Privacy Policy

1. Introduction and Pumpkn's Role

AG Digital Venture (Pty) Ltd operates as "Pumpkn" and is committed to protecting personal information in accordance with South African law — specifically the Protection of Personal Information Act, No. 4 of 2013 (POPIA). Contact hello@pumpkn.io for any questions about your data.

Pumpkn acts as a "responsible party" when deciding how personal data is processed, and as an "operator" when processing data on behalf of third parties. This policy creates a legally binding agreement upon data collection or service usage. We reserve the right to modify this policy, though material changes will be communicated. You must cease using the website if you disagree with any terms.

2. Personal Information We Collect

By using Pumpkn's website or services, you consent to data collection. We collect information you provide directly — such as names, identification numbers, addresses, emails, company details, contact information and banking information — and data automatically transmitted through browsers (IP addresses, browser type and version, cookies, geographical location, log files).

We also collect personal information from public sources like social media where you have made information publicly available. We do not process information from individuals under 18 years old. You warrant that you have the legal authority to provide the information submitted and that all information is accurate and lawfully obtained.

3. When We Collect Your Information

Pumpkn collects personal information when you submit enquiries, visit or register on the website, engage via social media, contract as a service provider, complete Pumpkn documents, or utilise our services.

4. How We Use Your Information

We process information only for adequate, relevant and non-excessive purposes aligned with collection intentions: to provide services and website access, fulfil orders, respond to contact requests, enable contracted service provision, and contact you about services, products, features, offers and promotions unless you unsubscribe.

You can opt out by clicking unsubscribe links or emailing hello@pumpkn.io for removal within 48 hours. We also use information to maintain website security, prevent fraud and improve services by monitoring browsing habits.

5. Our Legal Basis for Processing

Your consent through website or service usage is the explicit basis for processing. We also rely on contractual arrangements and legitimate business interests as lawful bases — to provide products and services, communicate about them, share data with third-party service providers you engage through us, fulfil internal administration, monitor website usage, ensure data accuracy, conduct fraud checks, and comply with legal obligations.

6. Links to Other Websites

The website contains links to third-party websites including social media, payment gateways, scheduling platforms and live chat services. These external sites operate under their own terms and policies beyond Pumpkn's control. Evaluate third-party website security before disclosing personal information. Pumpkn accepts no responsibility for losses from third-party disclosure.

7. Original and Updated Purposes

We use personal information only for its original collection purposes unless reasonably necessary for compatible reasons. You can request explanations about new processing purposes. If unrelated purposes arise, you'll be notified with legal basis explanations.

8. Disclosure to Third Parties

We keep information confidential and only share it per policy, user consent or legal requirements. Disclosures may occur to:

• Third-party service providers and processors via written agreements
• Legal and regulatory authorities upon request or for law-breach reporting
• Accountants, auditors, lawyers and professional advisors under written agreements
• Relevant parties for legal rights establishment or defence
• Relevant third parties in business sales or asset transfers

9. International Data Transfers

We transfer personal information internationally only to countries with adequate protection levels. You expressly agree to such transfers. Information submitted for website publication — testimonials, articles, or other content — becomes internet-available worldwide.

10. Marketing Communications

We only send direct marketing communications to data subjects who have given specific, informed, voluntary consent in accordance with section 69 of POPIA. Where required, we operate on a double-opt-in basis (a confirmation email is sent to the address provided before any marketing is delivered). You may withdraw consent and unsubscribe at any time by clicking the unsubscribe link in any marketing email or emailing compliance@pumpkn.io. After unsubscription, marketing communications cease, though service-related contact continues.

11. Cookies and Similar Technologies

We use cookies — small text files — to recognise repeat users, facilitate ongoing website access, and (with your consent) measure usage behaviour and serve marketing. Our cookie banner offers three explicit choices: Manage, Reject and Accept. Analytics and marketing tags (including Google Tag Manager, Hotjar, and the LinkedIn Insight Tag) are gated behind explicit opt-in and do not load until you choose. Your choice is stored in your browser; you can reset it at any time by visiting pumpkn.io/?cookies=reset. Strictly necessary cookies (which keep the site running) load by default; everything else is consent-only.

11A. Third-Party Processors

To deliver our services we use the following third-party processors, each bound by written processing agreements:

• Hosting and delivery: Vercel Inc. (United States) — website hosting and CDN.
• Analytics: Google LLC (Google Tag Manager, Google Analytics) and Hotjar Ltd — loaded only after explicit consent.
• Marketing: LinkedIn Insight Tag — loaded only after explicit consent.
• Email and CRM: Resend (transactional and marketing email delivery), Airtable (lead capture), HubSpot (CRM).
• Communications: Standard email and telephony providers used for client correspondence.

Where any processor is located outside South Africa, transfers occur only to jurisdictions with adequate protection or under appropriate safeguards, as required by section 72 of POPIA.

11B. Personal Information Breach Notification

Where there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, Pumpkn will notify the Information Regulator and affected data subjects as soon as reasonably possible after the discovery of the breach, in accordance with section 22 of POPIA. Notifications will describe the possible consequences of the breach, the measures Pumpkn has taken or intends to take, recommended actions for the data subject, and (where known) the identity of the unauthorised person who may have accessed or acquired the personal information.

12. Data Security

We ensure all employees, consultants, service providers and partners accessing personal information maintain appropriate confidentiality obligations. We implement appropriate technical, security and organisational measures, though we cannot guarantee internet transmission security. We retain information only as long as necessary unless legally required otherwise.

13. Your Rights

Under POPIA you have rights to fair, lawful and transparent data processing; informed usage notification; access; error correction; deletion in certain situations; data portability; direct marketing objection; automated decision-making objection; continued processing objection; and processing restriction. You normally access information without fees; we may charge reasonable fees for unfounded, repetitive or excessive requests.

14. Our Rights Relating to Personal Information

We disclose personally identifiable information when reasonably required by law, regulation or government authority, or to protect company or public rights and property. We may retain deleted information records for dispute resolution and Terms of Service enforcement. Information may not be completely removed after deletion requests.

We may rebrand, restructure, sell, buy, merge or reorganise the business, which may involve personal information disclosure to new entities for necessary, legitimate purposes.

15. Feedback / Complaints

Questions or complaints? Email hello@pumpkn.io. You can lodge formal POPIA complaints with The Information Regulator:

• Website: www.inforegulator.org.za
• Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
• Email: inforeg@justice.gov.za

16. Legal Disclosure

AG Digital Venture (Pty) Ltd (registration number 2022/434429/07), trading as Pumpkn, is a private company with limited liability incorporated under South African company law. We are a registered National Credit Act credit provider (NCRCP18413).

• Information Officer: Zaheer Dindar — registered with the Information Regulator of South Africa per POPIA s.55. Contact: compliance@pumpkn.io.
• Compliance: compliance@pumpkn.io
• PAIA manual (s.51, Promotion of Access to Information Act): pumpkn.io/paia-manual
• Website: www.pumpkn.io
• Registered address: Office Suite 2.4, The Heritage Firestation, 16 Baker Street, Rosebank, Johannesburg

Policy prepared by Lay Law. Updated 19 May 2026.