Code Zen as responsible party
When Code Zen determines why and how personal information relating to its own prospects, enquiries, clients or website visitors is processed, Code Zen generally acts as the responsible party for that processing.
Privacy and Data Protection
Privacy Policy
This Privacy Policy explains how Code Zen collects, uses, stores and protects personal information when people interact with our website, advertising, communications, systems and services.
Effective date: 25 August 2026
About this policy:
This policy is intended to explain Code Zen's privacy practices in clear language. It does not constitute a guarantee of legal compliance and should be read together with any applicable service agreement or other terms relevant to a particular service.
Introduction
Code Zen respects the privacy of the people and businesses whose personal information we process. We aim to process personal information responsibly and in accordance with applicable South African data-protection requirements, including the Protection of Personal Information Act 4 of 2013 ("POPIA").
This Privacy Policy explains the types of personal information Code Zen may process, where that information may come from, why it may be used, when it may be shared, and the choices and rights available to a person whose personal information is involved.
The way a particular item of information is processed depends on the circumstances in which Code Zen receives it and the service being provided.
Who Code Zen is
Code Zen is a digital agency and technology service provider. Our services may include smart websites, customer relationship management ("CRM") systems, lead capture, WhatsApp automation, AI-enabled systems, lead management, booking and enquiry workflows, customer follow-up, database-reactivation services and related digital and automation services.
Depending on the service, Code Zen may process information about its own prospective clients and customers or may process information on behalf of a client as part of delivering an agreed service.
Code Zen's different data-processing roles
Code Zen may have different responsibilities depending on why and for whom personal information is being processed.
Code Zen as operator or service provider
When a client supplies information to Code Zen and Code Zen processes that information under the client's instructions in order to provide an agreed service, Code Zen may act as an operator or service provider for that client.
Client data remains client data.
Code Zen does not treat a client's customer database as Code Zen's own customer or marketing database merely because Code Zen processes that information while delivering a service.
Information we may collect
Depending on the way a person or business interacts with Code Zen, the personal information processed may include:
- Name and surname.
- Business or salon name.
- Email address.
- Telephone or WhatsApp number.
- Town, city or business location.
- The nature of an enquiry or service requirement.
- Approximate customer or contact-database size where relevant to an enquiry or proposed service.
- Information about a booking, CRM, salon, management or other business system being used.
- Appointment, consultation and meeting information.
- Messages and other communications exchanged with Code Zen.
- Information submitted through website contact or enquiry forms.
- Information submitted through Facebook or Instagram Lead Forms or other Meta lead advertising.
- IP address, browser type, device information and website-usage information where collected by the website or associated technologies.
- Cookie, analytics, advertising-measurement, Meta Pixel or similar technical information where those technologies are enabled.
- Information reasonably required to implement, maintain or provide a contracted Code Zen service.
Code Zen aims to collect only information that is relevant to the purpose for which it is being processed.
How information is collected
Personal information may be collected directly from a person or business, automatically through appropriate website technologies, or from a Code Zen client where the information is required to deliver an agreed service.
Collection methods may include:
- The Code Zen website.
- Website contact and enquiry forms.
- Meta Facebook and Instagram lead advertisements and Instant Forms.
- WhatsApp conversations.
- Email communications.
- Telephone calls.
- Meetings and consultations.
- CRM and booking systems.
- Information supplied by clients for the delivery of contracted services.
- Cookies, pixels, analytics and similar technologies where enabled.
Why we process personal information
Code Zen may process personal information for legitimate business and service-delivery purposes, including:
- Responding to enquiries.
- Understanding a business's needs and assessing whether Code Zen services may be suitable.
- Preparing proposals, quotations or service recommendations.
- Providing contracted services.
- Managing client relationships.
- Arranging and managing consultations, calls or meetings.
- Sending information that has been requested.
- Following up on a genuine enquiry relating to Code Zen's services.
- Operating agreed CRM, communication, automation and follow-up systems.
- Improving Code Zen's website, processes and services.
- Understanding website activity and measuring advertising or marketing performance where suitable technologies are used.
- Protecting Code Zen, its systems and its clients against misuse, fraud or security threats.
- Complying with applicable legal, accounting, contractual and regulatory obligations.
Lawful processing and consent
Code Zen processes personal information only where there is an appropriate basis for doing so under applicable law.
Depending on the circumstances, this may include situations where:
- A person has provided consent.
- Processing is necessary to respond to a request or enquiry made by the person.
- Processing is necessary to prepare for, conclude or perform a contract.
- Processing is required in order to comply with a legal obligation.
- Processing protects or pursues a legitimate interest of Code Zen, a client or another relevant party, provided the processing is reasonable in the circumstances and does not unjustifiably interfere with a person's privacy.
Where consent is relied upon and the law permits withdrawal, a person may withdraw that consent. Withdrawal does not necessarily affect processing that lawfully occurred before the withdrawal.
Direct marketing and communications
When a person submits a genuine business enquiry to Code Zen, Code Zen may use the contact details provided to respond to that enquiry and to carry out reasonable related follow-up concerning the requested service or discussion.
Submitting an enquiry does not by itself mean that a person has agreed to receive unrelated ongoing promotional marketing indefinitely.
Where Code Zen sends electronic direct marketing, it will do so only where permitted by applicable law. Depending on the circumstances, this may involve the person's consent or an applicable existing-customer basis permitted under POPIA.
Where required, consent for ongoing promotional marketing will be handled separately from the person's original enquiry.
A recipient may unsubscribe, object to eligible direct marketing, or ask Code Zen to stop sending promotional communications. Code Zen will take reasonable steps to record and respect valid opt-out requests. Privacy or marketing-preference requests may be sent to [email protected].
Client database-reactivation services
Some Code Zen services may involve helping a client communicate with existing, previous, dormant or otherwise relevant contacts contained in that client's own database.
Where Code Zen processes customer or contact information on behalf of a client for this purpose:
- The client remains responsible for determining and establishing an appropriate lawful basis for its customer information and the proposed campaign or communication.
- Code Zen processes the information for the agreed service and within the scope of the client's instructions and applicable service arrangements.
- Code Zen takes reasonable steps to apply appropriate access and security controls to information it processes.
- A client's customer information is not treated as Code Zen's own marketing database.
- Code Zen does not sell the client's customer information.
Code Zen may also advise clients on practical opt-out, workflow and data-handling measures, but responsibility for a client's legal basis and business-specific obligations remains subject to that client's own circumstances and obligations.
GoHighLevel, Meta and other technology platforms
Code Zen may use third-party technology platforms to operate its own systems or to provide services to clients.
Depending on the implementation, these may include systems such as GoHighLevel, Meta services including Facebook and Instagram, WhatsApp, website-hosting providers, communication providers and analytics technologies.
These third parties may process information under their own terms, contractual arrangements, technical architecture and privacy practices. Code Zen does not control every independent privacy or security practice of an external technology provider.
Where Code Zen selects or configures providers, it takes reasonable steps to use established services and to manage access and information in a manner appropriate to the service being delivered.
Cross-border processing
Some of the technology providers used by Code Zen or its clients may operate infrastructure or process or store information in countries outside South Africa.
Where personal information is transferred or processed outside South Africa, Code Zen aims to take reasonable steps to use appropriate providers, contractual arrangements and other safeguards consistent with applicable requirements.
The exact location and mechanisms may depend on the provider and the particular service being used.
Information security
Code Zen takes reasonable technical and organisational measures appropriate to the nature of its services and the information being processed in order to reduce the risk of:
- Loss of information.
- Misuse.
- Unauthorised access.
- Unauthorised disclosure.
- Unauthorised alteration.
- Destruction.
These measures may include access controls, account security, permission management, use of reputable infrastructure providers and other operational security practices where appropriate.
No website, communication channel, cloud platform or digital system can be guaranteed to be completely secure. Code Zen therefore continues to assess reasonable security measures as systems and risks change.
Information retention
Code Zen aims to retain personal information only for as long as reasonably necessary for the purpose for which the information was collected or subsequently processed, subject to applicable legal and operational requirements.
Relevant considerations may include:
- The purpose for which the information is used.
- The duration of a client relationship.
- Contractual and service requirements.
- Operational record keeping.
- Resolving disputes or enquiries.
- Accounting, regulatory or other applicable legal retention obligations.
Information that is no longer reasonably required may be deleted, destroyed, anonymised or otherwise handled in accordance with applicable requirements and the circumstances of the processing.
Data-subject rights
Subject to applicable law and the circumstances of the request, a person may have the right to ask Code Zen to:
- Confirm whether Code Zen holds personal information about that person.
- Provide access to personal information where legally applicable.
- Correct or update inaccurate or incomplete information.
- Delete or destroy personal information where legally appropriate.
- Consider an objection to certain processing.
- Record a withdrawal of consent where consent is the relevant basis and withdrawal is permitted.
- Stop eligible direct-marketing communications.
Code Zen may need to take reasonable steps to verify the identity and authority of the person making a request before releasing, changing or deleting information.
Where Code Zen is acting only as an operator for a client, the request may need to be directed to or handled together with the client that is the responsible party for that information.
Privacy requests can be sent to [email protected].
Complaints
If a person has a question or concern about the way Code Zen has handled personal information, Code Zen encourages the person to contact us first at [email protected] or on 076 418 3721 so that the matter can be considered.
A person may also lodge a complaint with South Africa's Information Regulator where applicable.
Official Information Regulator website: inforegulator.org.za
Children's information
Code Zen's services are directed primarily at businesses and adults.
Code Zen does not intentionally design its ordinary business-enquiry forms for the collection of children's personal information.
If Code Zen becomes aware that children's information has been supplied in circumstances where it should not reasonably have been collected, Code Zen may take appropriate steps in accordance with the circumstances and applicable requirements.
Third-party links
The Code Zen website, messages or digital services may contain links to websites, applications or platforms operated by third parties.
Those external services have their own terms, technologies and privacy practices. Code Zen does not control all information processing performed independently by third parties merely because a link to their service appears on a Code Zen website or communication.
Visitors should review the privacy information of relevant third-party services where appropriate.
Changes to this Privacy Policy
Code Zen may update this Privacy Policy from time to time to reflect changes in its services, technologies, business practices or applicable requirements.
The effective date displayed near the top of this page indicates the version currently published.
Where a material change reasonably requires additional communication or consent, Code Zen will consider the appropriate steps in the circumstances.
Contact Code Zen
Questions about this Privacy Policy, privacy requests, marketing-preference requests or concerns regarding personal information can be directed to Code Zen using the contact information below.