DRAFT (revamp 2026-07) — for SA attorney review; not legal advice; not for publication.
This document is a working draft prepared for review by South African counsel. It does not constitute legal advice and must not be published or relied upon until counsel has reviewed and approved it. Provisional entity details and attorney-required placeholders are clearly marked below. All statutory references are indicative and must be verified by counsel against the current text of each Act before any reliance or publication.
This Waitlist & Marketing Collection Notice ("Notice") explains how eRunna collects and uses your personal information when you join our waitlist. It applies to both the "Join the waitlist" form on our website and in-person sign-ups captured by our promoters at mall activations and similar events. This Notice is issued in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA"). It must be read together with our Privacy Policy, which sets out your fuller data-protection rights, and — for our promoters — the Promoter Agreement. Where this Notice conflicts with your rights under applicable South African law, applicable law prevails.
1. Who we are
"eRunna", "we", "us" or "our" refers to eRunna (Pty) Ltd (registration number [TBD: company registration number]), whose registered address is 1 Wedgewood Link Road, Bryanston, Johannesburg, Gauteng 2191. Trading name: [TBD: registered trading name]; parent/shareholder: [TBD: parent/shareholder entity name]. Contact: info@erunna.app / 010 140 6554. For the purposes of POPIA, eRunna is the responsible party for the personal information described in this Notice.
2. What personal information we collect
When you join the eRunna waitlist — whether online or in person — we collect only the minimum information needed to keep you informed and, where you have opted in, to send you marketing:
- Your name — so we can address you and personalise our communications.
- Your email address and/or mobile number — so we can send you waitlist updates and, where you have opted in, marketing communications by the channel you choose.
- Sign-up context — the date, source (website form or a named mall activation), and, for in-person sign-ups, whether marketing consent was captured. We do not collect your identity number, payment details, or precise location through the waitlist.
Providing this information is voluntary. If you do not provide an email address or mobile number, we will not be able to add you to the waitlist or notify you when eRunna becomes available in your area.
3. Why we collect it — purposes
We collect and process your personal information for the following purposes only:
- Waitlist administration and service updates: to record your interest, notify you when eRunna launches or expands to your area, and provide onboarding or early-access information. These are operational messages relating directly to the service you asked to hear about.
- Marketing (only if you opt in): to send you promotional offers, news, and campaign communications about eRunna and related services by email and/or SMS. You will only receive marketing if you have given us your explicit, separate consent (see section 5).
We will not use your waitlist information for any purpose incompatible with those set out above without giving you a further notice and, where required, obtaining your consent.
4. Lawful basis for processing
Under POPIA, we rely on the following lawful bases:
- Waitlist updates and service notifications — processed on the basis that it is necessary to respond to your request to be added to the waitlist and to pursue our legitimate interest in keeping interested users informed about the launch of the service they signed up for.
- Marketing communications — processed only on the basis of your explicit, prior, opt-in consent, in line with POPIA's provisions on direct marketing by means of electronic communication. Consent for marketing is separate from, and not a condition of, joining the waitlist.
[ATTORNEY-REQUIRED: confirm the correct characterisation of the lawful basis for each processing purpose above under POPIA, and confirm whether waitlist "service update" messages themselves fall within the statutory definition of direct marketing (and therefore also require opt-in consent) or whether they are properly treated as transactional/operational messages relating to a service the data subject requested.]
5. Marketing — explicit opt-in and your right to withdraw
We will only send you marketing communications if you have expressly opted in. Marketing consent is captured separately from your waitlist sign-up:
- On the website: marketing consent is given by ticking a clearly labelled, un-pre-ticked checkbox. Joining the waitlist without ticking this box means you will receive service updates only — not marketing.
- At in-person activations: our promoter presents this Notice to you and records your marketing consent as a distinct, affirmative step (see section 9). Consent is never assumed from the fact that you signed the waitlist.
Your right to withdraw or object. You may withdraw your marketing consent, or object to receiving direct marketing, at any time and at no cost. Withdrawing marketing consent does not remove you from the waitlist and does not stop essential service-update messages. You can do this by:
- Clicking the unsubscribe link in any marketing email;
- Replying STOP to any marketing SMS [TBD: confirm the SMS opt-out keyword and short-code/reply behaviour supported by our messaging provider]; or
- Emailing info@erunna.app with the word "unsubscribe" and the email address or mobile number you signed up with.
Suppression. When you withdraw consent or object, we add your contact details to a suppression list so that you are not contacted for marketing again, and we action the request without undue delay (target: [TBD: number — e.g. within 3 business days]). We retain the minimum information necessary on the suppression list purely to honour your opt-out; we do not use it for any other purpose.
[ATTORNEY-REQUIRED: confirm that the opt-in mechanism, the withdrawal/objection routes, and the suppression approach described above satisfy POPIA's direct-marketing requirements (including the prescribed form and manner for consent to direct marketing by electronic communication), and advise on any prescribed consent form that must be used.]
6. How long we keep your information (retention)
We keep your waitlist information only for as long as necessary for the purposes set out in this Notice:
- Waitlist records — retained until eRunna launches in your area and you either convert to an account or a reasonable period elapses without conversion, after which the record is deleted or de-identified. Target retention: [TBD: retention period, e.g. 24 months from sign-up or until conversion, whichever is earlier].
- Marketing consent and opt-out records — retained for as long as needed to evidence your consent and, where you have opted out, to keep you suppressed. Suppression records are kept for [TBD: retention period for suppression records].
You may ask us to delete your information sooner (see section 8), subject to any records we are legally required to keep.
[ATTORNEY-REQUIRED: confirm the appropriate retention periods above, and confirm any minimum retention period required to evidence consent or to comply with the record-keeping obligations that apply to direct marketing.]
7. How we protect your information (security)
We apply reasonable technical and organisational measures to safeguard your personal information against loss, unauthorised access, and misuse, in line with our obligations under POPIA. These include access controls, encryption in transit, and restricting access to waitlist data to authorised personnel. In-person sign-up data is transferred into our secure systems promptly and paper capture, where used, is handled in accordance with the Promoter Agreement. If a security compromise affecting your personal information occurs, we will notify you and the Information Regulator where the law requires.
8. Your rights and how to exercise them
Under POPIA you have the right to access the personal information we hold about you, to ask us to correct or delete it, to object to processing, and to withdraw any consent you have given. You may exercise these rights by contacting us at info@erunna.app. Our full data-protection rights and processes — including how to lodge a complaint with the Information Regulator — are set out in our Privacy Policy.
Information Officer. Our designated Information Officer for the purposes of POPIA is [TBD: Information Officer name], contactable at [TBD: Information Officer email] / [TBD: Information Officer contact number]. You may also contact the Information Regulator (South Africa) directly.
9. In-person sign-ups at activations
Where you sign up at a mall activation or similar event, our promoter is required to:
- Present this Notice to you before capturing any personal information, so you know what is collected, why, and how to opt out;
- Capture your marketing consent recordably — as a distinct, affirmative step that is stored alongside your sign-up (for example, a dated on-device consent capture), so that we hold verifiable evidence of if and when you consented; and
- Never make marketing consent a condition of joining the waitlist, and never pre-select the consent option on your behalf.
Promoters act on eRunna's behalf as operators/agents and are bound by the Promoter Agreement, which governs their handling of your personal information, their conduct at activations, and the accuracy of what they may tell you.
10. Honesty of marketing claims
Any promotional or marketing claim we or our promoters make about eRunna — including any figures such as how much you could "earn" as a runner or "save" as a customer — must be honest, not misleading, and capable of substantiation, consistent with our obligations under the Consumer Protection Act 68 of 2008 ("CPA"). We do not authorise promoters to make guarantees of earnings or savings, or any claim that cannot be substantiated. If you believe a claim made to you was inaccurate or misleading, please contact us at info@erunna.app.
[ATTORNEY-REQUIRED: review the specific earnings/savings and other promotional claims used on the waitlist page and at activations against the CPA's prohibitions on false, misleading, or deceptive representations, and confirm what substantiation must be held on file before any such claim is used.]
11. Changes to this Notice
We may update this Notice from time to time. The updated version will be posted with a revised "Last updated" date. Where changes are material, we will take reasonable steps to inform you. Your continued participation in the waitlist after any update constitutes acceptance of the revised Notice, to the extent permitted by law.
12. Related policies
- Privacy Policy — explains how we collect, use, and protect your personal information under POPIA, and your fuller data-subject rights.
- Promoter Agreement — governs how our in-person promoters handle your personal information, capture consent, and represent eRunna at activations.
- Support — contact options and escalation paths.