Privacy Policy

MilliScoop · last updated 10 July 2026 · POPIA

1. The short version

MilliScoop is designed to know almost nothing about you, on purpose. We collect one email address and a payment reference. We do not ask for your name, we do not use passwords, we do not run advertising or sell data, and the inscriptions you write onto your Millis are drawn on your device and are not sent to or stored on our servers. What follows is the long version required by law.

2. Who is responsible

The responsible party under the Protection of Personal Information Act 4 of 2013 ("POPIA") is Vault of Time (Pty) Ltd (registration 2025/875420/07), of 13 Senator Senekal Street, Viljoenskroon, 9520. Our Information Officer is Nthabiseng Patsa, reachable at hello@vaultoftime.com.

3. What we collect and why

Email address. Collected when you purchase scoops, via our payment processor. It identifies your scoop wallet, delivers sign-in links, and delivers transactional messages about your purchases (for example season wind-down notices). Lawful basis: performance of our contract with you.

Payment reference. PayPal processes your payment and provides us a transaction reference and confirmation. We never see or store your card number or PayPal credentials. Lawful basis: contract performance and our legal obligations (tax and consumer-protection record-keeping).

Wallet and redemption records. Your credit balance, redemption timestamps, and the identifying numbers of your Millis — necessary to honour your credits (including the three-year validity required by the Consumer Protection Act) and to let your Millis be replayed. Lawful basis: contract performance.

Technical data. Our hosting infrastructure (Google Firebase) records standard server logs (IP address, browser type, timestamps) for security and reliability, and we collect minimal, aggregated usage analytics. Lawful basis: our legitimate interest in operating a secure service.

What we do not collect: your name, physical address, phone number, identity number, precise location, or advertising identifiers. Inscriptions are rendered into your artwork on your own device and never transmitted to us. Should that ever change, this policy will be updated first and the change announced.

4. Marketing

We do not send marketing communications. Every email we send is transactional: sign-in links, purchase confirmations, and legally required notices about your credits or the season's end.

5. Who processes data on our behalf

We use two operators, as defined in POPIA: PayPal (payment processing, under its own privacy policy) and Google Firebase (hosting, database, and authentication infrastructure). Both process data on servers that may be located outside South Africa. Such transfers occur under section 72 of POPIA on the basis that these providers are subject to binding corporate rules and contractual protections that uphold principles substantially similar to POPIA.

6. How long we keep things

Transaction and wallet records are kept for five (5) years to meet tax and consumer-law obligations, then deleted or anonymised. Your email address is kept while your wallet holds credits or redeemed Millis linked to it, and removed on deletion of your wallet. Server logs are retained on short rolling windows set by our infrastructure provider.

7. Your rights

Under POPIA you may ask us: what personal information we hold about you; to correct it; to delete it (which will close your wallet — we will refund unredeemed credits first); or to object to processing. Write to hello@vaultoftime.com and we will respond within a reasonable time. Requests for access to records follow the Promotion of Access to Information Act; our PAIA manual is available at https://vaultoftime.com/paia-manual.

If you are unsatisfied with our response, you may complain to the Information Regulator (South Africa): JD House, 27 Stiemens Street, Braamfontein, Johannesburg; complaints.IR@justice.gov.za.

8. Security

We protect personal information with appropriate technical and organisational measures, including encrypted transmission, access controls on our database, and a passwordless design that eliminates the most common breach category entirely. No system is perfectly secure; in the event of a compromise affecting your information we will notify you and the Information Regulator as POPIA requires.

9. Cookies and local storage

The Service uses only functional browser storage: a session token so your device stays signed in, and technical state required for the Service to work. We use no advertising or cross-site tracking cookies.

10. Children

The Service is intended for persons aged 18 and over, and we do not knowingly process the personal information of children.

11. Changes

We will post any changes to this policy here with an updated date, and announce material changes on the Service before they take effect.

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