1. Who is responsible
Asset Disposal Consultancy (Pty) Ltd (registration number 2018/621824/07), trading as Ledger Data, is the responsible party for the personal information described in section 3 below. Our Information Officer is John Bruce Taylor, reachable at jt@asset-disposal.co.za.
Two different roles, and the difference matters. For the accounts of the people who use Ledger Data, we are the responsible party — this policy covers that. For the documents a firm uploads into its own data room, the firm is the responsible party and we are its operator, processing on its instruction. That relationship is governed by the Operator Agreement, and questions about documents in a particular data room should go to the firm that runs it.
2. Who this covers
- Practitioners and their colleagues — people at a firm with an account.
- Viewers — people invited into a data room by a firm.
- People who ask for an account through the request form on our website.
3. What we hold, and why
| Name and email address | To create an account, to identify who did what, and to send the messages the service depends on. Without it there is no account. |
|---|---|
| Password | Held only as a one-way hash. We cannot read it and cannot recover it. |
| Telephone number and firm name | Given when asking for an account, so we can confirm who is asking before opening one. |
| Company name of a viewer | Recorded by the firm that invites them. |
| Sign-in records and IP addresses | To detect and limit attacks on accounts, and to answer the question of who signed in and from where. |
| Audit records | Every document opened or downloaded, by whom and when. This is the core purpose of the service: a firm must be able to prove who saw what. |
| Two-step sign-in data | An authenticator secret, or a temporary emailed code, and hashed recovery codes. |
| Documents uploaded by a firm | Held on the firm's instruction. These may contain personal information about third parties; the firm decides what goes in. |
4. On what basis
We process this information because it is necessary to perform the contract with the firm or to take steps at your request before entering one; because we have a legitimate interest in keeping the service secure and in being able to demonstrate who accessed what; and, in places, because the law requires it. Where we rely on consent we ask for it separately and you may withdraw it.
5. Watermarking, and what viewers should expect
Documents served to a viewer are stamped with that viewer's name, email address and the date. This is deliberate and it is disclosed here because a viewer should know it: it makes a leaked document traceable to the login that received it. Every view and download is recorded and reported to the firm that granted the access.
6. Who else touches it
We do not sell personal information and we do not use it for advertising. We use these service providers, and no others:
| Hetzner Online GmbH | Hosting of the application, the documents and the database. Servers in Helsinki, Finland. |
|---|---|
| Postmark (ActiveCampaign, LLC) | Sending the emails the service generates — invitations, sign-in links, notices. Receives names and email addresses, not documents. United States. |
| Microsoft (OneDrive) | Storage of backups. Backups are encrypted before they leave our control, so the contents are not readable by the storage provider. |
| Afrihost | Domain registration for ledgerdata.co.za. No personal information of users passes to them. |
7. Information leaving South Africa
Your information is stored outside South Africa. The servers are in Finland, and the email provider is in the United States.
Section 72 of POPIA permits this where the recipient is subject to a law or binding agreement that upholds principles for lawful processing comparable to POPIA. Finland is in the European Union and subject to the GDPR. Our providers are engaged under written data processing terms that impose comparable obligations.
8. How long we keep it
- Account information — while the account exists, and for a reasonable period afterwards to answer questions about past access.
- A firm's documents — while the firm's account is open, and for 60 days after it closes, after which they are deleted.
- Audit records — kept for as long as the firm's account exists. They are append-only: the database refuses to alter or delete them, which is what makes them worth producing. An erasure request that would require deleting an audit record is dealt with under section 10.
- Requests for an account that we decline — kept as a record that the request was made and considered.
9. How we protect it
- Encrypted connections for every page, with certificates that renew automatically.
- Passwords stored as one-way hashes; two-step sign-in available to every user.
- Rate limiting on sign-in, on invitations and on two-step codes.
- Cross-site request forgery protection on every form.
- The application runs as a limited account, not as an administrator, and listens only behind the web server. The firewall permits three ports.
- Backups encrypted before they leave our control.
- An append-only audit trail enforced by the database itself.
Uploads are not yet scanned for malware. Files are stored and never executed or opened on our servers, but a document is passed to a recipient as it arrived. We state this plainly rather than leave it to be discovered.
10. Your rights
Under POPIA you may:
- ask what personal information we hold about you, and be given a copy;
- ask us to correct or complete anything that is wrong;
- ask us to delete information we no longer have a lawful basis to keep;
- object to processing based on legitimate interest; and
- complain to the Information Regulator.
Write to jt@asset-disposal.co.za. We will respond within 30 days. If your request concerns documents inside a firm's data room, we will refer you to that firm, which is the responsible party for them.
Where a right conflicts with the append-only audit trail — for example a request to erase a record that a document was opened — we will explain the conflict, the legal basis for keeping the record, and your right to take it to the Regulator.
11. If something goes wrong
If personal information is accessed by someone unauthorised, we will notify the Information Regulator and the affected people as soon as reasonably possible after establishing what happened, as section 22 of POPIA requires, and tell you what was affected and what to do.
12. Cookies
Ledger Data sets one cookie, which keeps you signed in. It is strictly necessary for the service to work and is not used to track you. We use no analytics, no advertising trackers and no third-party scripts.
13. The Information Regulator
Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg 2001 · complaints.IR@justice.gov.za · inforegulator.org.za
14. Changes
If we change this policy in a way that materially affects you, we will tell account holders by email at least 30 days beforehand.