Privacy Policy
This Privacy Policy explains how ProperPics collects, uses, shares and protects personal information, in line with the Protection of Personal Information Act 4 of 2013 (POPIA). It is written for two audiences: the estate agents and agencies who use our service, and the people who contact us through this website.
1. Who we are
Warwick Brown (sole proprietor), trading as ProperPics, is the responsible party for the personal information described in this policy. Our Information Officer, registered with the Information Regulator, is Warwick Brown. You can reach us for any privacy matter at privacy@properpics.co.za.
2. Two roles: when we are the responsible party, and when we are only an operator
POPIA treats the two kinds of information we handle very differently, so we set the line out plainly:
- Our own data — we are the responsible party. This means the website enquiry leads you send us (your name, email, agency and message) and the email addresses of registered account users. This policy governs that information.
- The listing photographs we stage — we are only an operator. When an estate agency sends us photographs to stage, the agency is the responsible party and we process the photographs only on its instruction. Homeowners or sellers who are identifiable from a listing are not our direct data subjects: their POPIA notice, and any request to access, correct or delete that information, is handled by the instructing estate agency, not by us. If you are a homeowner with a query about a listing, please contact the agency that markets your property.
3. What personal information we collect, and where it comes from
- Enquiry leads (collected directly from you via our enquiry form): your name, email address, agency or company name (optional), and the free-text message you write. Please do not include unnecessary personal details in the message.
- Account users (collected when an account is set up): email address, role, organisation, and a securely hashed password.
- Operational and security data: your IP address and timestamps, used to rate-limit the enquiry form and keep security logs.
- Incidental information in listing photographs (handled as an operator, on the agency's instruction): the property, its contents and décor tied to a listing address. Photographs flagged as containing people are automatically excluded from staging and are never sent to the image model. Where this information is not collected from you directly, its source is the instructing estate agency.
4. Why we collect it
- To respond to and follow up your enquiry and prepare a quote or trial.
- To create, operate and secure user accounts and authenticate access.
- To deliver the service to the agency — classification, virtual staging, enhancement and listing copy — on the agency's instruction.
- For security, abuse-prevention and fraud-prevention.
- To meet our legal, tax and record-keeping obligations.
We do not sell personal information, and we do not use client listing photographs for our own portfolio, marketing or to train AI models. We will only use your enquiry contact details for our own marketing if you have given us consent to do so (POPIA section 69).
5. Is it voluntary?
Sending us an enquiry is voluntary, but we need your name and email to reply. For account users, an email address is required to create and secure the account. For agency clients, supplying the listing photographs is necessary for us to perform the service.
6. Our lawful basis (POPIA section 11)
We rely on the following justifications: for enquiry leads and account data — your consent, the steps needed to deal with your request, and our legitimate interest in running and securing the service (section 11(1)(b), (d) and (f)); for listing photographs — the instruction and authority of the responsible-party agency (section 20), which carries the homeowner's consent.
7. Who we share it with
We use a small number of operators (processors), each bound by a written contract to keep information secure and use it only on our instruction:
- Google (Gemini / Google Cloud AI models) — to perform the virtual staging, enhancement and listing-copy generation. The photographs and the text we generate are processed on Google's infrastructure outside South Africa (see section 8).
- Our hosting/infrastructure provider, our email-delivery provider, and our encrypted backup storage — by category.
We do not otherwise disclose personal information except as described here or as required by law.
8. Cross-border transfer to Google (POPIA section 72)
Because the AI models run on Google's infrastructure outside South Africa, performing the service involves transferring personal information (the listing photographs and generated text) across the border. We rely on the ground in POPIA section 72: a written data-processing agreement with Google that provides an adequate level of protection on terms substantially similar to POPIA — including substantially-similar restrictions on onward transfer — with Google contractually bound to no training and no human review on a paid tier, and, for the agency relationship, the operator agreement authorises this onward transfer. You may ask us for more detail about this safeguard at privacy@properpics.co.za.
9. How long we keep it
Client listing photographs and all staged outputs are automatically deleted after the job's retention window (30 days by default from delivery), and can be deleted sooner on the agency's instruction. Enquiry-lead records and account data are kept only as long as needed for the enquiry or account relationship and our legal record-keeping, after which they are deleted or de-identified. We keep personal information no longer than is necessary for the purpose (POPIA section 14).
10. How we protect it
We use reasonable, appropriate technical and organisational measures (POPIA section 19): HTTPS/TLS encryption in transit; encryption of backups at rest; per-record, owner-scoped access control; least-privilege administrator access; automatic deletion within the retention window; the people-photo exclusion described above; and a written breach-response procedure. If we become aware of a security compromise affecting an agency's client data, we notify the agency without undue delay so it can meet its POPIA section 22 obligations.
11. Your rights, and how to use them
You have the right to: be told what personal information we hold and to access it; ask us to correct or delete it; object to processing; and withdraw any consent you gave. These rights are free of charge. You do not have to use a prescribed form — simply contact us at privacy@properpics.co.za (or by post to the address below) and we will help you, including completing a POPIA form if you prefer (POPIA sections 5, 11(3) and 23–25, as strengthened by the 2025 amendment Regulations). Requests about a homeowner's listing photographs run through the responsible-party agency, as explained in section 2.
12. Complaints to the Information Regulator
If you are unhappy with how we have handled your personal information, you may complain to the Information Regulator (South Africa):
- Email (POPIA complaints): POPIAComplaints@inforegulator.org.za
- Email (general enquiries): enquiries@inforegulator.org.za
- Website: inforegulator.org.za · Telephone: 010 023 5200 / 0800 017 160 (toll-free)
- Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191 (postal: P.O. Box 31533, Braamfontein, Johannesburg, 2017)
13. Cookies
This website uses only strictly-necessary cookies and runs no analytics or third-party tracking. See our Cookie Notice for details.
14. Children and special personal information
Our service is offered to estate-agency professionals and is not directed at children. We do not knowingly collect the personal information of children. We do not seek to process special personal information; photographs that contain people — which could incidentally reveal special information — are excluded from staging by default (POPIA sections 26 and 34–35).
Changes to this policy
We may update this policy from time to time; the effective date above shows the current version. Please also read our Terms of Service, Virtual Staging Disclosure and PAIA Manual.
- Who we are
- Warwick Brown (sole proprietor), trading as ProperPics.
- Registration: Not applicable — sole proprietorship (no CIPC registration)
- Address
- 18 Murray Avenue, Morningside Manor, Sandton, Gauteng, South Africa
- Contact
- General: hello@properpics.co.za
- Privacy / data requests: privacy@properpics.co.za
- Information Officer (POPIA)
- Warwick Brown