Privacy Policy
This policy explains how we handle personal information on Yowl (yowl.co.za). We try to collect as little as necessary and be clear about what we do with what we keep.
1. Who we are, and our two roles
CDSoft (Pty) Ltd (Registration No. 2023/618547/07) is a South African company at 16 Sering Street, Red Swallow Room, Stellenbosch, Western Cape, 7600. We operate Yowl. Under the Protection of Personal Information Act 4 of 2013 (POPIA) we wear two hats:
- For the account information of our customers, we are the responsible party.
- For the mail sent to a customer’s addresses, the customer is the responsible party and we are their operator — we receive, store, and process that mail only on the customer’s instructions, to run their inbox (see section 5).
2. What we collect
For account holders (the organisations we host):
- Your name and email address (account creation)
- Organisation name and chosen Platform address (e.g. your-name.yowl.co.za)
- Session data (login state, device type, browser — standard web auth)
- Preference cookies (e.g. your chosen sort order or filters) — functional only, no tracking or advertising cookies
The mail we process on your behalf (as your operator): the messages sent to and from your addresses — sender and recipient addresses, subject, body, and attachments — together with the classifications and summaries the Platform generates from them so you can act on them.
For all visitors:
- Basic usage logs (pages visited, actions taken) — used for debugging and improving the Platform
- IP address — retained briefly for security purposes, not used for analytics profiling
3. What we don’t collect or do
- We never use the content of your mail for our own purposes — no model training, no advertising, no cross-customer analysis. Only aggregate, content-free metrics (counts, delivery stats) run the service.
- No behavioural tracking across other websites.
- No data from social networks unless you explicitly connect them.
4. Why we collect it, and our lawful basis
| Data | Purpose |
|---|---|
| Email address | Account authentication, Platform notifications |
| Organisation details | Your branded inbox and addresses on the Platform |
| The mail at your addresses | Receive, store, classify, and summarise it so your organisation can act on it |
| Usage logs | Debugging, Platform reliability, security |
| Session data & preference cookies | Keep you logged in; remember your settings |
For your account information, our lawful basis is your consent (given at registration) together with the performance of our contract to provide the Platform. For the mail we process for you, we act as your operator on your instructions; you, as the account holder and a party to that correspondence, give the processing and interception consent required under POPIA and RICA when you register (section 4 of our Terms of Use). For security and reliability logging we rely on our legitimate interest. We do not sell personal information.
5. The mail we process for you
The heart of the Platform is processing the mail you receive: storing it, and using AI to read, classify, and summarise its content and attachments so it lands usefully in your inbox. We do this as your operator, on your instructions — the account holder decides what happens next with every message. The AI provider involved is disclosed in section 7.
The load-bearing promise: we only ever use the content of your mail to serve you. We do not mine it for our own ends, and the moment we would need it for anything beyond running your inbox, we would ask you first.
6. A note for people who email a Yowl address
If you send an email to an address we host for one of our customers, we process your message — receiving, storing, and classifying it — so that we can deliver it to that customer and help them act on it. This is the same thing any hosted-email provider does to deliver mail. The customer you wrote to is the responsible party for your message in their inbox; questions about how they hold or use it should go to them. We process it only on their behalf, and we will not contact you on our own initiative.
7. Who we share data with
We use a small number of infrastructure providers to run the Platform, each under a data processing agreement:
- Cloudflare — hosting, database, storage, CDN, DDoS protection. Data may be processed on servers outside South Africa.
- Anthropic (Claude API) — the AI that reads, classifies, and summarises the content of the mail at your addresses, on your behalf. Anthropic does not use this data to train its models under our agreement, and does not retain content beyond the immediate API response.
- Resend — outbound email delivery (login codes, notifications, and the replies you send). Addresses are shared only to deliver the mail.
- Sentry — error monitoring. When something breaks, technical error context (which can include your user ID, IP address, and request details) is sent to Sentry so we can diagnose and fix it. Not used for anything else.
Beyond these providers we do not sell or share personal information.
8. Cross-border transfers
Several providers operate outside South Africa, so data may be processed abroad: Cloudflare, Anthropic, Resend, and Sentry (United States). This is permitted under POPIA Section 72 where the recipient is subject to equivalent protection obligations — each satisfies this through its data processing agreement.
9. How long we keep data
| Data | Retention |
|---|---|
| Active account | Held while your account is active |
| Deleted account | Account and its stored mail erased immediately on deletion — the messages, attachments and stored copies of the original emails are destroyed, leaving only the anonymous record described below. Organisations you own are kept (other members may still rely on them); ask us if you need one removed. |
| Anonymous mail record | Kept indefinitely: the date, direction and technical identifier of each message, with no sender, recipient, subject, content or attachment. We use it to check that no mail was lost in transit. |
| Usage logs | 90 days rolling |
| Mail-delivery logs | Our provider’s record of mail addressed to us — sender, subject line and delivery outcome — kept while we need it to investigate mail that failed to arrive |
| Billing records (paid features) | 5 years (SARS compliance) |
Day-to-day retention of the mail in your inbox is yours to manage. Deleting a conversation — or your whole account — erases the messages and attachments, including the stored copies of the original emails. What remains is an anonymous record that a message was received or sent on that date: no sender, no recipient, no subject, no content. We keep it because our provider logs every message our servers accept, and comparing the two is how we detect mail that was lost on the way to your inbox. If your account has been inactive for 12 months, we will email you before deleting it.
10. Your rights under POPIA
As an account holder you have the right to:
- Access — request a copy of the personal information we hold about you
- Correction — ask us to correct inaccurate information
- Deletion — ask us to delete your account and associated data
- Objection — object to specific processing (e.g. marketing emails)
- Complaint — lodge a complaint with the Information Regulator at inforegulator.org.za
To exercise any of these rights, contact us. We will respond within 30 days. If you emailed a Yowl address and want to reach the customer who received it, see section 6.
For how to request access to records CDSoft holds — including the applicable PAIA forms and fees — see our PAIA Manual.
11. Security
Connections to the Platform are encrypted (HTTPS). Data at rest is encrypted by Cloudflare’s storage infrastructure. Access to production systems is restricted to authorised personnel.
No system is completely immune to breach. If a breach occurs that poses a material risk to your rights, we will notify you and the Information Regulator as required by POPIA.
12. Age — 18 and over only
The Platform is for adults. You must be 18 or older to hold an account. We do not knowingly collect the personal information of anyone under 18 as an account holder; if we learn that an account holder is a minor, we delete their information.
13. Changes to this policy
If we make material changes to how we handle your personal information, we will notify active users by email at least 14 days before the change takes effect.
Information Officer: Brent Greeff — contact us