Veriflow: Cookie Notice

1. Who we are

1.1 This website is operated by Veriflow (Pty) Ltd, registration number 2023/584644/07, a private company incorporated in the Republic of South Africa, of 51 Ingersol Road, Lynnwood Glen, Pretoria, 0081, South Africa.

1.2 You can reach us about anything in this notice at support@veriflow.co.za or +27 83 209 0827.

1.3 Information Officer. This notice refers to the Protection of Personal Information Act 4 of 2013 (POPIA) and the Promotion of Access to Information Act 2 of 2000 (PAIA). “Information Officer” means Veriflow’s information officer as contemplated in section 1 of PAIA read with section 1(b) of POPIA, being the head of the body or a person duly authorised by that officer. The Information Officer is reachable at support@veriflow.co.za, marked for the attention of the Information Officer. The officer is named, with full contact details, in the Veriflow PAIA Manual, clause 2.3, and this notice states no more than the role and one address.

1.4 This notice works together with the Veriflow Privacy Notice (website), which explains what we do with information sent through this website. If anything here conflicts with the Privacy Notice, the Privacy Notice governs the processing itself; this notice governs cookies and similar technologies on the website.

1.5 This notice is not a contract and does not create contractual obligations. Where it is referenced in an agreement, the agreement governs.

2. What this notice covers

2.1 “Cookies” here means cookies and similar technologies: small files or records placed on your browser or device, plus equivalents such as localStorage, sessionStorage, pixels, tags and software development kit identifiers.

2.2 Where a cookie identifies you, or is used to profile or market to you, the information involved is personal information under POPIA, and POPIA protects identifiable, existing juristic persons as well as natural persons, so this notice applies whether you browse as a person or on behalf of a business.

2.3 What this notice does not cover. The Veriflow client platform at veriflowportal.co.za is a separate domain, reached by logging in, and is outside the scope of this notice.

3. Our current position: this website sets no cookies

3.1 As at the effective date stated at the head of this notice, www.veriflow.co.za sets no cookies at all. It stores nothing in your browser’s localStorage or sessionStorage, fires no pixels or tags, runs no analytics or advertising tool, and embeds nothing from another company’s servers: the fonts, stylesheets, scripts, images and video this website uses are served from Veriflow’s own domain. Nothing is placed on your device by this website, and no third party is contacted by your browser because you visited it.

3.2 There is therefore no consent banner and no “cookie settings” control on this website. There is nothing to consent to and nothing to switch off.

3.3 The enquiry form on our contact page posts to Veriflow’s own server and not to a third party. It sets no cookie and stores nothing on your device. What we do with the information you type into it is dealt with in the Veriflow Privacy Notice (website), clause 4.

3.4 We do not use cookies to make automated decisions about you, and browsing this website is never part of a verification.

4. Why there is no consent banner

4.1 South African law does not name cookie banners in any statute. What POPIA requires is openness: section 18 obliges us to tell you what we collect and why. Where a cookie involves personal information, we would also need a lawful ground under section 11(1) of POPIA before setting it, and section 69 of POPIA restricts direct marketing by electronic communication to people who have consented or, subject to conditions, are existing customers.

4.2 The Information Regulator’s Guidance Note on Direct Marketing, listed by the Regulator with the date 3 December 2024, carries its only published statements on the quality of consent: consent must be a positive choice between giving and refusing it, silence is not consent, and the party relying on consent bears the onus of proving it under section 11(2)(a) of POPIA.

4.3 We have therefore taken the most privacy-preserving position available: we run nothing that needs your consent. No analytics tool, no advertising tag, no third-party embed, and so no banner. If that ever changes, clause 6 says what we will do first.

5. Cookie categories and lawful basis

5.1 If this website ever sets cookies, they will be grouped into the four categories below and each one will be listed in this table before it is used. Every category is currently empty, and the table is published in that state deliberately, so that a reader can see what would change and on what basis.

5.2 For every cookie we ever set, this table will state its name, who sets it (us or a named third party), what it is for, and how long it lasts.

5.3 Third parties. This website currently embeds no third-party tool, widget or content, so no other company sets a cookie through it. If a tool of that kind is ever embedded (a booking calendar for demonstrations, a chat widget or embedded social media content are the usual candidates) the provider will be named in this clause, its cookies listed in the table above, and the embed will not load until you have opted in to the relevant category.

6. How consent would work, if it is ever needed

6.1 This clause is a commitment about the future, not a description of something already built. Veriflow will not introduce a functional, analytics or marketing technology on this website except on the following terms.

• (a) This notice is updated first. The technology is inventoried, added to the table in clause 5, and a new version and effective date are published before it runs.
• (b) Nothing non-essential runs until you say so. No script is injected, no cookie is set, no pixel is fired and no request is sent to the provider until you opt in to that category.
• (c) Refusing is as easy as agreeing. Refusal is available in the same number of clicks, at the same level and with the same prominence, as agreement. There is no cookie wall: the website works fully whichever you choose.
• (d) Granular and unticked. Each non-essential category has its own control, every control starts switched off, no box is pre-ticked, and silence or inactivity is never treated as consent.
• (e) Informed. You are given this notice and the Privacy Notice, and told who the provider is, before you choose.

7. Controlling cookies in your browser

7.1 Because this website sets no cookies, there is currently no consent to withdraw and nothing for you to clear. If that ever changes, clause 6(c) and clause 6(d) apply, and withdrawing consent will be as easy as giving it.

7.2 You can in any event block or delete cookies in your browser settings, and each browser’s own help pages explain how. Doing so will not affect anything on this website, because there is nothing to block.

7.3 You can also email us at support@veriflow.co.za with any question about this notice, and we will answer it.

8. Records we would keep

8.1 No consent record exists today, because no consent is asked for. If a consent-requiring technology is ever introduced, we will record what was chosen, when it was chosen and which version of this notice was shown, so that we can show the basis on which any cookie ran; and where marketing consent is refused, we will record the refusal so that the person is not approached again improperly.

8.2 Consent and refusal records would be kept only as long as needed to show the basis on which a cookie ran, and this notice would say how long before any such tool went live.

9. What we do not do

9.1 We do not sell personal information collected through cookies, we do not track you across other websites, and we do not build a profile of you from your browsing of this website.

9.2 We do not use cookies from this website in the identity-verification services themselves. Personal information processed in a verification is governed by the client’s relationship with the person verified and by our contracts with clients: the client is the responsible party and owes that person the section 18 notice, and Veriflow is its operator (Veriflow Privacy Notice (website), clause 2.2). If a business asked you to verify your identity through Veriflow, this page is written for you.

10. Complaints

10.1 If you are unhappy with how we handle cookies, please contact our Information Officer first (clause 1.3). You also have the right to complain to the Information Regulator (South Africa) at https://inforegulator.org.za or through its eServices portal at https://eservices.inforegulator.org.za.

11. Changes to this notice

11.1 We will update this notice whenever the position it describes changes, and it is reviewed annually in any event. The version number and the effective date at the top tell you what you are reading.

11.2 A change that introduces a consent-requiring technology will be made by publishing an updated notice first and then asking for consent, in that order. It will not be made by a silent edit to this page.