Privacy Policy

1. Introduction

Innovate Change Leap ("we," "us," or "our") operates WholePath (familywholepath.innovate-change-leap.com). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our family wellbeing assessment service.

We are committed to protecting your privacy and complying with the Protection of Personal Information Act (POPIA) of South Africa.

2. Information We Collect

2.1 Personal Information

• Name (first and last name)
• Email address
• Phone number
• Payment information (processed securely through PayFast)

2.2 Assessment Data

• Responses to assessment questions
• Overall and dimensional wellbeing scores
• Assessment completion dates and history
• AI-generated personalized recommendations and action plans

2.3 Technical Information

• IP address
• Browser type and version
• Device information
• Usage data and analytics

3. How We Use Your Information

We use the collected information to:

• Provide and maintain the WholePath assessment service
• Process payments securely through PayFast
• Generate personalized AI-powered insights and recommendations
• Send assessment results, reports, and notifications via email and WhatsApp
• Track your progress over time (with your consent)
• Improve our service quality and user experience
• Communicate important updates about our service
• Comply with legal obligations

4. Data Sharing and Disclosure

We do NOT sell, trade, or rent your personal information to third parties. We may share your information only in the following circumstances:

• Service Providers: PayFast (payment processing), SendGrid (email delivery), BulkSMS (WhatsApp notifications), and Abacus.AI (AI processing) – all under strict confidentiality agreements
• Legal Requirements: When required by law or to protect our rights
• With Your Consent: When you explicitly authorize us to share your information

5. Data Security

We implement industry-standard security measures to protect your personal information:

• Encrypted data transmission (HTTPS/SSL)
• Secure database storage with access controls
• Regular security audits and updates
• Password hashing and authentication protocols
• PCI-compliant payment processing through PayFast

6. Your Rights (POPIA Compliance)

Under South African law, you have the right to:

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your data (subject to legal obligations)
• Objection: Object to processing of your information
• Data Portability: Receive your data in a structured format
• Withdraw Consent: Withdraw consent at any time

To exercise any of these rights, contact us at: [email protected]

7. Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal obligations. Assessment data is retained to enable progress tracking and historical comparisons. You may request deletion of your data at any time.

8. Children's Privacy

WholePath is intended for use by adults (18+ years). While our assessments relate to family wellbeing (which may include children), we do not knowingly collect personal information directly from children under 18.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. Continued use of WholePath after changes constitutes acceptance of the updated policy.

10. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights:

Innovate Change Leap
📧 Email: [email protected]
🌐 Website: familywholepath.innovate-change-leap.com