Privacy & POPIA

1. Who is responsible

The responsible party — the “we” in this notice — is the company below, trading as PreOwnX. It decides what is collected and why.

Responsible party

深圳市众兴通讯科技有限公司Shenzhen Zhongxing Communication Technology Co., Ltd., trading as PreOwnX

Information Officer

Reachable on WhatsApp +86 177 2467 6105Subject line for anything POPIA-related: “POPIA request”

Registration no.

Supplied on request — ask on WhatsApp

Address

Shenzhen, Guangdong, China

2. What we collect

When you place an order

• Your name
• Mobile number
• Email address
• Delivery address — street, suburb, city, province, postal code
• What you ordered: model, capacity, colour, quantity, price paid
• Payment reference and status — never card numbers, CVVs or bank login details

When you message us

Your WhatsApp number, profile name and whatever you choose to type or photograph. If you send a photo of an ID or a bank card as proof of payment, delete the sensitive parts first — we do not need them.

When you browse

Nothing that identifies you. There is no analytics script, no advertising pixel and no third-party tracker on this site.

3. Why we hold it

• To perform the sale — take the order, confirm stock, take payment, hand the parcel to the courier, honour the warranty. (POPIA: processing necessary to perform a contract.)
• To keep records — order and payment records we are expected to keep, and to answer a dispute or a chargeback. (Processing necessary to comply with a legal obligation, and our legitimate interest in defending claims.)
• To prevent fraud — matching a payment to an order, spotting a stolen-card pattern. (Legitimate interest.)
• To send you stock drops — only if you ask to join the Thursday list. Every message has a way out, and asking is the only way in. (Consent, which you can withdraw any time.)

We do not sell your information, and we do not use it to build an advertising profile.

4. Where your order actually lives

Alongside that, a copy stays in your own browser's localStorage on the device you used, and we also get the order when you tap Send this order on WhatsApp on the confirmation screen. Four practical consequences, stated plainly:

• We cannot act on your order until we know about it. The WhatsApp message is what puts it in our queue, so please send it.
• You can look the order up from any phone under My orders → Track one order, using the order number and the last 4 digits of your phone number. There is still no account and no password.
• You can delete your own browser copy at any time by clearing site data. The cloud copy stays until it is no longer needed (see retention below), and you can ask us to delete it.
• We still ask you to keep the order number. Together with the last 4 digits of your phone number it is what unlocks the order.

Once the order is in WhatsApp, the record of the conversation lives in WhatsApp (operated by Meta) and in our WhatsApp Business account.

5. Who else sees it

• The courier — Aramex receives your name, address and mobile number, because somebody has to hand you the parcel.
• Payment providers — the Nedbank collection account operated by FinCRA processes transfers. It sees the amount and reference, not your order contents.
• WhatsApp / Meta — carries the messages you send us.
• The law — if a court order, a tax obligation or a legitimate fraud investigation requires it, we hand over the minimum required and tell you unless we are barred from doing so.

Nobody else. No data brokers, no marketing lists, no “partners”.

6. Cross-border transfers

We are based in China and sell into South Africa, so your information necessarily crosses a border. WhatsApp processes data outside South Africa under its own safeguards. Under section 72 of POPIA, this kind of transfer is permitted because it is necessary to perform the contract you entered into with us — you cannot receive the phone otherwise. We do not transfer your information to any other country for any other purpose.

7. How long we keep it

• Order and payment records: 24 months from delivery. That covers the 6-month warranty plus a sensible tail for disputes and chargebacks.
• WhatsApp threads: 24 months, then archived and deleted.
• Marketing consent: until you leave the list, plus a record that you left, so we do not message you again by mistake.
• Data in your browser: until you clear it. We have no way to delete it for you.

When the retention period ends we delete or irreversibly anonymise the record.

8. Your rights under POPIA

You may ask us to:

• confirm whether we hold information about you, and give you a copy;
• correct anything wrong — a misspelt name, an old address;
• delete what we no longer need (we may have to keep the order record for the retention period above, and we will tell you if so);
• object to processing based on our legitimate interest, including any direct marketing;
• withdraw consent to stock-drop messages at any time.

Send the request on WhatsApp marked “POPIA request”, with your order number if you have one. We verify it is you by asking something only the buyer would know, and we answer within 30 days. There is no fee.

If you think we have handled it badly, you can complain to the Information Regulator (South Africa) — JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 · complaints.IR@justice.gov.za · inforegulator.org.za. We would appreciate the chance to fix it first.

9. Cookies and tracking

This site sets no cookies and loads no analytics, advertising or social widgets. The only thing stored on your device is the site's own localStorage: your bag, your orders, your order-lookup session and a small passcode flag for the staff screen. Clearing site data removes all of it.

Fonts are served by Google Fonts, which receives your IP address as part of the request. If you would rather not, block the request — the site still works, in a fallback typeface.

10. Security, and children

The site is served over HTTPS. Order records in the database are not readable by the public: access is only possible through a lookup that needs your order number and the last 4 digits of your phone number, and through the staff console, which requires a signed-in staff account. The trade-off of keeping a cloud copy is that we now hold customer records, so we keep them only as long as we need them and delete them on request.

This shop sells phones to adults. We do not knowingly collect information from anyone under 18; if you believe a minor has placed an order, tell us and we will delete it and cancel the order.

Changes

If this notice changes materially — a new processor, a longer retention period — the date at the top changes with it, and we will say what changed on the Thursday list.