Privacy Policy

1. Introduction

This Privacy Policy describes how Cubbs Foods (Pty) Ltd (“Cubbs Foods”, “we”, “us”, or “our”) collects, uses, discloses and protects your personal information when you visit our website at www.cubbs.co.za, place an order with us, or otherwise interact with us.

We are committed to protecting your personal information in line with the Protection of Personal Information Act, 4 of 2013 (“POPIA”) and other applicable South African laws.

By using this website or placing an order, you consent to the processing of your personal information as described in this policy.

2. Who we are (the Responsible Party)

Legal name	Cubbs Foods (Pty) Ltd
Postal address	PO Box 100286, Moreleta Plaza, Pretoria, 0167, South Africa
Email	[email protected]
Telephone	+27 12 345 1173
Information Officer	The Director, Cubbs Foods (Pty) Ltd (contactable via [email protected])

3. Personal information we collect

We collect only the personal information we reasonably need to operate our business and serve you. This may include:

• Identifiers: name, surname.
• Contact information: email address, telephone number, delivery address (street, suburb, city, province, postal code).
• Order information: items purchased, quantity, price, payment status, order notes.
• Communications: any messages you send us via our contact form, email, or phone.
• Technical information: standard server log information such as IP address, browser type, pages visited, and date/time of access. This is used for security, troubleshooting, and aggregated analytics.

We do not collect or store credit card or other payment card information. Payment for orders is made by electronic funds transfer (EFT) directly to our bank account, after we contact you to confirm your order.

4. How we collect personal information

We collect personal information directly from you when you:

• Place an order through our website.
• Subscribe to our newsletter.
• Contact us by email, telephone, our contact form, or social media.
• Visit our website (technical log information is collected automatically).

5. Why we process your personal information

We process your personal information for the following purposes, on the lawful bases set out alongside:

Purpose	Lawful basis (POPIA §11)
Processing and fulfilling your order, including delivery via Postnet	Performance of a contract with you
Contacting you to confirm an order and provide EFT banking details	Performance of a contract
Sending you order confirmations and updates	Performance of a contract
Sending you marketing communications and newsletters	Your consent (which you may withdraw at any time)
Responding to customer-service enquiries	Legitimate interest / contract
Maintaining records for tax, accounting and regulatory compliance (incl. VAT)	Legal obligation
Site security, fraud prevention, and abuse detection	Legitimate interest
Improving our products and website	Legitimate interest

6. Who we share your personal information with

We do not sell your personal information. We only share it with the following categories of recipients, and only to the extent necessary:

• Couriers (Postnet) for delivery of your order.
• Cloud-service providers that host our website, database, and send our transactional email on our behalf (Cloudflare and Resend). These operators process personal information under our instructions only.
• Professional advisors (such as our accountants and lawyers) where necessary for tax, audit, or legal compliance.
• Regulators and law-enforcement where we are legally compelled to disclose.

Some of these operators may store data outside South Africa. Where this occurs, we take reasonable steps to ensure your information is protected by laws comparable to POPIA, in line with §72 of POPIA.

7. How long we keep your personal information

We keep personal information only for as long as is necessary for the purposes for which it was collected, unless a longer retention period is required by law:

• Order records: retained for at least 5 years to comply with the Tax Administration Act and VAT Act.
• Newsletter subscriber details: retained until you unsubscribe or ask us to delete your details.
• Contact-form messages: retained for up to 24 months unless an ongoing customer relationship exists.
• Server logs: typically retained for up to 90 days.

8. How we protect your personal information

We take appropriate technical and organisational measures to safeguard personal information against loss, unauthorised access, modification, or disclosure. These include:

• HTTPS encryption for all website traffic.
• Access controls on systems holding personal information.
• Regular backups of customer-order data.
• Engagement of reputable operators (Cloudflare, Resend, Microsoft 365) with their own security certifications.

9. Your rights under POPIA

You have the right to:

1. Be informed that your personal information is being collected, and to ask for confirmation of what personal information we hold about you.
2. Request access to your personal information.
3. Request correction of inaccurate or out-of-date personal information.
4. Request deletion of personal information that we are no longer entitled to retain.
5. Object to the processing of your personal information for purposes such as direct marketing.
6. Withdraw consent at any time, where processing is based on consent.
7. Lodge a complaint with the Information Regulator (South Africa).

To exercise any of these rights, please email [email protected]. We may need to verify your identity before complying with a request.

You may also contact the Information Regulator directly:

• Postal: PO Box 31533, Braamfontein, Johannesburg, 2017
• Email: [email protected]
• Website: inforegulator.org.za

10. Direct marketing

We will only send you direct marketing if you have given us your consent, or where you are an existing customer and we are marketing similar goods to you, in line with §69 of POPIA and §45 of the Electronic Communications and Transactions Act. Every marketing email contains a clear unsubscribe link. You may also email [email protected] with the word “Unsubscribe” at any time.

11. Cookies

Our website uses a small number of cookies and similar technologies for essential operation (for example, remembering the items in your shopping cart) and aggregated analytics. We do not use third-party advertising cookies. You can disable cookies in your browser, but some site features (such as the cart) may not function without them.

12. Children

Our products are not directed at children, and we do not knowingly collect personal information from children under 18. If you believe we have inadvertently collected information about a child, please contact us so that we can delete it.

13. Changes to this Privacy Policy

We may update this policy from time to time. The latest version is always available on this page and is dated above. Material changes will be communicated by email to active customers and newsletter subscribers.

14. Contact us

Questions about this policy, or about how we handle your personal information, can be sent to [email protected] or by post to PO Box 100286, Moreleta Plaza, Pretoria, 0167.