Lookmarks Privacy Policy

This Privacy Policy explains how Lookmarks (Pty) Ltd ("Lookmarks", "we", "us", and/or "our") collects, uses, stores, shares, and protects your personal information when you use our website, mobile application, and/or related digital services (collectively referred to as, "the App").

Lookmarks is committed to processing personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA"), the Electronic Communications and Transactions Act 25 of 2002 ("ECTA"), and other applicable South African laws.

1. Who We Are

Lookmarks (Pty) Ltd
195 Main Road, Green Point, Cape Town, 8005
South Africa

Our platform enables users to save organise fashion inspiration, discover similar products using visual search and connect with South African retailers.

Our designated Information Officer, as required by POPIA, is Danika Du Toit and can be reached via: info@lookmarks.co.za.

2. Definitions

2.1.

"Personal Information" means any information relating to an identifiable natural or juristic person, as defined in POPIA.

2.2.

"Special Personal Information" means sensitive categories such as biometric identifiers and children's data.

2.3.

"Processing" means any operation performed on information, including collection, storage, use, retrieval, dissemination, or destruction.

2.4.

"De-identified information" means information that cannot reasonably be linked to any person.

3. Information We Collect

We collect and process the following categories of information:

3.1. Information You Provide

• Name, surname and email address.
• Account login credentials.
• Uploaded images, links, notes, look libraries and saved fashion inspiration ("User Content").
• Browser preferences and communication settings.
• Wishlist and saved items.
• Messages or support requests sent to Lookmarks.

3.2. Information Collected Automatically

• Device information (IP address, OS, device type).
• App interaction data (search queries, saved items, and engagement metrics).
• Location data (approximate or precise, depending on device settings).
• Activity, error logs and crash reports.
• Referral activity and click-through behaviour.
• Crash logs and diagnostic reports.
• Cookies and similar tracking technologies (see Section 10).

3.3. Retailer and Technical Data

• Retailer product listings, referral traffic, and interaction analytics.
• Image analysis and visual similarity matching for product search.
• Click-through and purchase verification signals.
• Anonymised and aggregated user trends that may later be shared with retailers for insight and forecasting.

4. How and Why, We Process Personal Information

We process personal information only for lawful purposes under POPIA, including:

4.1. To Provide and Improve the App

• Account creation and authentication.
• Personalised recommendations and enable AI-powered visual search.
• Maintaining your look libraries and wishlists.
• Facilitate connections between users and South African retailers.

4.2. To Communicate With You

• Service updates and notifications.
• Customer support.
• Marketing messages (only with consent).

4.3. For Analytics and Platform Development

• Understanding user behaviour and engagement.
• Improving functionality.
• Generating aggregated insights for retailers.

4.4. To Facilitate Retailer Connections

Connecting users with retail partners and tracking referrals.

4.5. To Comply With the Law

• Record-keeping.
• Security monitoring.
• Responding to lawful requests.

5. Lawful Basis for Processing (POPIA)

We rely on these POPIA-compliant bases:

• Consent – For marketing, email sharing with retailers, the use of precise location and optional features.
• Contractual necessity – To provide and maintain your Lookmarks account.
• Legal obligation – To comply with POPIA, ECTA, tax and audit requirements.
• Legitimate interest of the data subject – To secure the App, prevent fraud or communicate essential service updates.

6. Data Sharing and Disclosure

We may share limited information in the following circumstances:

• Service Providers: With trusted partners (e.g. Supabase, Amplitude, email service providers) for hosting, analytics, or technical support. Service Providers process information under written agreements in accordance with POPIA and may not use information for their own purposes.
• Retail Partners: We may share anonymised and aggregated insights for forecasting and trend analysis. Your email address or unique identifier only with explicit consent and only to verify a purchase originating from Lookmarks. Retailers are bound by Service Level Agreements and must use data only for verification, not use it to market to you unless you consent to them directly and to protect the information with appropriate safeguards.

We may disclose information when required by law or necessary to protect Lookmarks, users and/or public safety. We do not sell or rent your personal information to third parties.

7. Data Storage and Security

7.1.

Your information is stored securely on encrypted servers hosted by Supabase and other reputable cloud providers.

7.2.

We implement appropriate technical and organisational measures to protect your data against loss, unauthorised access, or misuse. We use technical and organisational safeguards including encryption, secure authentication, and access controls.

8. Data Retention

8.1.

We retain your personal data for as long as your account remains active or as necessary to provide services, comply with legal obligations, or resolve disputes.

8.2.

Once you delete your account, your data will be permanently removed within 30 days, except for aggregated or anonymised data retained for analytics or reporting purposes.

9. Your Rights Under POPIA

Under the Protection of Personal Information Act, you have the right to:

• Access the personal information we hold about you;
• Request correction or deletion of inaccurate or unnecessary data;
• Withdraw consent for processing (where applicable);
• Object to certain processing activities;
• Lodge a complaint with the Information Regulator of South Africa.

To exercise these rights, contact us at info@lookmarks.co.za. We respond within 21 business days as required by POPIA.

10. Tracking Technologies and Cookies

10.1.

Lookmarks is a free service that earns commission when you purchase items through our retail partners. To provide this service, we use tracking technologies that are essential to our business model.

10.2.

Essential Cookies and Local Storage: Local device storage for authentication, preferences, and your Look Libraries. Used for login, preferences and core functionality.

10.3.

Analytics Cookies: We use Amplitude to understand how you use Lookmarks, improve features, and measure performance. This includes device information, searches performed, items saved, and retailer clicks.

10.4.

Performance Monitoring: Tools to identify and fix technical issues.

10.5.

Referral and Affiliate Tracking (Essential for Service):

When you click through to purchase items from our retail partners:

• We place a referral cookie on the retailer's website to track that the purchase originated from Lookmarks.
• This cookie contains a unique identifier linking the purchase to your session.
• These cookies typically expire after 30 days.
• This tracking is necessary for us to receive commission and keep Lookmarks free to use.
• The retailer may set additional cookies subject to their own privacy policy.

10.6. User Choices:

You may clear or block cookies through device settings, but certain App features may not function correctly.

11. Marketing Communications

We may send you emails or notifications about updates, new features, or promotions. You can opt out of marketing at any time by clicking "unsubscribe" or contacting info@lookmarks.co.za.

12. Children's Privacy

12.1.

The App is intended for users aged 13 and older. We do not knowingly collect personal information from children under the age of 13.

12.2. Users Aged 13-17:

If you are between 13 and 17 years old, you may only use Lookmarks with the consent and supervision of a parent or legal guardian. By using the App, you confirm that your parent or guardian has reviewed and agreed to this Privacy Policy and our Terms of Service on your behalf.

12.3. Parental Rights:

Parents or legal guardians of users under 18 have the right to:

• Review the personal information we hold about their child.
• Request deletion of their child's account and associated data.
• Withdraw consent for their child's use of the App.
• Object to further processing of their child's information.

To exercise these rights, please contact us at info@lookmarks.co.za.

12.4. Data Protection:

If we become aware that we have collected personal information from a child under 13 without proper parental consent, or from a user aged 13-17 without appropriate guardian consent, we will delete that information immediately and terminate the account.

Note: Our retail partner referral tracking applies to all users. Parents should be aware that when users aged 13-17 click through to retail partners, referral cookies will be placed as described in Section 10.

13. International Transfers

If information is stored or transferred outside South Africa, we ensure appropriate data protection measures are in place consistent with POPIA and applicable privacy standards.

14. Data Breach Notification

If a security compromise occurs, Lookmarks will notify:

• The affected data subjects, and;
• The information Regulator.

This is a requirement under section 22 of POPIA.

15. Updates to This Policy

We may update this Privacy Policy. The latest version will always be available on the App or website. Continued use constitutes acceptance of changes.

16. Contact Information

If you have any questions or requests related to this Privacy Policy, please contact:

Lookmarks (Pty) Ltd
195 Main Road, Green Point, Cape Town, 8005
info@lookmarks.co.za