Privacy Policy

1. Introduction

This Privacy Policy explains how Jittercat (Pty) Ltd ("Jittercat", "we", "us", or "our"), trading as Always Keep Me ("Always Keep Me", "the Service"), collects, uses, stores, shares, and protects personal information when you use alwayskeep.me and related services.

We are committed to responsible handling of personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA"), the Electronic Communications and Transactions Act 25 of 2002 where applicable, and other applicable South African law.

Where the GDPR or another data-protection law applies to a particular user or processing activity, we will comply with the requirements applicable to that processing.

2. Information We Collect

Information You Provide

• Email address: Used for orders, retrieval, support, security, transaction-related communications, and other communications relating to Always Keep Me and its services. You may opt out of non-essential communications at any time.
• Audio recordings: Audio files you upload to create and retrieve your keepsake.
• Text: Text you choose to include in your keepsake.
• Photos: Where supported, the original photograph is processed in your browser and is not retained by us as a separate original file. The photograph may form part of the final generated keepsake image that you choose to store.
• Payment information: Payment details are processed by the applicable payment provider. We do not store full payment-card details.
• Support communications: Information you provide when contacting us.
• AI chat messages: If you use Raiden, the information necessary to operate that feature is processed by the third-party AI provider or providers used by the feature.

Technical Information Collected Automatically

We use Cloudflare and similar infrastructure providers to operate and secure the Service. As part of this, Cloudflare and our other infrastructure and security providers may collect and process your IP address.

We and our service providers automatically collect the following technical information:

• IP address and approximate location derived from it;
• Browser type and version;
• Device type and operating system;
• Pages visited and interactions with the Service;
• Date and time of access;
• Referring page or website; and
• Security, diagnostic, error, and technical logs.

This technical information does not, on its own, directly identify you by name. However, some of it — such as your IP address — may be considered personal information under applicable data-protection law, and we treat it accordingly.

3. How We Use Your Information

• To create, deliver, host, and retrieve your keepsake;
• To process and confirm payments and maintain transaction records;
• To provide customer support;
• To send transaction, service, security, and account-related communications;
• To prevent fraud, abuse, unauthorised access, and security incidents;
• To maintain, secure, troubleshoot, and improve the Service;
• To investigate complaints and enforce our Terms;
• To comply with legal, regulatory, court, and law-enforcement obligations; and
• To operate Raiden when you choose to use it.

We do not sell personal information.

We do not use uploaded audio recordings, photographs, generated keepsakes, text, or customer communications to train, fine-tune, develop, or improve artificial-intelligence or machine-learning models.

4. Legal Basis for Processing

Where POPIA applies, we process personal information on lawful grounds recognised by POPIA, including consent, contractual necessity, compliance with a legal obligation, and legitimate interests where permitted.

Where GDPR applies, we rely on the following legal bases for our principal processing activities. This list covers our main processing activities; other bases may apply to activities not listed here.

Where we rely on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Where we rely on legitimate interests, you have the right to object to that processing; see Section 10 for details.

5. International Transfers and Third-Party Service Providers

Always Keep Me is operated from South Africa and may be accessed internationally.

We use third-party providers to operate parts of the Service, including hosting, storage, content delivery network (CDN), payment processing, email, security, diagnostics, and AI functionality. As a result, your information — including uploaded content and technical information — may be stored, cached, or processed on servers located in multiple countries, including countries outside South Africa and outside your own country of residence.

Where third parties process information on our behalf, we rely on the agreements and data protection terms those providers make available to their customers, together with other appropriate technical and organisational safeguards, to help protect your information consistent with applicable law. Where applicable law requires additional safeguards for an international transfer of personal information, we use appropriate safeguards required by that law — such as standard contractual clauses or reliance on an adequacy decision — to the extent applicable.

By using the Service, you understand that your information may be processed and stored internationally as described above.

Third-party providers may have their own privacy notices and terms. Where appropriate, we will identify material providers or categories of providers in this Privacy Policy or otherwise make relevant information available.

6. Photo Processing

Where the photo feature is used, the original photo may be processed within your browser to create the final keepsake. We do not retain the original photograph as a separate uploaded file where the Service is operating as described in these Terms.

The final generated keepsake may contain the photograph and may be uploaded and stored so that the Service can provide the purchased product and retrieval functionality.

Deleting the keepsake removes the generated image stored by the Service. We do not maintain a separate original-photo record where the original was processed only within your browser.

7. Voice Recordings and Consent

Voice recordings can contain personal information, including a person's voice and information spoken during the recording. You are responsible for ensuring that you have the necessary rights, permissions, or lawful basis to upload and use recordings through the Service.

By uploading a recording containing another person's voice, you confirm that you have obtained any consent required by applicable law or otherwise have a lawful basis to make that recording available through the Service.

A person who believes that their voice has been uploaded or used without appropriate authority may contact privacy@alwayskeep.me. We may take appropriate action where required by law or reasonably necessary to protect rights or the Service.

8. No Biometric Identification or Recognition

Always Keep Me does not use facial recognition technology, facial recognition software, facial recognition services, or other biometric facial-analysis technology.

We do not analyse photographs or images for the purpose of identifying, verifying, authenticating, or recognising an individual.

Always Keep Me does not use voice recognition technology, voice recognition software, voice recognition services, speaker-identification systems, voiceprint analysis, or other biometric voice-analysis technology.

Audio recordings uploaded to Always Keep Me are stored and delivered as recordings for the purpose for which the Service is provided. We do not analyse the characteristics of a person's voice for the purpose of uniquely identifying or verifying that person.

We do not create, generate, store, or maintain facial biometric templates, facial embeddings, voiceprints, voice biometric templates, or similar biometric identifiers from content uploaded to the Service.

We do not use uploaded photographs or audio recordings to identify individuals through biometric recognition.

We also do not use uploaded content to infer an individual's identity, personality, emotional state, health condition, or other characteristics through biometric recognition or voice/facial analysis.

Although Always Keep Me does not use facial or voice recognition technology, photographs and audio recordings may still contain personal information about individuals. We therefore treat such content as personal information where applicable and handle it in accordance with this Privacy Policy and applicable data-protection laws.

9. How We Share Information

We do not sell personal information. We may share or make personal information available where reasonably necessary for the purposes described in this Privacy Policy, including:

• Service providers: Hosting, storage, payment processing, email delivery, security, diagnostics, and other operational providers.
• AI providers: Where you use Raiden, the messages necessary to operate that feature may be processed by the relevant third-party AI providers.
• Professional advisers: Lawyers, accountants, auditors, insurers, and similar advisers where reasonably necessary.
• Authorities and legal processes: Courts, law-enforcement agencies, regulators, or other competent authorities where required or permitted by law.
• Business transactions: Information may be transferred in connection with a merger, acquisition, restructuring, financing, sale of assets, or similar transaction, subject to applicable law.

We do not authorise third parties to use your uploaded audio, photographs, generated keepsakes, or customer content for their own AI-model training on our behalf.

10. Your Privacy Rights

POPIA Rights

• Request access to personal information we hold about you;
• Request correction or updating of inaccurate or incomplete personal information;
• Request deletion where legally applicable;
• Object to certain processing;
• Object specifically to direct marketing;
• Withdraw consent where processing is based on consent;
• Request information about processing; and
• Complain to the Information Regulator of South Africa (see Section 21 for contact details).

GDPR Rights

Where GDPR applies, you may have rights including:

• Right to information and access;
• Right to rectification;
• Right to erasure;
• Right to restriction of processing;
• Right to object to processing, including direct marketing;
• Right to data portability;
• Right to withdraw consent where consent is the legal basis; and
• Rights concerning solely automated decision-making and profiling where applicable.

These rights are subject to the conditions and exceptions in applicable law. We may retain information where required or permitted for legal, tax, accounting, security, fraud-prevention, dispute-resolution, or other lawful purposes.

To exercise a privacy right, contact privacy@alwayskeep.me. We may need to verify your identity.

Where GDPR applies, you may also lodge a complaint with the competent supervisory authority in the EU/EEA country where you live, work, or believe an infringement occurred.

11. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

Uploaded audio and generated keepsakes are retained to provide retrieval functionality while the relevant Service remains operational, subject to deletion and applicable retention obligations.

Transaction, payment-reference, accounting, tax, security, fraud-prevention, dispute, and legal records may be retained for longer where required or reasonably necessary.

When information is no longer required, we will delete it or otherwise dispose of it securely, subject to applicable legal retention requirements.

12. Data Security

We implement reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration, disclosure, or destruction.

No internet-based system can be guaranteed to be completely secure. We cannot guarantee absolute security, but we will take reasonable measures appropriate to the nature of the information and the risks involved.

You are responsible for protecting your own email account, devices, passwords, authentication information, and other credentials used to access your content.

13. Cookies and Similar Technologies

Always Keep Me may use cookies, local storage, session technologies, and similar technologies necessary to operate the Service, maintain security, remember preferences, support functionality, and understand Service usage.

Where applicable law requires consent for non-essential cookies or similar technologies, we will seek that consent before using them for those purposes.

You can control cookies through your browser settings. Disabling certain technologies may affect Service functionality.

14. Direct Marketing

We may send service-related communications necessary to provide purchases, support, security notices, or important changes to the Service.

Where we send optional promotional or direct-marketing communications, we will do so only where permitted by applicable law and will obtain consent where required. You may opt out at any time using the available unsubscribe mechanism or by contacting us.

15. AI Assistant (Raiden)

Raiden is an optional AI-powered chat assistant intended to answer general questions about Always Keep Me.

If you use Raiden, messages you submit may be transmitted to and processed by the third-party AI providers used to operate the feature.

Do not submit passwords, payment-card details, authentication codes, or unnecessary sensitive personal information to Raiden.

We do not use your Always Keep Me audio recordings, photographs, generated keepsakes, or customer content to train, fine-tune, develop, or improve AI or machine-learning models.

Raiden conversations may be logged or retained for limited security, abuse-prevention, troubleshooting, or service-operation purposes where reasonably necessary.

AI providers may process information under their own terms and privacy practices, subject to the arrangements we maintain with them and applicable law.

16. Data Deletion

You can permanently delete your keepsake and associated stored content at any time through alwayskeep.me/delete.

Deletion is intended to take effect immediately within the Service and is irreversible. Once deleted, the keepsake and associated stored content cannot be recovered through the Service.

We may retain limited records that are not part of the keepsake where reasonably necessary or required for tax, accounting, payment reconciliation, fraud prevention, security, dispute resolution, legal compliance, or the establishment, exercise, or defence of legal claims.

17. Children's Privacy

Always Keep Me is not directed to children under 18. We do not knowingly collect personal information directly from children under 18 without appropriate legal authorisation or parental or guardian involvement where required by law.

If you believe a child has provided personal information without the required authorisation, contact privacy@alwayskeep.me so that we can investigate and take appropriate action.

18. Third-Party Websites and Services

The Service may contain links to third-party websites or use third-party services. We are not responsible for the privacy practices, content, security, or policies of third parties acting independently of us.

You should review the privacy policy and terms of any third-party service before providing personal information to it.

19. Data Breaches and Security Incidents

If we become aware of a security compromise involving personal information, we will assess the incident, take reasonable steps to contain and investigate it, and comply with applicable notification and reporting obligations.

Where POPIA, GDPR, or another applicable law requires notification to a regulator or affected individuals, we will make the required notification within the applicable legal timeframe. Where individual notification is required but would involve disproportionate effort — for example, where we do not hold reliable contact details for affected individuals — we may instead use a public communication, such as a notice on our website, where permitted by applicable law.

20. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to the Service, processing activities, legal requirements, or security practices.

When material changes are made, we will update the "Last Updated" date and, where required by law, provide additional notice or obtain consent.

21. Contact Information

Privacy and Legal: privacy@alwayskeep.me

Support: support@alwayskeep.me

Security: security@alwayskeep.me

Legal Entity: Jittercat (Pty) Ltd

Physical Address: Eagle Canyon Office Park, Cnr Christiaan De Wet Road & Dolfyn Str, Randparkridge
(This is a meeting office only, available by appointment only. We otherwise operate remotely.)

Jurisdiction: Republic of South Africa

PAIA Manual

Our manual describing the records we hold and how to request access to them, prepared in terms of the Promotion of Access to Information Act 2 of 2000, is available at alwayskeep.me/paia-manual or on request from privacy@alwayskeep.me.

Information Regulator

If you believe we have not adequately addressed your concern, or you wish to lodge a complaint about how we have processed your personal information, you may contact the Information Regulator of South Africa:

Email: POPIAComplaints@inforegulator.org.za
Website: inforegulator.org.za