Virtual Window Privacy Policy (POPIA Compliant)
Last updated: 29 January 2026

Virtual Window (“we”, “us”), in service of The Open Window Pty Ltd, is the Responsible Party under POPIA.

We process Personal Information (e.g., name, email, IP address, device ID, Usage Data) lawfully, minimally, and securely for the Virtual Window app (“Service”). Processing basis: consent, contract performance, legitimate interests (e.g., service improvement). No processing without basis.

Data Collected & Purposes
– Personal Data: Provided (email, account) or auto-collected (IP, browser, device ID, visit duration) via app.
– Purposes: Provide/maintain Service; manage accounts; communicate updates (opt-out anytime); analyze usage; comply with law. No marketing without explicit opt-in consent.

Sharing & Transfers
Shared only with: Service Providers (e.g., hosting analytics—bound by agreements); affiliates (POPIA-compliant); authorities (legal duty). No sales. Cross-border: only with adequate safeguards (e.g., Standard Contractual Clauses). No transfers to high-risk countries without consent.

Retention & Security
Retained: Account data until deletion request + 3 years (legal/disputes); Usage Data: 12 months (analysis/security). Secure via encryption, access controls, regular audits—no absolute guarantee. Breaches notified to Regulator/users within reasonable time.

Your POPIA Rights
– Access/correct/delete (“right to be forgotten”)/object/restrict processing/port data—within 30 days, free (save abuse).
– Withdraw consent anytime (impacts Service).
– Lodge complaints: Information Regulator (inforeg@justice.gov.za).
Children under 18: No knowing collection without parental consent.

Cookies & Third Parties
App may use essential cookies/analytics (opt-out via settings). Third-party links: review their policies—we’re not responsible.

Changes posted here + email notice. Continued use = acceptance. Review periodically.

Contact: games@virtualwindow.co.za