TOPCODE AI — PRIVACY POLICY

Effective Date: 26 August 2026

Last Updated: 26 August 2026

1. Introduction

TopCode (“TopCode”, “we”, “us”, or “our”) respects your privacy and is committed to protecting personal information processed through the TopCode AI platform (“Platform”).

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you access or use TopCode AI.

TopCode processes personal information in accordance with applicable South African data-protection laws, including the Protection of Personal Information Act 4 of 2013 (“POPIA”), where applicable.

2. Who We Are

TopCode is a South African software development company providing custom software, cloud, API, mobile application and artificial intelligence solutions.

TopCode AI is a software-as-a-service platform operated by TopCode.

3. Information We Collect

Depending on how you use the Platform, we may collect:

  • Account Information
  • Name
  • Email address
  • Telephone number
  • Company name
  • Login credentials
  • Account preferences
  • Organisation Information
  • Business name
  • Business contact information
  • Logo
  • Billing information
  • Account configuration
  • Payment Information
  • Payments are processed through third-party payment providers.

We may receive information such as:

  • transaction reference;
  • payment status;
  • amount;
  • currency;
  • date of payment; and
  • other transaction information.

We generally do not store complete payment card details processed directly by payment providers.

4. Customer Conversation Information

Businesses using TopCode AI may connect their customer communication systems to the Platform.

As a result, the Platform may process information contained in customer conversations, which may include:

  • names;
  • telephone numbers;
  • email addresses;
  • messages;
  • enquiries;
  • conversation history;
  • order or service information; and
  • other information voluntarily provided during a conversation.

The business using TopCode AI is responsible for determining what information it submits to the Platform and for ensuring that it has an appropriate lawful basis for processing that information.

5. Knowledge Base Information

Businesses may provide information to TopCode AI for use by their AI agents.

This may include:

  • documents;
  • FAQs;
  • product information;
  • business policies;
  • website content;
  • instructions;
  • internal business information; and
  • other Customer Content.

We process this information to provide the AI functionality requested by the customer.

 

6. Usage and Technical Information

We may collect technical and usage information such as:

  • IP address;
  • browser type;
  • operating system;
  • device information;
  • login timestamps;
  • pages accessed;
  • API usage;
  • AI message usage;
  • error information;
  • security logs; and
  • other information necessary to operate and secure the Platform.

7. How We Use Personal Information

We may use personal information to:

  • create and manage accounts;
  • provide TopCode AI services;
  • process payments;
  • maintain AI agents;
  • process knowledge bases;
  • process conversations;
  • provide human-handoff functionality;
  • monitor AI message usage;
  • maintain billing records;
  • provide customer support;
  • authenticate users;
  • prevent fraud and abuse;
  • detect security incidents;
  • maintain and improve the Platform;
  • communicate with customers;
  • comply with legal and regulatory requirements; and
  • enforce our agreements.

8. AI Processing

Information submitted to an AI agent may be processed by TopCode’s AI orchestration infrastructure to generate responses.

Depending on the configuration of the Platform, TopCode may use third-party AI technology providers to process requests.

We may therefore transmit relevant information to these providers where reasonably necessary to provide the requested AI functionality.

TopCode does not permit third-party providers to use customer information for purposes unrelated to providing the applicable service where contractual and technical controls are applicable.

The specific providers used by TopCode may change over time.

9. Third-Party Service Providers

We may use third-party providers for services including:

  • cloud hosting;
  • artificial intelligence processing;
  • payment processing;
  • email delivery;
  • analytics;
  • monitoring;
  • security;
  • storage;
  • communications; and
  • other infrastructure required to operate the Platform.

These providers may process personal information on our behalf.

We take reasonable steps to ensure that appropriate contractual, technical and organisational safeguards are applied where required.

 

10. Payment Processing

Payments for TopCode AI services may be processed by PayFast or another authorised payment provider.

Payment providers process payment information according to their own privacy policies and terms.

TopCode receives transaction information necessary to identify and reconcile payments and provide purchased services.

 

11. Cookies and Similar Technologies

The Platform may use cookies and similar technologies for purposes including:

  • authentication;
  • maintaining sessions;
  • security;
  • remembering preferences;
  • analytics; and
  • improving the user experience.

Where required, appropriate consent mechanisms will be provided.

12. Sharing Personal Information

We may disclose personal information to:

  • service providers working on our behalf;
  • payment providers;
  • AI and technology providers;
  • hosting providers;
  • professional advisers;
  • legal or regulatory authorities where required;
  • law-enforcement authorities where legally required; and
  • other parties where necessary to provide the Service or where authorised by law.

We do not sell customer personal information as a commercial product.

 

13. International Transfers

Some technology providers used by TopCode may process information outside South Africa.

Where personal information is transferred internationally, TopCode will take reasonable steps to ensure that the transfer is conducted in accordance with applicable data-protection requirements.

14. Data Security

TopCode takes reasonable technical and organisational measures to protect personal information against:

  • unauthorised access;
  • accidental loss;
  • destruction;
  • misuse;
  • alteration; and
  • unauthorised disclosure.
  • Security measures may include:
  • encrypted communications;
  • access controls;
  • authentication;
  • logging;
  • monitoring;
  • secure infrastructure; and
  • appropriate credential management.

No internet-based system can be guaranteed to be completely secure.

15. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, to provide the Service, maintain appropriate business records, resolve disputes, enforce agreements, prevent fraud, or comply with legal and regulatory obligations.

Different categories of information may be retained for different periods.

16. Customer Responsibilities

Businesses using TopCode AI are responsible for:

  • ensuring they have a lawful basis for providing personal information to TopCode;
  • providing appropriate notices to their own customers where required;
  • ensuring Customer Content is accurate and lawful;
  • configuring their AI agents appropriately; and
  • complying with applicable privacy and data-protection requirements.

Where TopCode processes personal information on behalf of a business customer, the respective roles and responsibilities of the parties may be further governed by the applicable agreement between TopCode and that customer.

 

17. Your Privacy Rights

Subject to applicable law, individuals may have rights relating to their personal information, including rights to:

  • request access to personal information;
  • request correction of inaccurate information;
  • request deletion where legally applicable;
  • object to certain processing;
  • request restriction of processing in certain circumstances; and
  • exercise other rights provided by applicable data-protection law.

Requests may be submitted using the contact details below.

18. Marketing Communications

Where permitted by law, TopCode may communicate with customers regarding:

  • account activity;
  • service updates;
  • billing;
  • security;
  • important operational notices; and
  • new products or services.

Marketing communications will be handled in accordance with applicable law and applicable consent requirements.

 

19. Data Breaches

If TopCode becomes aware of a security incident involving personal information, we will take reasonable steps to:

  • investigate the incident;
  • contain and remediate the incident;
  • assess potential risks;
  • comply with applicable notification requirements; and
  • notify affected parties or relevant authorities where required by law.

20. Children’s Information

TopCode AI is intended primarily for businesses and their authorised users.

The Platform is not specifically directed at children.

Customers must not intentionally use TopCode AI to collect personal information from children in violation of applicable law.

21. Third-Party Websites

The Platform may contain links or integrations to third-party websites and services.

TopCode is not responsible for the privacy practices of third-party websites.

Users should review the privacy policies of those third parties before providing personal information.

22. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

The updated version will be published on the TopCode AI website with a revised “Last Updated” date.

Where required by law, we will provide additional notice of material changes.

23. Contact Us

For privacy-related questions or requests, please contact:

TopCode

Email: info@topcode.co.za