Privacy
How ManyHands collects, uses, shares, and protects your Personal Information across the Website, the App, WhatsApp, and Manny.
Privacy Policy
Last updated: 21/06/2026
About this policy. This Privacy Policy explains how ManyHands ("Provider", "ManyHands", "we", "us") collects, uses, shares, and protects your Personal Information when you use our Website, our Apps, our WhatsApp service, and our AI agent "Manny" (collectively, the "Platform"). It forms part of, and should be read with, the Website Terms and the Terms of Service. Clauses that limit our liability or place risk or obligations on you are highlighted in bold and you must read them carefully.
1. Who this policy applies to
1.1. This Privacy Policy applies to every person who uses the Platform — whether you are a registered user, a guest chatting with Manny on WhatsApp, or just visiting our Website.
1.2. We process Personal Information in accordance with:
1.2.1. the Protection of Personal Information Act, 4 of 2013 ("POPIA");
1.2.2. the Promotion of Access to Information Act, 2 of 2000 ("PAIA");
1.2.3. the Electronic Communications and Transactions Act, 25 of 2002 ("ECTA");
1.2.4. the Regulation of Interception of Communications and Provision of Communication-Related Information Act, 70 of 2002 ("RICA"); and
1.2.5. the Consumer Protection Act, 68 of 2008 ("CPA"),
and any other data-protection or privacy laws applicable to us from time to time.
2. What we collect
We collect the following categories of "Personal Information" (as defined in section 1 of POPIA, including special personal information where applicable):
2.1. Identity & contact — name, phone number (in E.164 international format), WhatsApp identifier, email address, physical and delivery addresses, date of birth.
2.2. Account & lifecycle — Clerk user ID, lifecycle state (guest, trialling, paid, lapsed, suspended), Subscription Plan, sign-up source, and your recorded consents.
2.3. Conversational — all messages you exchange with Manny (whether via the Website, the App, or WhatsApp), including audio, images, files, and screenshots you upload.
2.4. Commerce — purchase history, carts, wish-lists, preferences, dietary and lifestyle preferences you supply or that Manny infers from conversation, delivery addresses Manny has used at Merchants, returns and disputes.
2.5. Payments — the masked Payment Method on file (last four digits and card brand), the Virtual Card identifier issued to you, and transaction histories.
2.6. Device & telemetry — IP address, device type, browser, App version, surfing patterns, click and scroll events, error logs.
2.7. Location — city-level location for delivery and Merchant search, and (where you opt in) precise location.
3. How and why we process your Personal Information
3.1. Purpose limitation. We process Personal Information only for the purposes set out in this Privacy Policy, for a purpose to which you subsequently consent, or where required or permitted by law.
3.2. The specific purposes are:
3.2.1. Operating the Platform — registering and authenticating you, providing Manny, and keeping the Platform secure.
3.2.2. Executing Authorised Purchases on your behalf. You acknowledge that, in order for Manny to act as your agent, we will share your name, delivery address, phone number, masked card token (the Virtual Card), and order detail with the relevant Merchant and with delivery, logistics, and payment partners as needed to fulfil the order.
3.2.3. Enabling Manny's AI features. Manny uses third-party large-language-model providers (including providers based outside South Africa, such as in the United States or the European Union) to generate its responses. You consent to the cross-border transfer of your conversational content and associated metadata to such providers, on the contractual basis that those providers handle the data only on our instructions and delete it after processing where the provider so commits. A current list of model and infrastructure sub-processors is available on request to privacy@manyhands.co.za.
3.2.4. Billing your Subscription Plan and any other amounts due under the Terms of Service.
3.2.5. Preventing fraud, abuse, and breach of the Terms of Service, including screening against sanctions, politically-exposed-persons, and fraud-risk databases.
3.2.6. Quality assurance, model improvement, and personalisation of Manny's recommendations and reminders. Conversational content may be reviewed by humans (subject to confidentiality safeguards) as part of quality assurance and improvement.
3.2.7. Communicating with you — transactional, service, and (where you have not opted out) marketing communications via email, SMS, WhatsApp, push notification, or the Platform.
3.2.8. Legal compliance — responding to lawful requests from regulators, courts, and other competent authorities.
3.2.9. Business continuity, audit, and dispute resolution.
4. Conversations with Manny — RICA & POPIA consent
4.1. Manny is a large-language-model-based AI agent. All conversations with Manny (via web, App, or WhatsApp) are recorded, processed, retained, and may be used to (a) operate the service, (b) improve Manny and the Platform (including model fine-tuning and quality review by humans subject to this Privacy Policy), and (c) comply with law.
4.2. Your consent to this clause 4 constitutes consent in writing for the purposes of section 4 of RICA and section 11(2) of POPIA, both of which require your express consent for the interception, recording, and processing of your electronic communications.
4.3. Manny may interact with third-party Merchant websites on your behalf, including by completing checkout forms, entering addresses, applying coupon codes, and submitting orders. You authorise Manny to do so, and confirm that any such interaction is taken on your account and at your risk, within the Spending Limit and the authority described in the Terms of Service.
5. Who we share your Personal Information with
5.1. We may share Personal Information with the following categories of recipient, only to the extent necessary for the purposes set out above:
5.1.1. Merchants with whom you ask Manny to transact (limited to what is necessary to complete the purchase, booking, or service);
5.1.2. Payment, card-issuance, and banking partners, including the Provider's Virtual Card issuer, our nominated payment processor, and acquiring banks;
5.1.3. Logistics and delivery partners appointed by the Provider or by the Merchant;
5.1.4. Cloud and infrastructure sub-processors used to host the Platform, run Manny, store data, and operate the WhatsApp Channel;
5.1.5. AI and ML model providers used by Manny (which may be located outside South Africa);
5.1.6. Identity, authentication, and fraud-prevention providers, including Clerk for identity and any sanctions, PEP, or anti-fraud screening providers;
5.1.7. Professional advisers (legal, accounting, audit) on a need-to-know basis;
5.1.8. Regulators, courts, and law-enforcement where required by law; and
5.1.9. Acquirers, investors, or successors-in-business in the event of a corporate restructure, merger, acquisition, sale of all or substantially all of the Provider's business or assets, or insolvency.
5.2. We take contractual steps to require these recipients to comply with POPIA and to process Personal Information only on our instructions and only for the purposes stated above.
6. Cross-border transfer of Personal Information
6.1. You acknowledge that some of the recipients listed above (notably AI / ML model providers and certain cloud infrastructure) are located outside South Africa, and you consent to the cross-border transfer of your Personal Information to those recipients on the contractual basis described in this Privacy Policy and in section 4 above.
6.2. We rely on the lawful bases for cross-border transfer set out in section 72 of POPIA, including (i) your consent, (ii) contractual safeguards binding the recipient to POPIA-equivalent protection, and (iii) the necessity of the transfer for the performance of our contract with you.
7. Your consent
7.1. By providing us with Personal Information, you consent to us:
7.1.1. storing such Personal Information;
7.1.2. contacting you (by email, SMS, WhatsApp, push notification, or via the Platform) for service, transactional, and (where you have not opted out) marketing communications;
7.1.3. using your Personal Information as set out in this Privacy Policy;
7.1.4. disclosing your Personal Information to the categories of recipient set out in section 5; and
7.1.5. transferring your Personal Information cross-border on the basis set out in section 6.
7.2. You may withdraw consent at any time by emailing privacy@manyhands.co.za, subject to sections 9 and 10 below.
8. Marketing
8.1. You can opt out of marketing communications at any time by:
8.1.1. following the unsubscribe link in any marketing email;
8.1.2. replying "STOP" to a marketing WhatsApp message; or
8.1.3. emailing privacy@manyhands.co.za.
8.2. Transactional, security, billing, and service messages (including messages from Manny in response to your instructions) are not marketing and you cannot opt out of them while remaining on the Platform.
9. Your rights — access, correction, deletion
9.1. You have the right to:
9.1.1. ask what Personal Information we hold about you;
9.1.2. ask for it to be corrected or updated;
9.1.3. ask for it to be deleted (subject to our retention obligations under law and the limits in section 10); and
9.1.4. object to processing on legitimate-interest grounds.
9.2. Requests must be made in writing to privacy@manyhands.co.za. We may require proof of identity before acting on a request.
10. Retention
10.1. We will not retain Personal Information for longer than necessary for the purposes set out above, save where retention is required or permitted by law (for example, for tax, accounting, anti-money-laundering, payment-card-network, or dispute-resolution purposes).
10.2. Conversational content with Manny is retained for as long as your Account is active and for a reasonable period thereafter to support dispute resolution and audit, after which it is deleted or de-identified.
11. Information security
11.1. We have technical and organisational measures in place to protect Personal Information against unauthorised access, loss, or alteration.
11.2. Should we become aware of a breach of our security safeguards that affects your Personal Information, we will notify you as soon as reasonably practical, in compliance with section 22 of POPIA, and will also notify the Information Regulator as required by law.
12. Passwords and one-time PINs
12.1. Where you hold an account secured by Clerk and (where applicable) a one-time PIN, you undertake to keep credentials secure and warrant that no other person will use the Platform under your credentials.
12.2. You acknowledge responsibility for ensuring that no unauthorised access to the Platform is obtained using your credentials, and that you will be liable for all activities conducted under your credentials, whether authorised or not, save where you have notified us of compromise.
13. Interception of communications
13.1. Internet-based communications can be intercepted by third parties despite reasonable safeguards. You accept this risk by using the Platform. We will not be responsible for any damages you or any third party may suffer as a result of the transmission of confidential information that you transmit through the internet, save where caused by our gross negligence or wilful misconduct.
14. PAIA and the Information Regulator
14.1. Our Promotion of Access to Information Manual is available on request to privacy@manyhands.co.za.
14.2. The Information Regulator of South Africa can be reached at:
- Post: P.O. Box 31533, Braamfontein, Johannesburg, 2017
- Email: POPIAComplaints@inforegulator.org.za
- Telephone: 010 023 5200
15. Cookies and similar technologies
15.1. We use cookies and similar technologies (including local storage and SDKs in the App) to (a) keep you signed in, (b) measure usage and improve the Platform, (c) personalise the Platform, and (d) (where you consent) measure marketing performance.
15.2. You can manage your cookie preferences from the cookie banner on the Website. Disabling cookies may prevent parts of the Platform from working.
16. Business transfer
16.1. In the event of a corporate restructure, merger, acquisition, sale of all or substantially all of our business or assets, or insolvency, your Personal Information may be transferred to the successor entity, subject to the protections of this Privacy Policy continuing to apply.
17. Casual browsing
17.1. You may visit the Website without registering or providing any Personal Information beyond standard server-log data (IP address, time of visit, pages viewed).
17.2. We use this aggregated data to measure usage and improve the Platform.
18. Legal process
18.1. When we are served with due legal process requiring the delivery of Personal Information, we have the legal duty to abide by that demand and will do so.
18.2. We may also impart Personal Information if permitted or required by law.
19. Review and updates
19.1. This Privacy Policy will be reviewed at least annually and updated as needed.
19.2. We will publish material changes on the Website.
Contact us
MANYHANDS (PTY) LTD The Penthouse Suite, 10th Floor, 74 Shortmarket Street, Cape Town, 8001 Privacy / data requests: privacy@manyhands.co.za General: info@manyhands.co.za
© ManyHands, South Africa.