Privacy Policy

Last updated 14 October 2026. Version 2026-10-draft.

Draft: placeholder text pending legal review. It is not final and should not be relied on as legal advice.

This policy explains what personal information IntriFund collects, why, who sees it, how long we keep it, and what rights you have. We try to write it in plain language, because it concerns your health and your money.

1. Who we are

IntriFund runs a charity healthcare platform. For the information described here, IntriFund is the “responsible party” under South Africa’s Protection of Personal Information Act (POPIA) and the “data controller” under Zambia’s Data Protection Act, 2021. [Placeholder: the legal entity name, registration number and address are to be added.] You can reach us at the address in the last section.

2. What we collect

What we collect depends on how you use the platform.

Information we collect
Kind	Examples	Whose
Account	Email address, password (kept only as a one-way hash), phone number if you add one, wallet address, sign-in and security records, the time you accepted our terms.	Everyone
Identity	Name, date of birth, national ID or passport number and a copy of the document, a face photo, your signature, your address and a utility bill.	Beneficiaries
Medical	Health conditions, diagnoses, the care you need and the care you receive, doctors and clinics you visit.	Beneficiaries, and patients of clinics
Financial	Household and income details to decide who needs help most; donation history and payment method details held by our payment partners; clinic bank or wallet details for payouts.	Beneficiaries, donors, clinics
Documents	Files you upload, such as IDs, bills, proof of income, claim attachments and facility logos.	Beneficiaries, clinics
Usage	Pages and actions in the portal, device and browser type, IP address and error logs, used to run and protect the service.	Everyone

We get this information from you, from the clinic that treats you, from our payment and accounting partners where you or the clinic use them, and, with your consent, from other sources we use to verify what you told us. Medical and financial information about you is “special” or “sensitive” personal information and we treat it with extra care.

3. Why we use it

To create and secure your account and to sign you in.
To review your application, verify who you are, and decide on cover.
To tell a clinic whether you are covered, and to pay the clinic.
To process donations, refunds, withdrawals and statements.
To keep an accurate ledger and publish a record of money movements.
To prevent fraud, abuse and mistakes, and to keep the platform safe.
To contact you about your account, applications and payments.
To meet legal, tax, accounting and regulatory duties.
To improve and support the platform.

We do not sell your personal information. We do not use it for advertising and we do not profile you for marketing.

4. Our legal bases

The law requires a lawful reason to use personal information. We rely on:

Your agreement or a contract with you, to give you an account and the services you ask for.
Your consent, in particular for medical and other sensitive information in your application, for sharing it to verify you, and for the optional photo. You may withdraw consent at any time, but then we may not be able to keep your application or cover going.
A legal duty, for example tax, accounting, anti-money-laundering and healthcare record rules.
Our legitimate interests and those of our donors and members, in running a fair and secure charity, preventing fraud and keeping honest records, where these are not outweighed by your rights.

We share information only where there is a reason to:

Clinics and hospitals. When a clinic checks your cover, it sees your name, date of birth, Member ID and the result of the check. It does not see your photo, phone number, email address, home address or your uploaded documents through that check. The clinics you visit for care may see the medical information that you gave in your application.
Our staff. Managers see applications and requests so that they can review them. Doctors’ contact details are not shown to managers or members.
Donors. See service requests in summary form. Donors do not see health details.
Payment processors and banks, such as Stripe, to take donations and pay out.
Accounting software the clinic turns on, such as Xero or QuickBooks. A clinic that connects its accounting package, or downloads an export, receives the amount, date, reference and a short description of items. No patient name or Member ID is sent.
Service providers that host our systems, store files and send email or text messages for us. They may use the information only for us and under contract.
Authorities and advisers, where the law requires it or to protect rights, and to our lawyers and auditors.

6. Identity and photo checks

In your application you can choose to let a photo of your ID fill in your details, and to have your face photo compared with the face on your ID. Both are optional. You can type everything yourself and still finish your application.

What is sent. The photo of your ID for the scan. For the photo check, your face photo and the photo of your ID. Only the images are sent, not your name or account details.
To whom. To Eden AI, a French company that passes the image on to the reading and face-matching providers it works with, and back to us. Which providers are used can change; we can tell you which ones are in use on request.
Why. To save you typing, to catch mistakes in numbers and dates, and to help our staff confirm that the face photo is you. A person always makes the decision about your application. A result from these checks never refuses or approves anyone on its own.
Your consent. We ask you to agree each time before an image leaves IntriFund. Without it nothing is sent.
What we keep. We do not keep the images from the scan or the photo check, and we do not keep a face template. We keep only the outcome for our staff: whether the ID could be read, whether the ID number looks valid, whether the date of birth fits the number, whether the face photo looked like a match (and a score), which providers answered, and when. Your ID document and face photo that you upload as part of your application are stored as described above, as before.
What Eden AI and its providers keep. Eden AI says it does not store the content of requests by default and does not train models on it. The providers behind it set their own rules and some of them may keep an image for a limited time. We cannot promise they delete it the moment the check is done.
Other countries. The providers may process the image outside South Africa and Zambia. We ask for your agreement for this before sending.
Your choices. Skip the scan and the photo check and type your details instead. Ask us to delete the outcome of the checks, or to tell you what was recorded, at the address in the last section. A face comparison is only a hint to our staff and you can ask a person to look at your photos instead.

7. The blockchain

To make our money records open to checking, we publish batches of ledger entries to a public blockchain. A blockchain cannot be edited or erased. We therefore put no personal data on it: only amounts, the type of movement and codes for accounts. Names, contact details, Member IDs, medical information and documents are never published. If you donate in crypto, your wallet address and the transaction are visible on the blockchain because the blockchain makes them public by design.

8. How long we keep it

We keep information only as long as we need it for the reasons above. As a guide [placeholder periods, to be confirmed]:

Account information: while the account is open, and a short time after.
Applications and documents: while you are a member, and then for the period the law requires for health and charity records.
Financial and ledger records, and statements: at least 5 to 7 years for tax and audit rules.
Sign-in codes and logs: a short period, days to months.

When we no longer need information, we delete it or make it anonymous, unless the law requires us to keep it.

9. How we protect it

We use technical and organisational measures to keep information safe. For example: passwords are stored as one-way hashes; sign-in can use a second check with an authenticator app; sessions are held in cookies that scripts cannot read; uploaded files are private and available only through links that expire; secrets such as authenticator keys and accounting tokens are encrypted; access is limited by role; and searches by clinics are limited and logged.

No system is perfectly secure. If a breach of security puts your information at risk, we will tell the regulator and you, as the law requires. See also Security and privacy.

10. Your rights

Under POPIA (South Africa) and the Data Protection Act, 2021 (Zambia), and similar laws, you have rights over your personal information. In plain words, you may:

Ask what we hold about you and get a copy.
Ask us to correct information that is wrong, out of date or incomplete.
Ask us to delete or restrict information that we no longer need or have no right to keep. Some information must be kept by law.
Object to our use of your information in some cases, and withdraw consent you gave.
Ask not to be subject to a decision made only by automated means that has a serious effect on you. Our decisions on applications are made by people.
Complain to the regulator: in South Africa the Information Regulator, and in Zambia the Office of the Data Protection Commissioner. [Placeholder: contact details to be confirmed.]

To use these rights, write to us at the address below. We may need to check who you are first. We will answer within the time the law allows.

11. Children

A child under 18 may be a beneficiary only through a parent or legal guardian, who gives the information and the consent for them. We use a child’s information only to review cover and arrange care for the child, and we take extra care with it. We do not knowingly create accounts for children, or collect donations from them. If you think a child has given us information without a guardian’s consent, please contact us and we will deal with it.

12. Sending information to other countries

Our systems and our service providers may be in countries other than yours, and clinics and donors may be in other countries too. When we send personal information across a border, we do so only where the law allows, for example because the receiver is bound by rules that give similar protection, you have agreed, or it is needed to carry out the service you asked for.

13. Cookies

We use only the cookies needed to keep you signed in and secure. We do not use advertising cookies. Details are in the Cookie Notice.

14. Changes

We may update this policy. The date and version at the top show when it last changed, and we will tell you of important changes before they apply.

15. Contact

For privacy questions or to use your rights, email support@intrifund.com (a placeholder address while the support desk is being set up) and say that your message is about privacy. [Placeholder: the name and contact details of our Information Officer to be added.] Please do not send passwords, card numbers or recovery codes.