Privacy Policy

ESG Navigator Platform — TIS Holdings (Pty) Ltd

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Effective Date: 10 February 2026  |  Version: 1.0  |  Last Updated: 10 February 2026

1. Introduction

TIS Holdings (Pty) Ltd ("TIS Holdings", "we", "us", or "our"), registered in the Republic of South Africa, operates the ESG Navigator platform at esgnavigator.ai ("the Platform"). We are committed to protecting your personal information in accordance with the Protection of Personal Information Act, 2013 (Act No. 4 of 2013) ("POPIA"), the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000) ("PAIA"), and all applicable data protection legislation.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you access or use the Platform.

2. Information Officer

Responsible Party: TIS Holdings (Pty) Ltd

Information Officer: Dr. Terry Ramabulana

Email: terry@tisholdings.co.za

You may contact our Information Officer for any queries regarding this Privacy Policy, to request access to your personal information, or to lodge a complaint.

3. Personal Information We Collect

3.1 Information You Provide

3.2 Information Collected Automatically

3.3 Information We Do Not Collect

We do not collect special personal information as defined in POPIA Section 26, including race, ethnic origin, political opinions, religious beliefs, trade union membership, health information, sexual orientation, biometric data, or criminal records — unless explicitly required for a specific ESG assessment and with your express consent.

4. Purpose of Processing

PurposeLegal Basis (POPIA)
Account creation and authenticationSection 11(1)(a) — Consent
Delivery of ESG compliance assessment servicesSection 11(1)(b) — Contractual obligation
AI-powered compliance analysis and recommendationsSection 11(1)(a) — Consent
Platform security, fraud prevention, and access controlSection 11(1)(d) — Legitimate interest
Compliance with legal and regulatory obligationsSection 11(1)(c) — Legal obligation
Service improvement and analyticsSection 11(1)(d) — Legitimate interest
Communication regarding your account and servicesSection 11(1)(b) — Contractual obligation

5. AI Processing and Automated Decision-Making

5.1 Use of Artificial Intelligence

The Platform uses AI models, including Anthropic Claude and IBM Watsonx, to provide ESG compliance analysis, risk assessments, and recommendations. When you interact with the AI assistant or submit assessment data:

5.2 Your Rights Regarding AI Processing

In accordance with POPIA Section 71, you have the right not to be subject to a decision based solely on automated processing that produces legal effects or similarly significantly affects you. You may request human review of any AI-generated assessment or recommendation.

6. Cross-Border Transfer of Personal Information

In accordance with POPIA Section 72, we transfer personal information outside the Republic of South Africa to the following service providers:

ProviderPurposeLocationSafeguard
Anthropic (Claude AI)AI processingUnited StatesContractual clauses, data minimisation
Amazon Web ServicesInfrastructureVariousAWS DPA, encryption
Neon TechDatabaseUnited StatesEncryption at rest and in transit
RailwayBackend hostingUnited StatesEnvironment isolation
VercelFrontend hostingGlobal CDNEdge-only static delivery
CloudflareSecurity, DNSGlobalCloudflare DPA
DRATASOC 2 complianceUnited StatesSOC 2 Type II certified

All cross-border transfers are protected by encryption in transit (TLS 1.2+) and at rest (AES-256), role-based access control, and data processing agreements with all providers.

7. Data Retention

Data CategoryRetention Period
Account informationActive account + 12 months after closure
Assessment data and reports5 years from assessment date
AI interaction logs12 months
Authentication and access logs24 months
Financial and billing records5 years

8. Security Measures

Technical Measures: JWT-based authentication with token expiry, role-based access control (RBAC), bcrypt password hashing, TLS 1.2+ encryption, database encryption at rest, session management with automatic timeout, and CORS policy restricting API access.

Organisational Measures: Information security policies, staff access limited to role-required data, regular security assessments, incident response procedure, and SOC 2 compliance pathway via DRATA.

9. Your Rights Under POPIA

Contact our Information Officer at terry@tisholdings.co.za. We will respond within 30 days.

10. Breach Notification

In accordance with POPIA Section 22, in the event of a security compromise we will notify the Information Regulator and affected data subjects as soon as reasonably possible, document the breach, and take remedial steps.

11. Cookies and Tracking

The Platform currently does not use cookies, third-party tracking scripts, or advertising technologies.

12. Children's Information

The Platform is not directed at children under 18. We do not knowingly collect personal information from children.

13. Changes to This Privacy Policy

Material changes will be communicated via the Platform or email.

14. Complaints

Contact our Information Officer at terry@tisholdings.co.za, or lodge a complaint with the Information Regulator:

15. Governing Law

This Privacy Policy is governed by the laws of the Republic of South Africa, including POPIA and PAIA.