Privacy Policy

1. Who We Are

Pure Salts is an online software platform operated by TIPTREE FARMING ENTERPRISES (PTY) LTD, registration number 2013/076070/07, a company incorporated in South Africa ("Tiptree", "Pure Salts", "we", "us" or "our").

Our registered/business address is:

22 3rd Avenue Walmer Port Elizabeth South Africa

Email: info@puresalts.co.za

For purposes of the Protection of Personal Information Act 4 of 2013 ("POPIA"), Tiptree is the responsible party in respect of personal information processed through Pure Salts where Tiptree determines the purpose and means of that processing.

This Privacy Policy explains how we collect, use, disclose, store and protect personal information when you visit or use the Pure Salts website, application and related services ("Services").

2. Information We Collect

The information we collect depends on how you use Pure Salts.

2.1 Account information

When you create or use an account, we may process information such as:

• your email address;
• authentication and account identifiers;
• profile information you choose to provide;
• account status;
• subscription status; and
• information necessary to administer your account and access to the Services.

Authentication may also be provided through supported third-party sign-in services.

2.2 Cultivation and application data

When you use Pure Salts, you may enter, create or save information relating to your cultivation activities, including:

• nutrient formulations and recipes;
• fertiliser and raw salt information;
• water-source information and water chemistry;
• elemental concentrations and nutrient targets;
• crop and batch information;
• irrigation and runoff readings;
• environmental and cultivation parameters;
• plant observations;
• deficiency or toxicity information;
• diagnostic information; and
• other information you choose to enter into the Services.

This information is primarily processed to provide the functionality you request.

You should avoid entering personal, confidential or commercially sensitive information that is not necessary for your use of the Services.

3. AI-Enabled Features

Pure Salts includes certain artificial-intelligence-assisted features.

These currently include:

• Water Report PDF/Image Parser;
• AI Water Analysis; and
• Deficiency & Toxicity Advisor.

When you use these features, information you submit may be transmitted to third-party artificial intelligence infrastructure used by Pure Salts to generate the requested analysis.

Depending on the feature, this may include water chemistry, cultivation parameters, environmental information, plant symptoms, images, feed and runoff information, growth stage, substrate information and uploaded water reports.

For water-report uploads, the document or image may be transmitted in full for processing. Pure Salts does not intentionally retain the original uploaded water-report file after processing; extracted information may be retained if you choose to save it within your account.

You should remove unnecessary personal, confidential or commercially sensitive information from documents or images before submitting them to an AI-enabled feature.

AI outputs may contain errors or inaccuracies and should be treated as decision-support information rather than independently verified professional advice.

4. Feedback, Contact and Consultation Information

If you contact us, submit feedback or request a consultation, we may collect information such as:

• your name or contact details where provided;
• your email address;
• the contents of your message;
• feedback or issue reports;
• screenshots you choose to submit;
• technical or browser information associated with a feedback submission; and
• records of our interaction with you.

We use this information to respond to enquiries, provide support, investigate problems, improve Pure Salts and administer consultation requests.

5. Subscription and Payment Information

Pure Salts subscriptions are sold through Freemius, which acts as Merchant of Record for paid subscriptions. Pure Salts Pro costs USD $199 per month. New customers may start a 7-day free trial with a valid payment method. Unless cancelled before the scheduled first payment date, the trial converts automatically to paid billing at USD $199 per month. Customers may instead subscribe and pay immediately without a trial. Freemius processes payments, issues receipts and handles applicable taxes.

When you subscribe, you will enter your name, email address, billing address, any tax number and your payment details directly on Freemius's secure checkout. Freemius and the payment providers it uses process this information to complete and administer the transaction, prevent fraud and meet tax obligations.

To open checkout, Pure Salts gives Freemius your account email address, the selected plan and any referral discount you are eligible for. Pure Salts does not use information collected at checkout to send you Pure Salts marketing.

Paddle was previously used with Pure Salts for testing only. No live customer subscriptions were processed through Paddle, and Paddle is no longer used. Historical Paddle test records remain retained as described in section 11.

Pure Salts does not store your full payment-card details.

We may receive and retain limited subscription information necessary to operate your account, such as:

• subscription status;
• trial status;
• subscription start or end dates;
• renewal or cancellation status;
• internal account linkage;
• Freemius customer, licence, subscription and payment identifiers, and, for historical test transactions, Paddle identifiers; and
• limited transaction or payment-event information required for account administration, security, reconciliation and compliance.

Freemius processes buyer and transaction information under its own privacy policy, available at freemius.com/privacy.

6. Analytics and Cookies

Pure Salts uses Google Analytics 4 ("GA4") to help us understand how users interact with the Services.

Analytics is disabled unless you expressly choose Accept analytics through our cookie consent controls.

If you choose Essential only, analytics remains disabled.

Where analytics consent has been provided, we may collect limited information such as:

• pages or application screens viewed;
• selected application events;
• whether a visitor is signed in;
• limited subscription-plan information associated with billing events; and
• a one-way scrambled account reference where applicable.

We do not intentionally send names, email addresses, payment-card information, cultivation data, nutrient formulations or other detailed account content to Google Analytics.

Advertising and remarketing features are not intentionally used as part of our current GA4 configuration.

You may change your analytics preference through the Cookie settings control available on the website.

Please see our Cookie Policy for additional information.

7. How We Use Information

We may process information for purposes including:

• creating and administering accounts;
• authenticating users;
• providing Pure Salts functionality;
• saving user-created recipes, water information, crop records and other application data;
• performing calculations and analyses requested by users;
• providing AI-assisted functionality;
• managing subscriptions, trials and access rights;
• processing and reconciling subscription events;
• providing customer support;
• responding to feedback and consultation requests;
• maintaining application security;
• preventing misuse, fraud and unauthorised access;
• troubleshooting and improving the Services;
• understanding application usage where analytics consent has been provided;
• maintaining administrative and compliance records;
• exercising or defending legal rights; and
• complying with applicable legal and regulatory obligations.

We seek to collect and process only information reasonably necessary for these purposes.

8. Legal Grounds for Processing

Where POPIA applies, we process personal information where permitted by law, including where processing is:

• necessary to provide a service or perform an agreement with you;
• necessary to take steps requested by you before entering into an agreement;
• required or authorised by law;
• necessary to pursue our legitimate interests or those of a third party, where your rights do not override those interests;
• necessary to protect a legitimate interest of the data subject; or
• based on your consent where consent is the appropriate basis.

Where processing is based on consent, you may withdraw that consent subject to applicable law and any processing that is otherwise legally permitted.

9. Service Providers and Third Parties

We use third-party service providers and infrastructure to operate Pure Salts.

Depending on how you use the Services, these may include providers supporting:

Hosting, database and authentication

Pure Salts uses infrastructure associated with Lovable and Supabase for application hosting, database functionality, authentication and related services.

Artificial intelligence

AI-enabled features use the Lovable AI Gateway and underlying third-party AI services, which currently include Google Gemini models.

Payments and subscriptions

Freemius provides checkout, payment processing, invoicing, tax handling and Merchant of Record services, using payment service providers it selects. Paddle was previously used for testing only; no live customer subscriptions were processed through Paddle, and historical Paddle test records remain retained as described in section 11.

Transactional email

Resend is used for certain transactional and application emails.

Analytics

Google Analytics is used only where analytics consent has been provided.

Authentication

Google may process information where you choose to use Google Sign-In or another supported Google authentication service.

Website delivery and security

Cloudflare or related infrastructure may be involved in delivering and protecting the published website.

These organisations may process information in accordance with their respective roles, contractual arrangements and privacy practices.

We may also disclose information where required by law, legal process or a competent authority, or where reasonably necessary to protect our legal rights, users or systems.

We do not sell users' personal information as part of Pure Salts' business model.

10. International Processing and Transfers

Once live subscriptions are available, payment information will be processed by Freemius and the payment providers it uses, which may process information outside South Africa.

Pure Salts is operated by a South African company but uses technology providers and infrastructure that may process or store information outside South Africa.

For example, application infrastructure may be located in the European Union, and other service providers may operate internationally.

Where personal information is transferred across borders, we seek to do so in accordance with applicable data-protection requirements, including POPIA where applicable, and to use appropriate service providers and contractual or other safeguards where required.

By using functionality that necessarily involves international service providers, your information may be processed in countries with data-protection laws different from those of South Africa.

11. How Long We Keep Information

We do not intend to retain personal information indefinitely.

Our current retention approach includes:

• Account and profile information: generally retained while your account exists.
• Recipes, water information, crop data, readings, diagnoses and application usage records: generally retained while your account exists and deleted when the account is deleted, subject to legitimate legal or security exceptions.
• Original AI water-report uploads: not intentionally retained by Pure Salts after processing.
• Feedback submissions: up to 24 months.
• Feedback screenshots: up to 12 months.
• Consultation records: generally up to 24 months after the last recorded interaction.
• Privacy request records: up to 5 years.
• Generated personal-data export files: intended to be kept no longer than 30 days, and may be deleted earlier.
• Administrative and security audit records: generally up to 5 years.
• Subscription metadata: while your account exists and, where reasonably justified or legally required, for up to 5 years thereafter.
• Payment-event records: where reasonably justified or legally required, for up to 5 years.
• Google Analytics data: retained by Google according to the data-retention setting of our Google Analytics account, and collected only where you have given analytics consent.
• Guest/local application data: may remain on your device until you clear it or your browser/application storage removes it.

The periods above are the maximum periods we intend to keep each category. Records past these periods are currently removed through periodic review and deletion by our team rather than fully automatic deletion, so some records may remain for a short time after the stated period before they are deleted.

Third-party service providers may maintain their own records for periods determined by their legal obligations and privacy practices. We do not promise specific third-party retention periods unless they are within our control.

We may retain information for longer where reasonably necessary to comply with law, resolve disputes, prevent fraud, enforce agreements or establish, exercise or defend legal claims.

12. Account Deletion

Registered users can request deletion of their Pure Salts account through the account settings.

Account deletion removes or de-identifies applicable account information and user-created application data in accordance with our deletion process and legal obligations.

Certain information may be retained or anonymised where reasonably necessary for:

• financial or tax compliance;
• security and fraud prevention;
• legal obligations;
• dispute resolution;
• audit and compliance evidence; or
• establishing, exercising or defending legal rights.

Where an account has an active or trial subscription, cancellation of that subscription may be required as part of the deletion process.

Deleting your Pure Salts account does not necessarily require independent controllers such as payment providers to delete information they are legally required or independently entitled to retain.

13. Access to Your Information

Pure Salts provides registered users with a mechanism to request a copy of personal information associated with their account.

You can make this request through Account → Settings → Privacy & your data.

For security reasons, we may need to verify your identity before fulfilling certain privacy requests.

Generated export files are made available through temporary secure download links and are retained for a limited period.

14. Your Privacy Rights

Subject to applicable law, you may have rights relating to your personal information, including the right to:

• request confirmation that we hold personal information about you;
• request access to personal information we hold;
• request correction or updating of inaccurate information;
• request deletion or destruction of information where legally applicable;
• object to certain processing;
• withdraw consent where processing is based on consent;
• request information about how your information is processed;
• lodge a complaint concerning the processing of your personal information; and
• exercise other rights available under POPIA or other applicable data-protection legislation.

Requests can be sent to info@puresalts.co.za.

We may request reasonable information to verify your identity before actioning a request.

15. Information Officer

Tiptree has an Information Officer responsible for overseeing applicable privacy and information-protection obligations.

Privacy enquiries and requests concerning Pure Salts can be directed to:

Information Officer TIPTREE FARMING ENTERPRISES (PTY) LTD Email: info@puresalts.co.za 22 3rd Avenue, Walmer, Port Elizabeth, South Africa

16. Security

We use reasonable technical and organisational measures designed to protect personal information against loss, misuse, unauthorised access, alteration and disclosure.

Measures used within Pure Salts include authentication controls, account-based access restrictions, database access controls, role-based administrative permissions and server-side controls for sensitive operations.

No internet-based service or electronic storage system can be guaranteed to be completely secure. Users are responsible for protecting their login credentials and should notify us if they suspect unauthorised access to their account.

17. Security Incidents

If we become aware of a security compromise involving personal information, we will investigate and take reasonable steps appropriate to the circumstances.

Where required by applicable law, we will notify affected data subjects and/or the Information Regulator.

18. Children's Privacy

Pure Salts is a professional cultivation and agronomic software platform and is not intended for use by children.

We do not knowingly design the Services to collect personal information from children.

If you believe that a child has provided personal information to us inappropriately, please contact info@puresalts.co.za.

19. Business and Cultivation Information

Some information entered into Pure Salts may constitute commercially sensitive business or cultivation information rather than personal information.

We treat user account data and user-created application content as confidential within the normal operation of the Services, subject to the disclosures and processing necessary to provide the Services and as otherwise described in this Privacy Policy.

Users remain responsible for deciding what confidential or proprietary information they submit to third-party-assisted functionality, particularly AI-enabled features.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the Services, technology, service providers, legal requirements or our information-processing practices.

The latest version will be published through Pure Salts with an updated Last updated date.

Where a change is material and applicable law requires additional notice or consent, we will take reasonable steps to provide it.

21. Complaints

If you have a concern about how Pure Salts processes your personal information, please contact us first at:

info@puresalts.co.za

You may also have the right to lodge a complaint with the Information Regulator (South Africa) in accordance with POPIA.

22. Contact Us

For questions about this Privacy Policy or our handling of personal information, contact:

TIPTREE FARMING ENTERPRISES (PTY) LTD Trading as / operating Pure Salts Registration No. 2013/076070/07 22 3rd Avenue Walmer Port Elizabeth South Africa

Email: info@puresalts.co.za