YOUR DATA. YOUR RIGHTS. OUR DUTY.

Introduction

Shawn Inc respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, process, store, disclose, and protect personal information when you visit our website, communicate with us, purchase our products, or engage our professional services.

Shawn Inc is a trading brand operated by Adversa Holdings (PTY) LTD, a private company registered in the Republic of South Africa under registration number 2024/477200/07.

For the purposes of the Protection of Personal Information Act 4 of 2013 (POPIA), Adversa Holdings (PTY) LTD acts as the responsible party for personal information where it determines the purposes and means of processing.

This Policy applies to:

• Visitors to our website, shawnpale.com
• Prospective clients and individuals submitting enquiries
• Clients purchasing or receiving our services
• Customers purchasing digital products, eBooks, and downloadable resources
• Individuals communicating with us through email, telephone, forms, or messaging platforms
• Newsletter subscribers and marketing recipients
• Suppliers, contractors, and business representatives
• Other individuals whose personal information we lawfully process in connection with our business activities

By using our services, you acknowledge that you have been provided with this Privacy Policy. Where consent is legally required, we will request it separately.

Personal Information We Collect

The personal information we collect depends on how you interact with Shawn Inc.

How We Collect Information

We may collect personal information through the following channels.

3.1 Directly from You

When you:

• Complete a contact or quotation form
• Book a consultation
• Subscribe to marketing communications
• Purchase a service or digital product
• Make a payment
• Communicate with our team
• Submit project requirements
• Request customer support

3.2 Automatically Through Our Website

Certain technical information may be collected through server logs, cookies, analytics tools, and tracking technologies.

3.3 From Third-Party Platforms

Where lawful and relevant, we may receive information from:

• Payment processing providers
• Website and e-commerce platforms
• Customer relationship management systems
• Advertising and analytics platforms
• Appointment scheduling platforms
• Social media platforms
• Authorised integration providers

3.4 From Other Lawful Sources

We may obtain business contact information through referrals, publicly available business information, or legitimate business introductions.

Public availability does not automatically authorise unrestricted collection, use, or direct marketing. Any subsequent processing must comply with applicable law.

Purposes for Processing Personal Information

Shawn Inc collects and processes personal information for specific, lawful business purposes.

These include:

Lawful Basis for Processing

We process personal information only where a lawful justification exists under POPIA.

Depending on the circumstances, these grounds may include:

Consent: Where you have voluntarily agreed to a specific form of processing, such as receiving certain marketing communications.

Contractual necessity: Where processing is necessary to conclude or perform a contract with you.

Legal obligation: Where we must retain or process information to comply with applicable legislation.

Legitimate interests: Where processing is necessary to pursue a legitimate interest of Shawn Inc or a third party, provided the requirements of POPIA are satisfied.

Protection of your legitimate interests: Where processing is necessary to protect your lawful interests.

We will not rely on consent where it is not the appropriate legal justification, nor will we assume that use of our website constitutes consent to every form of data processing.

Where consent is required, you may withdraw it, subject to applicable legal limitations.

Withdrawal of consent does not automatically invalidate processing lawfully undertaken before the withdrawal.

Mandatory and Optional Information

Certain personal information is required to provide our services.

For example:

• An email address may be needed to respond to an enquiry.
• Contact and project information may be required to prepare a quotation.
• Billing information may be required to process a transaction.
• Client-provided access credentials may be necessary to complete agreed technical work.

If required information is not provided, we may be unable to complete the requested transaction or service.

Other information, including optional marketing preferences, is voluntary.

We will endeavour to identify mandatory information clearly when collecting it and explain any material consequences of not supplying it.

Cookies and Tracking Technologies

Our website may use cookies, tracking pixels, scripts, and similar technologies.

Cookies are small data files stored on or accessed through your device. They support website operation, remember preferences, and help measure website activity.

Advertising, Remarketing and Conversion Tracking

Shawn Inc may use online advertising platforms to promote its services and measure campaign effectiveness.

Advertising-related processing may involve:

• Measuring website conversions
• Analysing advertisement engagement
• Understanding traffic sources
• Building permitted audience segments
• Measuring campaign performance
• Delivering relevant advertising where lawfully permitted

Where applicable, advertising technologies may collect information such as browser identifiers, page visits, conversion events, and related technical data.

We will not knowingly upload personal contact lists or disclose identifiable customer data for advertising purposes without an appropriate lawful basis and compliance with applicable platform requirements.

Users may exercise available advertising preferences through the relevant platform or website privacy controls.

An individual who opts out of personalised advertising may still encounter general advertisements unrelated to their personal information.

Email Marketing and Direct Communications

Shawn Inc may send marketing communications through email or other electronic channels where legally permitted.

We will comply with the direct marketing requirements of POPIA, including section 69.

Where consent is required, we will seek valid consent rather than treating silence, inactivity, or a preselected checkbox as approval.

Where the existing-customer exception applies, communications will be limited to the circumstances permitted by law, including marketing our own similar products or services and providing an opportunity to object.

Every electronic marketing communication will provide an appropriate way to opt out or unsubscribe.

You may also request removal from our marketing communications by emailing:

support@shawnpale.com

Opting out of marketing does not necessarily prevent us from sending essential transactional communications, including invoices, purchase confirmations, project updates, or legally required notices.

Customer Relationship Management and Automation

We may use customer relationship management (CRM) systems and workflow automation tools to manage enquiries and client relationships.

These systems may assist with:

• Recording contact details
• Tracking quotation requests
• Scheduling consultations
• Sending transaction confirmations
• Delivering purchased digital products
• Assigning customer enquiries
• Monitoring project communication
• Managing lawful follow-up workflows
• Organising customer support requests

Automated communications may be triggered by actions such as submitting a form, booking an appointment, or purchasing a product.

We will take reasonable steps to ensure that automation is used for legitimate, disclosed purposes and that marketing communications comply with applicable consent requirements.

Digital Products and Online Purchases

When you purchase an eBook, template, digital resource, or other online product from Shawn Inc, we may collect the information required to process and fulfil your order.

This may include:

• Your name
• Email address
• Billing details
• Product purchased
• Transaction reference
• Payment confirmation
• Delivery or access status

This information may be used to:

• Confirm your purchase
• Deliver the purchased product
• Provide purchase-related support
• Resolve access issues
• Process refunds where applicable
• Maintain accounting and transaction records

Purchasing a digital product does not automatically enrol you in unrelated marketing communications.

Where marketing consent is required, it will be requested separately.

Sharing Personal Information

Shawn Inc does not sell customer contact databases to third-party data brokers.

We may, however, share personal information with trusted third parties where reasonably necessary, lawful, and relevant to the purposes described in this Policy.

Recipients may include:

12.1 Hosting and Infrastructure Providers

To operate our website, maintain systems, and store relevant data.

12.2 Payment Service Providers

To facilitate secure transactions, process payments, manage payment confirmations, and support refunds.

12.3 CRM and Communication Providers

To manage enquiries, deliver customer communications, and maintain service records.

12.4 Analytics and Advertising Providers

To measure website activity, evaluate advertising campaigns, and support permitted marketing activities.

12.5 Professional Service Providers

Including accountants, legal advisers, contractors, and service providers who require relevant information to fulfil authorised duties.

12.6 Regulatory or Legal Authorities

Where disclosure is required by law, a lawful process, or another legally recognised ground.

Third-party service providers acting on our behalf are expected to handle personal information appropriately and implement reasonable confidentiality and security protections.

We will limit disclosure to information reasonably necessary for the applicable purpose.

International Data Transfers

Some technology providers, cloud services, payment processors, and marketing platforms used by Shawn Inc may store or process personal information outside South Africa.

Cross-border processing may occur where we use internationally operated services.

We will undertake international transfers only where permitted by section 72 of POPIA.

Depending on the circumstances, this may involve:

• Appropriate contractual protections
• Applicable foreign laws providing adequate safeguards
• Binding corporate rules
• The data subject's lawful consent
• Transfers necessary for a relevant contractual arrangement
• Another transfer ground permitted by POPIA

Where required, we will provide additional information about relevant international transfers and the protections applicable to them.

We do not guarantee that every third-party service stores all data exclusively within South Africa.

Personal Information Processed on Behalf of Clients

As a digital marketing and website development agency, Shawn Inc may process personal information supplied by clients during the delivery of contracted services.

Examples include customer databases, lead information, form submissions, marketing audiences, contact records, and transaction-related information.

In certain arrangements, the client determines the purposes and means of processing and Shawn Inc acts as an operator processing personal information on the client's behalf.

In those circumstances:

• We will process relevant information in accordance with applicable contractual instructions and legal requirements.
• We will apply appropriate confidentiality and security safeguards.
• We will not independently repurpose client-controlled personal information for unrelated marketing.
• We will restrict access to authorised personnel and service providers.
• We will assist with reasonable privacy-related requests in accordance with our contractual and legal obligations.
• We will handle information on termination according to the agreed instructions and applicable retention requirements.

Clients remain responsible for their own lawful collection and use of personal information where they act as the responsible party.

Nothing in this section removes any responsibilities imposed on Shawn Inc by POPIA.

Data Storage and Retention

We retain personal information only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Retention considerations may include:

• The duration of a client relationship
• Contractual and service obligations
• Legal and accounting recordkeeping requirements
• The need to resolve disputes
• Fraud prevention and security
• Legitimate administrative requirements
• Valid consent to continued retention

Different categories of information may be subject to different retention periods.

For example, certain accounting and transactional records may need to be retained for prescribed periods even after a customer relationship ends.

Marketing information will be retained only while a lawful basis for its processing remains.

Where information is no longer required and no lawful reason for continued retention exists, we will take reasonable steps to delete, destroy, or de-identify it securely.

Backup systems and legally preserved records may require additional time before information is fully removed, where permitted by law.

Information Security

Shawn Inc is committed to implementing reasonable technical and organisational safeguards appropriate to the personal information we process.

Depending on the relevant system and risk, safeguards may include:

• Access controls and authentication
• Secure data transmission
• Restricted administrative permissions
• Software and security updates
• Appropriate backup procedures
• Staff and contractor confidentiality obligations
• Secure handling of account credentials
• Monitoring for unauthorised access
• Appropriate controls for external service providers

No website, online service, or electronic storage system can guarantee absolute security.

We will take reasonable steps to assess and reduce foreseeable risks and respond appropriately to identified security vulnerabilities.

If we have reasonable grounds to believe personal information has been accessed or acquired by an unauthorised person, we will comply with the applicable notification requirements of section 22 of POPIA.

This includes notifying the Information Regulator and affected data subjects as soon as reasonably possible, as required by law.

Your Rights Under POPIA

Subject to applicable legal conditions and limitations, you have rights concerning your personal information.

These include the right to:

17.1 Request Confirmation

Ask whether Shawn Inc holds personal information about you.

17.2 Access Personal Information

Request access to personal information we hold about you, subject to applicable identification, procedural, and lawful access requirements.

17.3 Request Correction

Ask us to correct information that is inaccurate, incomplete, misleading, or outdated.

17.4 Request Deletion

Request the deletion or destruction of personal information that we are no longer legally authorised or required to retain.

17.5 Object to Processing

Object to certain processing activities where the law provides this right.

17.6 Withdraw Consent

Withdraw consent previously given for processing based on that consent.

17.7 Object to Direct Marketing

Request that we stop processing your personal information for direct marketing purposes.

17.8 Challenge Certain Automated Decisions

Exercise protections relating to qualifying decisions based solely on automated processing, as provided by POPIA.

17.9 Lodge a Complaint

Submit a complaint to the Information Regulator if you believe your personal information has been processed unlawfully.

We will not deny any right granted under applicable data protection legislation through the wording of this Policy.

Exercising Your Privacy Rights

To exercise a privacy-related right, please contact us using the following details.

Email: support@shawnpale.com

Subject: Personal Information Request – Privacy

Please include sufficient information for us to identify the relevant records and understand your request.

For security reasons, we may require reasonable verification of your identity before disclosing, correcting, or deleting personal information.

We will not request unnecessary sensitive information solely to verify an ordinary privacy request.

Requests will be handled within the periods and procedures required by applicable law.

Certain access requests may be subject to prescribed fees where lawfully permitted. Any applicable fee will be communicated as required before the requested service is provided.

Some information may need to be retained to comply with legal obligations, resolve disputes, or establish or defend legal rights.

Where a request cannot be fulfilled in whole or in part, we will explain the reason to the extent appropriate and legally permitted.

Children's Personal Information

Our website, products, and professional services are primarily directed toward businesses and adults.

We do not intentionally solicit personal information from children without an appropriate lawful basis.

Where the processing of a child's personal information is necessary, we will comply with the additional requirements of POPIA, including obtaining consent from a competent person where required or relying on another applicable lawful authorisation.

If you believe that a child has provided personal information to us in circumstances that require corrective action, please contact:

support@shawnpale.com

We will investigate and take appropriate steps.

Special Personal Information

Shawn Inc does not ordinarily require customers to provide special personal information, such as information concerning health, religious beliefs, political persuasion, biometric information, or other specially protected categories.

We ask users not to submit unnecessary sensitive information through general website forms.

Where special personal information must be processed for a legitimate purpose, we will do so only where legally authorised and with appropriate safeguards.

Automated Processing and Artificial Intelligence

Shawn Inc may use automation and AI-assisted systems for legitimate business functions, including:

• Organising enquiries
• Supporting customer communication
• Assisting with content production
• Improving internal processes
• Routing service requests
• Performing technical or administrative tasks

We will take reasonable steps to limit personal information used by these systems to what is necessary for an authorised purpose.

Where external AI or automation providers are used to process personal information, applicable data protection and confidentiality considerations will be assessed.

We will not subject individuals to decisions based solely on automated profiling that produce legal consequences or substantially affect them except where authorised by law and subject to applicable safeguards.

Third-Party Websites and External Links

Our website may contain links to external websites, payment platforms, booking services, social media platforms, or other third-party resources.

These websites may operate independently and have their own privacy policies.

Shawn Inc is not responsible for the independent privacy practices of external operators, except to the extent that responsibility arises from our own conduct or applicable law.

We encourage users to review the privacy policies of third-party services before submitting personal information.

Confidentiality of Client Information

During the delivery of our services, Shawn Inc may receive confidential business information, including marketing strategies, customer data, account access information, internal documents, and commercial records.

We will take reasonable steps to protect such information and restrict its use to legitimate service delivery or other lawful purposes.

We will not knowingly publish confidential client information without appropriate authorisation, unless disclosure is required or otherwise permitted by law.

Additional confidentiality terms may apply under individual service agreements.

Changes to This Privacy Policy

We may amend this Privacy Policy when necessary to reflect changes in:

• Our business operations
• Services and products
• Technology providers
• Data processing practices
• Legal or regulatory requirements
• Security and privacy procedures

The latest version will be made available on our website and identified by its last-updated date.

Where a material change requires further notification or fresh consent, we will take the necessary steps before undertaking the affected processing.

Changes will not retrospectively legitimise processing that was unlawful when it occurred.

Complaints and the Information Regulator

If you believe that Shawn Inc has handled your personal information improperly, we encourage you to contact us first so that we can investigate the concern.

You may contact:

Shawn Inc – Privacy Enquiries

Email: support@shawnpale.com

You also have the right to lodge a complaint with the Information Regulator of South Africa.

Information Regulator (South Africa)

Website: https://inforegulator.org.za

General Enquiries: enquiries@inforegulator.org.za

POPIA Complaints: POPIAComplaints@inforegulator.org.za

Telephone: +27 10 023 5200

Toll-Free: 0800 017 160

Physical Address:

Woodmead North Office Park
54 Maxwell Drive
Woodmead, Johannesburg
2191
South Africa

Governing Law

This Privacy Policy is governed by the laws of the Republic of South Africa.

Our processing of personal information is subject to applicable South African privacy and data protection legislation, including the Protection of Personal Information Act 4 of 2013.

Nothing in this Policy excludes rights or remedies that cannot lawfully be excluded.

Business Information and Contact Details

Trading Name: Shawn Inc

Registered Legal Entity: Adversa Holdings (PTY) LTD

Company Registration Number: 2024/477200/07

Registered Country: South Africa

Business Address:

16 Panfluit Drive
Eco Park East Estate
Centurion, Gauteng
0157
South Africa

Telephone: +27 68 033 5031

General Enquiries: shawn@shawnpale.com

Privacy and Support Enquiries: support@shawnpale.com

Website: https://shawnpale.com

All privacy-related requests and concerns should be directed to support@shawnpale.com.