extensive searches.

10. Direct marketing

We send electronic marketing only where you have opted in, where you are an existing customer and the message relates to similar services, or where another lawful basis applies. Every marketing message includes an unsubscribe link, and you can object at any time. We do not sell or rent contact lists.

11. PAIA and access to records

Requests for access to records under the Promotion of Access to Information Act 2 of 2000 (PAIA) may be sent to our Information Officer at info@blackbartechnologies.co.za. Our PAIA manual describes the records we hold, the request procedure and the applicable fees, and is available on this website at PAIA Manual, from the Information Officer on request, and at our offices.

12. Complaints

If you are unhappy with how we have handled your information, please contact us first so we can try to resolve it. You also have the right to complain to the Information Regulator (South Africa):

If GDPR applies and you are in the EEA, you may also complain to the data protection authority in the country where you live or work.

13. Changes to this policy

We may update this policy from time to time. The current version is published on this page with its effective date. If a change is material, we will take reasonable steps to bring it to your attention.

14. Contact