Privacy Policy

1Introduction

URBYN (Pty) Ltd ("URBYN", "we", "our" or "us") respects your privacy and is committed to protecting your personal information in accordance with the Protection of Personal Information Act, 2013 ("POPIA") and all other applicable South African laws.

This Privacy Policy explains how we collect, use, store, disclose and protect your personal information when you use our website, request our services or otherwise interact with URBYN.

By using our website or engaging our services, you acknowledge that your personal information will be processed in accordance with this Privacy Policy.

2Company Information

Registered Name: URBYN (Pty) Ltd

Registration Number: 2025/684427/07

Trading Name: URBYN

Website: www.urbyn.co.za

Email: info@urbyn.co.za

Telephone: +27 69 055 1241

Registered Address: 14 Sandpiper Place, Hout Bay, Cape Town, Western Cape, 7806

3Personal Information We Collect

Depending on the services you request, we may collect information including:

Customers

• •Full name
• •Email address
• •Telephone number
• •The address at which the vehicle may be inspected
• •Vehicle details, including registration number, vehicle identification number (VIN), make, model, derivative, year and odometer reading
• •Photographs and video of the vehicle recorded during the inspection
• •Voice notes, WhatsApp messages and other communications exchanged with URBYN or its inspectors
• •Booking information and inspection requirements
• •Payment confirmation
• •Any documents, photographs or files submitted during booking or inspection

Inspectors

• •Full name
• •South African ID or Passport details
• •Driver's Licence information
• •Contact details
• •Banking details (where required for payment)
• •Professional information supplied during onboarding
• •Inspection records
• •Communications with URBYN

Website Information

When you visit our website, we may automatically collect:

• •IP address
• •Browser type
• •Device information
• •Operating system
• •Pages visited
• •Time spent on our website
• •Cookie information
• •Website usage statistics

3AInformation About Vehicle Sellers

To carry out an inspection, URBYN must contact the person who has the vehicle. When a customer makes a booking, we ask them for the seller's name, telephone number and, where available, email address.

This information is given to us by the customer rather than by the seller.

We use it only to contact the seller, arrange access to the vehicle and carry out the inspection the customer has requested. We do not use seller information for marketing, we do not add it to any marketing list, and we do not share it other than with the inspector assigned to that inspection.

Sellers have the same rights under POPIA as anyone else whose information we hold, set out in section 13, and may contact us at info@urbyn.co.za at any time.

Seller information is held with the booking record and deleted on the same schedule.

4How We Collect Information

We may collect personal information through:

• •Our website booking forms
• •Inspector onboarding forms
• •Email correspondence
• •Telephone conversations
• •WhatsApp communications
• •Information supplied during inspections
• •Payment processing
• •Customer enquiries
• •Voluntary submissions

We only collect personal information that is reasonably necessary for providing our services or complying with legal obligations.

5Why We Collect Your Information

We process personal information for purposes including:

• •Booking vehicle inspections
• •Allocating inspections to authorised inspectors
• •Preparing inspection reports
• •Confirming that a person requesting an inspection or a report is entitled to it
• •Securing inspection reports against unauthorised access
• •Communicating with customers and inspectors
• •Processing payments
• •Maintaining business records
• •Improving our services
• •Understanding how our website is used
• •Measuring which of our adverts bring people to our website
• •Showing URBYN adverts to people who have already visited our website
• •Preventing fraud
• •Complying with legal obligations
• •Responding to enquiries
• •Resolving complaints
• •Maintaining quality assurance standards

We will only process personal information where permitted by POPIA or where you have provided your consent where required.

6Technology-Assisted Processing

URBYN uses technology-assisted systems, including artificial intelligence, to assist in processing inspection information, analysing inspection data and generating inspection reports.

These technologies are used to improve consistency, efficiency and report quality. All reports remain subject to URBYN's quality assurance processes and professional oversight before being released to customers.

URBYN may also use inspection information and inspection media to test, develop and improve these systems. Where this is done, information is anonymised wherever reasonably possible, and personal information is not disclosed to any third party for this purpose without consent.

7Sharing Personal Information

We share personal information where it is necessary to provide our services, or where the law requires it. We also share information about your visits to our website with Google, to measure how well our advertising works, to show our adverts to people who have visited us, and to understand how the website is used, as described in section 10.

We do not send inspection information, booking details or the personal information of customers, sellers or inspectors to Google for advertising or website analytics. We do not upload anyone's email address or telephone number to Google.

When a booking request is submitted, all we tell Google is that a request happened. If you have left the advertising switch off, that signal carries no cookie and no advert-click identifier, so Google cannot match it to you or to an advert you clicked. If you have switched advertising on, Google can match it to the advert you clicked and to the browser you are using, which is what that switch is for. Whichever way you have answered, the request carries your internet address, your browser and the address of the page you are on, as every request your browser makes does.

Your information may be shared with:

• •Authorised URBYN inspectors assigned to your inspection, or asked to review or quality-check it
• •Vehicle sellers or their authorised representatives, where reasonably necessary to arrange and perform an inspection
• •Paystack, our payment provider
• •Meta Platforms, which operates the WhatsApp service through which inspections are conducted
• •Anthropic, whose systems analyse inspection photographs and assist in preparing report text
• •Groq, whose systems transcribe inspectors' voice notes
• •Google, which hosts our systems and stores inspection files, and which also receives information about your visits to our website, including your internet address and the pages you visit, for advertising measurement, for advertising audiences and for website analytics, as set out in section 10
• •Supabase, which hosts our database
• •Resend, which sends our confirmation emails
• •Vercel, which hosts our website
• •Professional advisers, regulatory authorities and law enforcement where required

URBYN may change, replace or add to the service providers listed above from time to time as its technology platform develops. Where a replacement or additional provider handles personal information on our instructions, we will require it to offer comparable protection for your information.

Google's advertising products are not in that position. Google sets its own terms for them and decides for itself what it does with the information, so there is nothing we can require of it. This is explained below and in section 10.

Several of these providers are located outside South Africa. See section 14.

Such communications may include the customer's name, appointment information and relevant vehicle details solely for the purpose of facilitating the inspection.

We do not sell personal information to third parties.

Any third party processing personal information on our behalf is expected to maintain appropriate confidentiality and security measures consistent with applicable legal requirements.

What your browser sends to Google

When you open a page on urbyn.co.za, your browser contacts Google directly. That is because we have put two pieces of Google's technology on our pages, not because you have chosen to use anything of Google's.

The first is the fonts the website is displayed in, which are loaded from Google on almost every page. That request tells Google your internet address and which browser you are using. It sets no cookie, it happens before any cookie question is asked, and there is no way to decline it while we load our fonts from Google.

The second is the advertising and analytics tag described in section 10, which is a small piece of Google code we place on our pages. It loads on every page, for every visitor, whatever you answer, and the request tells Google your internet address, your browser and the address of the page you are on. Your answer decides what Google may store and use, not whether Google is contacted.

Google's role is not the same for both of them. For website analytics, Google handles the information on our instructions. Under POPIA it is our operator, which means it may use that information only as we tell it to. Google's own data processing terms set out how. For advertising measurement, and for showing you our adverts elsewhere, Google acts on its own account. Under POPIA it is a responsible party in its own right, deciding its own purposes, and what it does with that information is governed by Google's privacy policy rather than by ours. The same is true of the font request.

These two requests sit outside everything set out above about the service providers we appoint. We have no agreement with Google about the fonts and cannot require anything of Google about them. For the advertising and analytics tag, the terms are Google's own.

8Payment Processing

Payments made through our website are processed by Paystack.

URBYN does not store your banking card details. Payment information is processed securely by our authorised payment provider in accordance with their own security and privacy standards.

9Marketing and Service Communications

URBYN will only send direct marketing communications by electronic means where permitted by POPIA and, where required, where the data subject has provided the necessary consent.

URBYN will not use personal information collected through an incomplete or abandoned booking for general marketing purposes unless the data subject has separately consented to receive such communications.

Service-related communications may be sent where reasonably necessary to administer, clarify, complete or assist with a booking or service interaction initiated by the data subject. This may include contacting a person where a booking was started but not successfully completed, where payment was unsuccessful or where a technical or administrative issue may have prevented the booking from being finalised.

Such communications will be limited to the purpose of assisting with or resolving the relevant booking or service interaction and will not constitute general marketing communications.

Where a booking or service interaction is not completed, URBYN will retain or process the relevant personal information only for as long as reasonably necessary for the purpose for which it was collected, to resolve related administrative or payment matters, or where otherwise required or permitted by law.

10Cookies

Our website uses cookies and similar technologies. This section explains what we use them for, who receives the information they collect, and how you choose what we may use. Our Cookie Policy covers the same ground in more detail.

We may use cookies and similar technologies to:

• •Ensure the website functions correctly
• •Improve website performance
• •Remember user preferences
• •Enhance your browsing experience
• •Support website security
• •Understand how visitors move through our website, using Google Analytics
• •Measure whether someone who clicked a URBYN advert went on to request a booking
• •Show URBYN adverts to people who have already visited our website, on other websites and apps in Google's advertising network

The advertising and analytics cookies described below store a code that singles out your browser from other people's. We treat codes like these as personal information under POPIA.

Your choice

The first time you visit the website you are shown a cookie banner with two buttons: Essentials only, and Accept all. Essentials only refuses both optional purposes; Accept all agrees to both. A link on the banner opens three switches — essential, analytics and advertising — if you would rather set them one at a time.

The essential switch is always on and is not part of the choice. It covers one thing only: a small note your browser keeps of the answer you give, so that you are not asked again on every page. It is not a cookie, it is not used for advertising or analytics, and it is not sent to us.

The analytics switch and the advertising switch are both off unless you turn them on. They work independently of each other, so you may turn one on and leave the other off, and you may change either of them at any time.

Until you answer, Google's tag places no cookie on your device and reads nothing from it.

Leaving either switch off, or both, costs you nothing. The website works in exactly the same way and you can book an inspection as normal. All that happens is that we lose some of our advertising measurement and website statistics.

Your answer is kept in your own browser rather than on our systems. If you use another device or browser, or clear your browsing data, you will be asked again.

Google

The advertising and analytics cookies are set by Google, not by URBYN. Google's tag is on every page of urbyn.co.za and it loads for every visitor, before anyone is asked anything. What your answer decides is not whether Google is contacted. It decides what Google may store on your device and what it may do with the information.

If you turn the analytics switch on, Google Analytics sets cookies on urbyn.co.za that give your browser a randomly generated number and keep track of your current visit. Google Analytics is provided by Google, which collects and processes that information on our behalf.

Google Analytics records:

• •The address of each page you open, and the page you came from
• •The page title
• •Your browser language and screen size
• •The type of device you are using, its operating system and its browser
• •An approximate location, usually a city, worked out from your internet address

We do not collect GPS or precise device location.

Google Analytics also records some things automatically, under a Google setting called Enhanced Measurement: how far you scroll down a page, clicks on links that lead away from our website, file downloads, video plays, and anything typed into a search box on this site.

If you turn the advertising switch on, Google may set cookies both on urbyn.co.za and on its own websites, including google.com and doubleclick.net. They are used for two things: measuring whether someone who clicked a URBYN advert went on to request a booking, and showing URBYN adverts to that visitor again afterwards, which is often called remarketing.

We use information about visits to urbyn.co.za to advertise online. Someone who has visited our website may be shown URBYN's own adverts later, on other websites and apps.

Third-party vendors, including Google, show URBYN adverts on sites across the internet.

Third-party vendors, including Google, use cookies and device identifiers to serve adverts based on your past visits to urbyn.co.za. A device identifier is a small code that recognises a particular phone or computer.

You can opt out of Google's use of cookies and device identifiers for advertising in Google's Ads Settings, at https://adssettings.google.com/. As an alternative, you can opt out of a number of advertising companies at the Network Advertising Initiative's opt-out page, at https://www.networkadvertising.org/managing/opt_out.asp.

Whenever a Google tag is present on a page, your browser automatically sends Google the address of that page and your internet (IP) address. That is how ordinary internet communication works. Google uses the internet address to work out roughly where you are, to city and country level. Google states that it does not log or store internet addresses in Google Analytics. We do not hide your internet address from Google, and Google Analytics gives us no setting that would let us.

We do not send Google your name, email address, telephone number, vehicle registration number or vehicle identification number through these tags.

Google explains how it collects and processes information from websites that use its services at https://policies.google.com/technologies/partner-sites.

Google's role is not the same for all of this, as section 7 explains.

If you leave the optional switches off

Google's tag still loads, because it is on every page for everyone, but it is told as it loads that it may store nothing. No advertising or analytics cookie is placed on your device and nothing is read from one.

Google is still sent two signals that carry no cookie. One is sent when you open a page. The other is sent when you complete something we count as a result of our advertising, such as submitting a booking request successfully, which happens when the request reaches us and before any payment is taken.

Neither signal carries a cookie, and neither carries the code that would identify an earlier advert click. Neither joins one page view to the next, or one visit to another.

Nothing in those two signals lets Google tie the visit to a person or build a picture of them. They are not invisible, though. Like every request your browser makes, they carry your internet address, your browser details and the address of the page you are on.

Turning a switch back off returns you to this position, and your later page views and booking requests send the same signals as those of someone who has never turned it on.

Changing your mind

You can change either switch at any time using the "Cookie preferences" control at the foot of every page. It takes effect in your browser straight away. You do not have to write to us and you do not have to prove who you are.

Turning a switch off tells Google's tag to stop storing and using that information from that point, and deletes the Google cookies that were set on urbyn.co.za.

That control does not reach the cookies Google has set on its own websites, such as google.com and doubleclick.net. We cannot delete those. Your browser settings can: most browsers let you view, delete and block cookies. You can also manage them in Google's Ads Settings.

Turning a switch off stops future use. It does not undo what Google has already received, which is dealt with under Google's own privacy policy, and it does not by itself take you out of an advertising audience Google has already built. Google's Ads Settings is the route for that.

You may object at any time to your information being used for advertising. Turning the advertising switch off is the quickest way and it is free. You may also object by emailing info@urbyn.co.za, or by sending us Form 1, the objection form published with the POPIA Regulations, which we will send you on request. There is no charge for any of these routes.

If you object, we stop using your information to advertise to you. We never see who is inside an advertising audience Google holds, so for information Google already has, Google's Ads Settings is the route.

The information described in this section is sent to Google outside South Africa. See section 14.

11Data Security

URBYN takes reasonable technical and organisational measures to protect personal information against:

• •Unauthorised access
• •Loss
• •Theft
• •Misuse
• •Disclosure
• •Alteration
• •Destruction

While no system can guarantee absolute security, we continually seek to maintain appropriate safeguards appropriate to the nature of the information we process.

12Data Retention

URBYN retains personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected or as required by law.

Our general retention periods include:

• •Inspection reports, including the original report, any corrected version and the copy supplied to the customer – At least 5 years
• •Inspection photographs, video and voice notes – At least 5 years
• •Booking records – At least 5 years
• •Inspector records – Duration of engagement plus at least 5 years
• •Accounting and financial records – At least 7 years

Information may be retained for longer where required by law or where reasonably necessary to protect URBYN's legal rights.

13Your Rights Under POPIA

Subject to applicable law, you have the right to:

• •Request access to your personal information.
• •Request correction of inaccurate or incomplete information.
• •Request deletion of information where legally permissible.
• •Object to certain forms of processing.
• •Withdraw consent where processing is based on consent.
• •Lodge a complaint with the Information Regulator of South Africa.

Requests may be submitted using the contact details below.

Your cookie choices work differently and need no request. You give and take back your consent to advertising and analytics cookies on the website itself, using the "Cookie preferences" control at the foot of any page, as described in section 10. It takes effect in your browser straight away. You do not have to write to us, and you do not have to prove who you are.

14Cross-Border Processing

Some of the technology platforms or service providers used by URBYN may process or store information outside South Africa.

Where this occurs, URBYN will take reasonable steps to ensure that appropriate safeguards are in place and that such processing complies with POPIA and other applicable legal requirements.

Information about your visits to our website, described in section 10, is sent to Google outside South Africa. Google may process it in any country in which Google or its suppliers have facilities.

South African law does not treat any other country as automatically giving personal information the same protection it has here, and Google's standard terms contain no safeguard written specifically for South African law. So we cannot promise you that this information has the same protection once it leaves the country.

Where you switch analytics or advertising on, we rely on your consent to send it, given through the cookie banner. The Protection of Personal Information Act allows information to be sent abroad where the person it is about consents to it (section 72(1)(b) of the Act). You can take that consent back at any time, as described in section 10.

Some information reaches Google whatever you answer, because Google's tag and Google's fonts load on every page. That is limited to what any request to any website carries: your internet address, your browser and, for the tag, the address of the page you are on. Sections 7 and 10 describe it, and it cannot be declined while we load those two things from Google.

15Children's Privacy

URBYN's services are intended for adults.

We do not knowingly collect personal information directly from children unless permitted or required by applicable law or with the necessary consent from a parent or legal guardian.

16Changes to this Privacy Policy

URBYN may update this Privacy Policy from time to time to reflect changes in legislation, technology, our services or our business operations.

The latest version will always be published on our website with the updated effective date.

17Contact Us

If you have any questions regarding this Privacy Policy or wish to exercise your rights under POPIA, please contact us:

URBYN (Pty) Ltd

Email: info@urbyn.co.za

Telephone: +27 69 055 1241

14 Sandpiper Place, Hout Bay, Cape Town, Western Cape, 7806

18Complaints

If you believe that URBYN has not processed your personal information in accordance with POPIA, we encourage you to contact us first so that we may attempt to resolve your concerns.

You also have the right to lodge a complaint with the Information Regulator (South Africa) in accordance with applicable legislation.