Privacy Policy
Comtel Communications (Pty) Ltd · Privacy Policy
1. Introduction
1.1 Comtel Communications (Pty) Ltd with registration number 2011/011968/07 (“Comtel”, “we”, “us”, “our”) is committed to protecting the personal information of all individuals and entities that engage with our services, platforms, and partner network.
1.2 This Privacy Policy (“Policy”) explains what personal information we collect, why we collect it, how we use and protect it, who we share it with, and what rights you have as a data subject.
1.3 Comtel is a responsible party as defined in the Protection of Personal Information Act 4 of 2013 (“POPIA”). This Policy is published in compliance with POPIA and in accordance with related legislation, including the Regulation of Interception of Communications and Provision of Communication-Related Information Act 70 of 2002 (“RICA”), the Electronic Communications and Transactions Act 25 of 2002 (“ECTA”), and the Consumer Protection Act 68 of 2008 (“CPA”).
1.4 This Policy forms part of the Agreement between Comtel and its clients, as described in the General Terms and Conditions. By using Comtel’s services or platforms, you acknowledge that you have read and understood this Policy.
1.5 If you have questions about this Policy, contact our Information Officer using the details set out in section 21.
2. Scope
2.1 This Policy applies to:
(a) home and business clients who subscribe to Comtel’s internet services;
(b) partners – Sales-Support Partners and Channel Partners – who register and operate through PartnerZone;
(c) MarketPlace users, including members of the public who register on market.comtel.co.za;
(d) individuals whose personal information is processed in connection with a business client, including directors, contact persons, and authorised account users;
(e) job applicants; and
(f) visitors to Comtel’s websites and applications.
2.2 Where Comtel processes personal information on behalf of a business entity, this Policy applies equally to the personal information of the individuals within that entity.
3. Information Officer
3.1 Comtel has designated an Information Officer as required by section 55 of POPIA. The Information Officer is responsible for overseeing Comtel’s compliance with POPIA and this Policy.
3.2 Information Officer contact details:
| Field | Detail |
|---|---|
| Name | Phillip Pierce |
| connect@comtel.co.za |
3.3 Requests to exercise data subject rights, access requests under POPIA or the Promotion of Access to Information Act 2 of 2000 (“PAIA”), and formal complaints should be directed to the Information Officer.
4. Personal Information We Collect
4.1 Clients – Home and Business
4.1.1 We collect the following personal information from clients:
(a) Identity information: full name, South African identity number or passport number, and date of birth.
(b) Contact information: email address, mobile number, physical service address, and billing address.
(c) RICA-required information: proof of identity and verified physical address, as required for Electronic Communications Service subscriber registration under RICA.
(d) Financial information: banking details for debit order collection, and payment history. Payment card details are processed directly by our payment gateway and are not stored by Comtel.
(e) Service information: service address, fibre network operator (“FNO”), speed profile, service status, provisioning records, and migration and cancellation history.
(f) Device information: router type, MAC address, and device connectivity and diagnostic data.
(g) Communication and consent preferences: preferred communication channel (email, WhatsApp, or SMS), notification preferences, and the consent log record.
(h) Support and interaction records: support ticket content, Aime interaction history, and correspondence with Comtel staff.
(i) Referral and credit records: referral codes, account credit balances, credit expiry dates, and redemption history.
(j) Audit trail records: all material account actions, with timestamp and session reference.
4.2 Partners
4.2.1 In addition to the contact information set out in clause 4.1.1, we collect the following from partners during the onboarding and operating phases:
(a) trading name, legal name, company registration number, and VAT number;
(b) director identity documents;
(c) CIPC registration documents;
(d) proof of business address;
(e) tax clearance certificate;
(f) bank confirmation letter;
(g) business references;
(h) job card records, including photographs of work performed and GPS or location stamps where captured; and
(i) service performance data, including pings accepted, jobs completed, and partner ratings received.
4.3 MarketPlace Visitors
4.3.1 Members of the public who register on market.comtel.co.za provide their name and surname, email address, and mobile number for OTP verification.
4.3.2 Job request records – including service category, service area, and job description – are retained in connection with the registered visitor’s profile.
4.4 Automatically Collected Information
4.4.1 When you use our websites and applications, we automatically collect:
(a) IP address and approximate geolocation;
(b) browser type, version, and operating system;
(c) pages visited, time spent, and referring URLs;
(d) session data and authentication events; and
(e) device type and screen resolution.
5. Lawful Basis for Processing
5.1 Comtel processes personal information on one or more of the following lawful grounds under section 11 of POPIA:
(a) Contractual necessity: processing required to conclude or perform the Agreement, including account opening, identity verification, service provisioning, billing, and technical support.
(b) Legal obligation: processing required to comply with applicable law, including RICA subscriber registration, POPIA, ECTA, ICASA regulations, tax and financial record-keeping requirements, and ISPA Code of Conduct obligations.
(c) Legitimate interest: processing for fraud prevention, network security and management, credit risk assessment, and debt recovery, where such interests are not overridden by the data subject’s rights.
(d) Consent: processing for optional marketing communications, optional notification categories, MarketPlace profile publication, and other purposes for which Comtel has obtained your express consent.
6. Purposes for Which We Use Personal Information
6.1 We use personal information for the following purposes:
(a) account opening, identity verification, and RICA subscriber registration;
(b) credit assessment and fraud screening;
(c) service provisioning and activation, including coordination with FNOs;
(d) billing, invoicing, and debit order management;
(e) technical support, fault diagnosis, and resolution;
(f) service migration, relocation, and cancellation;
(g) router and device management and replacement;
(h) network management, performance monitoring, and security;
(i) partner assignment and managed call-out coordination;
(j) referral programme and gift code administration;
(k) PlayComtel audience engagement and competition administration;
(l) communication via email, WhatsApp, and SMS;
(m) legal and regulatory compliance and reporting;
(n) debt collection and credit bureau reporting where applicable;
(o) platform improvement and analytics, using aggregated or anonymised data where possible; and
(p) any other purpose notified to you at the time of collection or to which you subsequently consent.
7. Third-Party Sharing
7.1 Comtel may share personal information with the following categories of third parties, to the extent necessary for the purposes set out in this Policy:
(a) FNOs, for service provisioning, activation, fault escalation, and migration;
(b) payment processors, for billing and debit order management;
(c) courier companies, for router and device delivery;
(d) Comtel Partners – Sales-Support Partners and Channel Partners – for service management, managed call-out coordination, and onsite support;
(e) credit bureaus, for credit assessment and the reporting of payment behaviour, defaults, or arrears in accordance with applicable law;
(f) registered debt collectors and attorneys, for recovery of overdue amounts;
(g) professional advisers, including legal advisers, auditors, and compliance consultants;
(h) ISPA, for compliance and takedown notice processing under the ISPA Code of Conduct;
(i) law enforcement bodies, regulators, courts, and other public authorities, as required or permitted by law; and
(j) the Information Regulator, as required by POPIA.
7.2 We require all third parties who receive personal information from Comtel to handle it in compliance with POPIA. We do not sell personal information to any third party.
8. MarketPlace – Disclosure of Contact Details
8.1 Comtel MarketPlace (market.comtel.co.za) enables clients and registered visitors to submit job requests to vetted onsite service partners.
8.2 When a client or registered visitor submits a job request through MarketPlace, their contact details – including name, mobile number, email address, and service area – may be disclosed to up to three compatible vetted partners who accept the request. This disclosure is necessary to facilitate the requested service.
8.3 By submitting a job request, you consent to the limited disclosure described in clause 8.2 for the purpose of facilitating that service.
8.4 MarketPlace partners who receive contact details are bound by Comtel’s platform terms and their own obligations under POPIA.
9. Automated Processing and AI-Assisted Services
9.1 Comtel’s platforms include Aime, an AI-assisted service agent available on ClientZone, PartnerZone, FibreZone, and related applications. Aime receives structured context data – including account status, service details, and permitted actions – to provide contextual assistance relevant to your session.
9.2 Aime does not make material decisions about accounts, services, or personal information without human oversight. Decisions that materially affect a client’s rights or obligations – including service suspension, credit assessments, and account termination – are subject to human review.
9.3 Comtel may use automated processes for purposes such as fraud detection, payment processing, and system notifications. Where an automated decision significantly affects you, you have the right to request human review by contacting the Information Officer.
10. Communication Channels
10.1 Comtel communicates with clients and partners via email, WhatsApp, and SMS. You select your preferred channel at signup and may update your preference in ClientZone or PartnerZone at any time.
10.2 Required notifications – including service alerts, billing notices, security notices, and legal notices – may be sent across all three channels regardless of your stated preference, to ensure delivery of material information.
10.3 Marketing and optional notifications are sent only to your preferred channel and may be turned off at any time through your notification settings.
11. Consent and the Consent Log
11.1 Where Comtel processes personal information on the basis of consent, you may withdraw that consent at any time by updating your preferences in ClientZone or by contacting the Information Officer. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
11.2 ClientZone maintains a consent log recording every notification preference change, including what was opted into or out of, when, via which channel, and the associated session reference. This record supports POPIA compliance and is available to you on request.
12. Data Security
12.1 Comtel implements appropriate technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss, destruction, or unlawful processing.
12.2 These measures include:
(a) access controls and role-based permissions across all platforms;
(b) encryption of personal information in transit;
(c) audit trails for all material account and system actions;
(d) OTP verification for material account changes;
(e) regular security assessments and monitoring; and
(f) staff training on data protection obligations.
12.3 In the event of a security compromise involving personal information, Comtel will notify the Information Regulator and affected clients as required by section 22 of POPIA, in accordance with clause 25 of the General Terms and Conditions. Notification will be sent via the client’s registered communication channel.
12.4 Comtel maintains an incident log recording all security compromises involving personal information.
12.5 No transmission method over the internet is completely secure. While Comtel takes all reasonable steps to protect personal information, absolute security cannot be guaranteed.
13. Data Retention
13.1 Comtel retains personal information for as long as is necessary for the purposes set out in this Policy and as required by applicable law.
13.2 On expiry of the applicable retention period, personal information is securely deleted, anonymised, or archived in accordance with Comtel’s data governance procedures.
14. Cross-Border Transfers
14.1 Some personal information may be processed or stored outside South Africa where Comtel uses cloud infrastructure or third-party service providers whose servers are located in other jurisdictions.
14.2 Where personal information is transferred outside South Africa, Comtel takes steps to ensure that the recipient provides a level of protection substantially equivalent to POPIA’s requirements, in accordance with section 72 of POPIA. The specific mechanisms used for such transfers are available from the Information Officer on request.
15. Cookies and Tracking Technologies
15.1 Comtel’s websites and web applications use cookies and similar tracking technologies to:
(a) maintain session state and user authentication;
(b) remember user preferences;
(c) analyse usage patterns and improve our platforms; and
(d) support security monitoring.
15.2 You may disable cookies through your browser settings. Disabling essential cookies may impair the functionality of Comtel’s platforms.
15.3 A detailed cookies notice is published at fibre.comtel.co.za/legal/cookies.
16. Minors
16.1 Comtel’s services are not directed at persons under 18 years of age, as defined in POPIA.
16.2 We do not knowingly collect personal information from minors without the consent of a competent person, as defined in POPIA.
16.3 If we become aware that personal information has been collected from a minor without appropriate consent, we will take steps to delete or cease processing that information as soon as reasonably practicable.
17. Third-Party Links and Public Platforms
17.1 Comtel’s websites and applications may contain links to third-party websites, including social media platforms. We are not responsible for the privacy practices or content of those sites and we recommend that you read their privacy policies before disclosing personal information.
17.2 Information that you disclose voluntarily on public platforms – including social media, public forums, or public areas of our websites – is not subject to this Policy once it has been made public.
18. Your Rights as a Data Subject
18.1 Under POPIA, you have the following rights in respect of personal information that Comtel holds about you:
(a) Right of access: you may request confirmation of whether Comtel holds personal information about you and, if so, a description or copy of that information.
(b) Right to correction or deletion: you may request correction or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or unlawfully obtained.
(c) Right to object: you may object to the processing of your personal information on reasonable grounds relating to your particular situation, unless processing is required by law or is necessary for the performance of a contract.
(d) Right to withdraw consent: where processing is based on consent, you may withdraw that consent at any time.
(e) Right to human review of automated decisions: you have the right to request human review of any decision made solely on the basis of automated processing that produces legal or similarly significant effects on you.
(f) Right to lodge a complaint: you may lodge a complaint with the Information Regulator as described in section 19.
18.2 To exercise any of the rights set out in clause 18.1, submit a written request to the Information Officer using the contact details in section 21. Comtel will respond within a reasonable time and in accordance with POPIA’s requirements.
18.3 Access to personal information may also be requested under PAIA. Comtel’s PAIA manual is available on request from the Information Officer.
19. Complaints to the Information Regulator
19.1 You have the right to lodge a complaint with the Information Regulator if you believe that Comtel has processed your personal information in breach of POPIA.
19.2 Comtel encourages you to contact the Information Officer first so that we may attempt to resolve your concern directly and promptly.
19.3 Information Regulator contact details:
| Field | Detail |
|---|---|
| Name | Information Regulator (South Africa) |
| Website | www.inforeg.org.za |
| General enquiries | inforeg@justice.gov.za |
20. Changes to This Policy
20.1 Comtel may update this Policy from time to time in response to changes in applicable law, our technology, or our business operations.
20.2 For material changes – including changes to the purposes for which we process personal information, the categories of third parties with whom we share it, or your rights – we will notify you through your registered communication channel (email, WhatsApp, or SMS) before the change takes effect.
20.3 The current version of this Policy is always available at fibre.comtel.co.za/legal/privacy-policy.
20.4 Continued use of Comtel’s services after notification of a material change constitutes acceptance of the updated Policy.
21. Contact Details
21.1 For questions about this Policy, to exercise your data subject rights, or to submit a complaint:
| Field | Detail |
|---|---|
| Information Officer | Phillip Pierce |
| connect@comtel.co.za | |
| Website | comtel.co.za/privacy-policy |
21.2 Comtel will acknowledge all requests within a reasonable time and resolve them in accordance with the timeframes prescribed by POPIA.