pleks
Why PleksThe workCharterWho built thisPricingFounding agentsContact
PLEKS · LEGAL REGISTRY · BOOK 04FOL. 0117 · POPIA · CPA · NCAFORM · POPIA-S22CONSENTCLAUSE LEDGER · S04§ 04.01 acceptance§ 04.02 service description§ 04.03 subscription & payment§ 04.04 cancellation · 90 days§ 04.05 prohibited uses§ 04.06 limitation of liability§ 04.07 governing law · ZA · WCREPUBLIC OF SOUTH AFRICAPOPIAACT 4 OF 2013¶ 01¶ 02¶ 03¶ 04
POPIA · S17 · S18processing registerv2.6.0

Processing register

Pleks's POPIA processing-purpose register — all 12 platform purposes and 26 operator purposes, with lawful bases, data categories, retention periods, and the full operators directory.

Last reviewed2026 · 10 · 03
In force from2026 · 05 · 01
Versionv2.6.0
StandardPOPIA s17 · s18
On this page
  • —Summary
  • 00About this register
  • 01Controllers
  • 02Information officer
  • 03Security safeguards
  • 04Data-subject rights
  • A·Platform purposes
  • B·Operator purposes
  • C·Operators directory
Legal docs
  • §Definitionsv1.2.3
  • §Cookie policyv1.4.1
  • §Credit check policyv1.6.0
  • §PAIA manualv1.3.0
  • §POPIA registerv2.6.0
  • §Privacy policyv4.9.0
  • §Terms of servicev3.7.0
Pleks (Pty) Ltd · ZA

Plain-language summary

What this register covers

  • Pleks operates in two roles: as Responsible Party for 12 platform purposes (authentication, billing, support — Part A) and as Operator for 26 agency-side purposes (tenant data, leases, inspections, credit screening, property-intelligence — Part B).
  • For Part B data, the agency is the Responsible Party. Data-subject requests about tenant or lease records must be directed to the agency, not to Pleks.
  • Credit checks (B4) require the applicant’s explicit consent under POPIA · S11(1)(a) and the Credit Bureau Code of Conduct (issued under POPIA, October 2020) before any bureau query is submitted.
  • AI processing (B22) is assistive only. Pleks does not make automated decisions about tenants or applicants — all decisions remain with the agency or landlord.
  • All cross-border transfers to US/international vendors are governed by Standard Contractual Clauses under POPIA · S72(1)(a).

00 · Background

About this register

This document is Pleks’s processing-purpose register under POPIA · S17 (accountability principle — Responsible Party must have measures in place to ensure compliance) and POPIA · S18 (notification to data subjects of processing purposes). It is published publicly because public accountability is stronger than private accountability, and because agencies evaluating Pleks for procurement have a legitimate need to review exactly what the platform does with personal information before they commit.

If you are an agency or property practitioner using Pleks: under POPIA you are the Responsible Party for every natural person whose personal information you collect — tenants, applicants, landlords, contractors, references, household members. Pleks is your Operator, processing data on your behalf under the Pleks Operator Agreement. This document describes what Pleks does as your Operator; your own register must describe what your agency does, with Pleks listed as one of your Operators.

If you are a data subject (tenant, applicant, landlord, supplier): this document tells you what the platform does and who the actors are. For Part B data, your rights under POPIA are exercised against the agency — the Responsible Party for that data. For Part A data (your Pleks account), your rights are exercised against Pleks directly. Under PAIA, requests for access to records held by Pleks on behalf of a client agency must be directed to that agency’s Information Officer, not to Pleks. Pleks will acknowledge any misdirected request within 2 business days and route it to the correct Responsible Party within 5 business days — so the agency’s statutory 30-calendar-day response clock under s23(1) (per PAIA s25, extendable under s26) is not materially eroded.

Purposes prefixed A are Pleks as Responsible Party. Purposes prefixed B are Pleks as Operator for agencies. This distinction is preserved throughout the register and is load-bearing for all data-subject rights and accountability obligations.

01 · Roles

Controllers

Pleks’s processing activities fall into two distinct controller relationships:

Pleks as Responsible Party (Part A) — for data arising from the platform itself: authentication, security telemetry, error monitoring, product feedback, uptime probes, cost observability, billing, marketing, and support communications. Pleks is the sole decision-maker about this processing and is accountable under POPIA for it.

Pleks as Operator (Part B) — for data arising from agency use of the platform: tenant profiles, leases, inspections, maintenance, communications, trust transactions, deposits, applications, credit checks, owner statements, and every other artefact of property management. The agency is the Responsible Party; Pleks processes this data on the agency’s behalf under section 09 of the Pleks Terms of Service (“ToS §09”), which constitutes the mandatory written-contract terms required by POPIA · S20 and POPIA · S21. Under POPIA · S21 (Operator-to-RP notification), Pleks will notify the agency immediately once Pleks has reasonable grounds to believe that personal information for which the agency is the Responsible Party has been accessed or acquired by an unauthorised person. The agency must then assess whether its own POPIA · S22 obligations to notify the Information Regulator and affected data subjects are triggered; s22 requires those notifications as soon as reasonably possible. The breach-notification obligation is given contractual force in ToS §09.4.

Agency audit rights over Pleks as Operator. Under POPIA · S21, agencies as Responsible Parties have the right to verify Pleks’s compliance with ToS §09. Pleks supports this right through: (a) this publicly available processing-purpose register; (b) provision of a completed security questionnaire or equivalent on written request (at no cost, once per 12 months); and (c) cooperation with reasonable compliance audits on 30 days’ written notice, subject to confidentiality obligations protecting other agencies’ data. The full audit-rights framework is set out in ToS §09.5.

Sovereign-trust invariant. Pleks holds no client funds. Client funds reside in the agency’s own Section 54 trust account at the agency’s own bank. Pleks does not initiate payments and is not the trustee. This is the financial expression of the same principle: Pleks is an Operator, not a custodian.

Mixed-role processing. Purpose B9 (application fee processing) and all Part A observability purposes operate at the Pleks-RP layer even where initiated within an agency workflow. These are structurally separated from Part B processing and are listed under their correct controller in this register.

02 · Officers

Information officer

The Information Officer for Pleks-RP purposes (Part A) is named below. For Part B purposes, the Information Officer is the agency’s own — not Pleks’s. Agencies set their Information Officer details at /settings/privacy/information-officer.

Information
officer
(Part A)
Stéan Bouwer · Pleks (Pty) Ltd
legal@pleks.co.za
Deputy IO /
succession
Role vacant — to be appointed under POPIA · S56 as the organisation grows. In the interim, any IO incapacity is covered by the board director of Pleks (Pty) Ltd.
Pleks is registered with the Information Regulator under POPIA s55. Registration number on file with the IO.
Information
Regulator
Information Regulator of South Africa
JD House, 27 Stiemens Street, Braamfontein, 2001 · inforegulator.org.za · 010 023 5207

Every data subject has the unconditional right to complain to the Information Regulator independently of Pleks or the agency’s response. The Regulator’s contact details are surfaced on every data-subject-rights interface in the platform. Formal information-access requests to Pleks under PAIA must be submitted on Form 2 (Request for Access to Record of Public/Private Body), available from the Information Regulator. Pleks will respond using Form 3 (Outcome of Request and Notice of Fees) within the statutory 30-day window. In compliance with PAIA · S51(3) and the 2021 Regulations, the Pleks PAIA manual is published on this website at /paia-manual.

03 · Safeguards

Security safeguards

Pleks implements appropriate technical and organisational measures consistent with POPIA · S19:

  • Encryption in transit: TLS 1.3 for all connections; HSTS enforced; no plaintext fallback.
  • Encryption at rest: AES-256 at the database layer via the database and storage provider (see §C); sensitive fields (bank account numbers, TOTP secrets, passkey credentials) additionally encrypted at the column level.
  • Row-Level Security: Postgres RLS enforced on every table carrying personal information; service-role access restricted to server-side only with org-scoped gateway helper; no broad-access admin views.
  • Authentication: magic-link auth for tenant/landlord/supplier roles; password + mandatory MFA for agent roles; MFA step-up required for fiduciary-class actions.
  • Immutable audit logging: every state-changing operation recorded in audit_log with actor, target, event type, timestamp, and change payload; no UPDATE or DELETE policies on the log.
  • PII scrubbing for observability: error monitoring and log aggregation tools receive PII-scrubbed events only; scrubber runs pre-transmission and strips request bodies from sensitive routes and PII patterns from all payloads.
  • Signed URLs with TTL: all sensitive downloads use time-limited signed URLs; no public bucket access to customer data.
  • Operator contractual controls: every third-party Operator operates under a Data Processing Addendum with SCCs where cross-border, and documented retention and breach-notification terms.

Data quality (POPIA · S16 / S11(2)). Pleks is obliged to keep personal information complete, accurate, not misleading, and updated. For Part A data, Pleks owns this obligation directly. For Part B data, the agency is the Responsible Party and holds the quality obligation; Pleks provides the mechanism (the s23 in-platform correction interface in Purpose B23) to discharge it. Accuracy is especially consequential in credit checking (B4), FitScore generation (B5), and arrears management (B11) — an inaccurate data point in any of these purposes can have legal and financial consequences for the data subject. Pleks surfaces data-quality alerts when it detects internally inconsistent records (e.g., arrears balance vs trust reconciliation mismatch). Agencies must act on correction requests within the 30-calendar-day window under s23(1) (per PAIA s25). Pleks will propagate confirmed corrections to all downstream records that derived from the corrected source data.

Where multiple retention periods apply to the same record, Pleks enforces the longest applicable statutory, contractual, or evidentiary period. Purpose-level retention periods in this register are minimum commitments and may be overridden by mandatory statutory retention (Tax Administration Act s29 — 5 years; PPRA trust records; FIC Act s23 — 5 years; Companies Act s24 — accounting records, 7 years), active legal holds, subject-request restrictions, ongoing disputes, or subpoenas.

Special personal information (POPIA · S26–S27). Pleks does not solicit special personal information as defined in POPIA s26 (religious/political beliefs, race/ethnicity, trade-union membership, health/sex life, criminal behaviour, biometric information). However, special PI may appear incidentally in free-text fields or photos: a maintenance request may reference a tenant’s medical condition; an inspection photo may incidentally capture religious symbols or other s26 attributes. Where this occurs, the agency as Responsible Party must hold a valid s27 ground for processing (typically s27(1)(a) explicit consent or s27(1)(d) law-compliance necessity). Pleks’s UI includes contextual nudges discouraging agents from entering special PI in free-text fields that are not structured for it. Agencies should configure their own data-minimisation policies for their teams. Pleks will flag any pattern of systematic special-PI collection identified through its Operator oversight function.

DPIA programme. Pleks conducts a Data Protection Impact Assessment before deploying or materially changing any processing purpose that involves: (a) credit data or financial scores about natural persons (currently B4, B5); (b) special personal information (s26); (c) AI-derived assessments of natural persons (B22); (d) persistent or precise location data, including EXIF GPS metadata in inspection photography (B14); or (e) systematic processing of children’s personal information (B3). A completed DPIA is a deployment prerequisite — no such purpose ships without one. DPIA records are retained for the life of the purpose.

Sub-processor authorisation and change notification. Pleks uses general written authorisation from agencies for the sub-processors listed in Section C of this register (consistent with POPIA s21(2) and industry practice). When Pleks changes a sub-processor in a way that materially affects agencies’ data, Pleks will notify agencies by email to their registered Information Officer address at least 30 days before the change takes effect, giving agencies a reasonable right to object. Changes that do not materially affect data processing (e.g., infrastructure migration within the same legal entity or jurisdiction) are recorded in the register’s version history without the 30-day window. The current sub-processor list is maintained in Section C of this register and is updated on every version increment.

04 · Rights

Data-subject rights

POPIA confers the following rights on every data subject whose personal information Pleks processes (as Responsible Party — Part A) or processes on behalf of an agency (as Operator — Part B). For Part B rights, exercise them against the agency (the Responsible Party); Pleks will support the agency’s response. The channel for each right is shown below.

  • Right of access (s23). Request a copy of the personal information Pleks holds about you, the categories of recipients, the source, and the purpose. Channel: submit Form 2 to our Information Officer at legal@pleks.co.za or via the in-platform subject-rights dashboard. Response within 30 calendar days, extendable per PAIA s26.
  • Right to correction (s24). Request correction or deletion of inaccurate, misleading, outdated, incomplete, or unlawfully obtained personal information, and notification to third parties to whom it was disclosed. Channel: in-platform settings (immediate self-serve for profile data) or Information Officer for other records.
  • Right to deletion / restriction (s25). Request destruction or deletion of personal information Pleks is no longer authorised to retain. Note: statutory retention obligations (s29 Tax Administration Act, PPRA, audit logs) may prevent deletion during the applicable retention window; Pleks will explain the basis for any retention that continues after a deletion request. If you are not satisfied with Pleks’s response, you may apply to the Information Regulator under POPIA · S74 or to a court under POPIA · S99. Channel: Information Officer.
  • Right to object (s11(3)). Where Pleks’s lawful basis is legitimate interest (POPIA · S11(1)(f)) — purposes A3, A5, A6, A10, A12, B11, B16 — you have the right to object to processing on reasonable grounds relating to your particular situation. Pleks will cease processing unless it can demonstrate compelling legitimate grounds that override your interests, or processing is necessary for the exercise or defence of legal claims. Channel: Information Officer or the in-platform subject-rights dashboard.
  • Automated-decision rights (s71). Pleks does not make automated decisions about data subjects that produce legal or similarly significant effects. FitScore (B5) is assistive only — final tenancy decisions remain with the agency. If this changes, affected data subjects will have the right to request human review, to express their point of view, and to receive an explanation of the decision. Channel: Information Officer.
  • Direct-marketing opt-out (s69 / s11(3)). Where Pleks sends any direct marketing (A7 waitlist communications, any future B25 agency marketing), you may opt out at any time via the unsubscribe link in every message or by contacting the Information Officer. Opt-outs are honoured within 5 business days. Channel: unsubscribe link or Information Officer.
  • Right to complain (POPIA s74). You may lodge a complaint with the Information Regulator at any time, independently of Pleks’s or the agency’s response. See §02 for the Regulator’s contact details.

A · Pleks as Responsible Party

Platform purposes

These 12 purposes are those for which Pleks itself is the Responsible Party. The lawful basis for each is normally either performance of the contract between Pleks and the platform user (the Terms of Service, POPIA · S11(1)(b)), or Pleks’s legitimate interest in operating a reliable and secure service (POPIA · S11(1)(f)), with appropriate balancing against the data subject’s interests.

§07 Charter · Agency isolation

Enforced at 4 layers

Layer 1 · Database

Row Level Security on every table

Postgres RLS policies are defined on every agency-scoped table and enforced by the database engine, not the application layer. Every policy carries both USING and WITH CHECK clauses — reads and writes are equally gated. The anon key, used on all client-facing paths, cannot bypass RLS. A direct SQL query using the anon key fails the policy check if org_id does not match the session organisation.

Layer 2 · Application

Gateway org_id binding

Every server-side read and write path passes through gateway() or requireAgentWriteAccess(), which bind the session orgId to the Supabase client before any query executes. Project rules mandate that every query include the org_id scope. Omitting it is a policy violation caught in code review. No server route queries across org boundaries.

Layer 3 · Computation

FitScore scoped at compute time

FitScore results (Purpose B5) are computed within the requesting org context and inserted with org_id bound at the point of write. The FitScore engine has no API surface that accepts a cross-org context. The archived PDF report-of-record is stored under the originating org storage path. A result produced for Agency A cannot be read by Agency B — RLS blocks the read at the database layer.

Layer 4 · Integration

No external aggregation pool

Pleks maintains no external data warehouse, analytics platform, or ML training dataset that aggregates applicant or tenant data across agencies. Each agency's data is a closed silo from ingest to deletion. A successful intrusion yields one agency's data — not a cross-agency pool, because the aggregation system does not exist.

A1Platform authenticationplatform_authentication
Allow users (agents, tenants, landlords, suppliers, applicants) to sign in and maintain an authenticated session. Covers email/password, magic-link, session cookie issuance, expiry, and logout.
Lawful basiss11(1)(b) — performance of contract (Terms of Service)
Dataemail address, password hash (bcrypt), session tokens, IP address, user agent, authentication event timestamps
Recipientsdatabase and storage provider, transactional email provider (magic-link and new-device notifications)
RetentionSessions: 30 days after expiry · Auth events: 7 years · Account records: purged 30 days after account closure
Cross-borderYes — SCCs (s72(1)(a))
A2Multi-factor authenticationmfa_totp_passkeys
Enforce MFA for agent accounts (mandatory) and offer optional MFA for tenant/landlord/supplier accounts. Includes TOTP enrolment via authenticator app, passkey (WebAuthn) registration, and step-up challenges for fiduciary-class actions. Passkey biometric matching (fingerprint / face) occurs entirely on the user’s device via the WebAuthn protocol; Pleks receives only the public key and credential ID — not biometric samples — so passkey enrolment does not constitute processing of biometric information under POPIA s26.
Lawful basiss11(1)(b) — contract + s11(1)(c) — compliance with law (POPIA s19 security safeguards)
DataTOTP secret (encrypted), passkey credential ID, passkey public key, credential counter, device name, enrolment timestamps, IP at enrolment
Recipientsdatabase and storage provider, transactional email provider (enrolment/unenrolment notifications)
Retention7 years alongside auth events · revoked passkey records purged after 30 days
Cross-borderYes — SCCs (s72(1)(a))
A3Error monitoring and exception trackingerror_monitoring
Capture unhandled exceptions and server/client-side errors to detect and fix defects. Every event routed through a POPIA-safe scrubber that removes request bodies from sensitive routes and strips known PII patterns from all payloads before transmission to the error monitoring provider (see §C).
Lawful basiss11(1)(f) — legitimate interest (detection and remediation of platform defects is necessary for a reliable service)
DataUser ID (UUID), organisation ID, role, release version, error type, stack trace, route path (query parameters stripped). No email, name, phone, IP, request body, or session cookie.
Recipientserror monitoring provider (see §C)
Retention90 days at the error monitoring provider (provider default) · Pleks does not retain error events independently
Cross-borderYes — SCCs (s72(1)(a)) + PII scrubber removes personal information at source
A4In-product user feedbackuser_feedback
Capture free-text feedback, bug reports, and feature requests via the floating feedback button on authenticated layouts. Support reply-by-email. Used to prioritise product development.
Lawful basiss11(1)(a) — consent (user explicitly initiates submission) + s11(1)(b) — contract (responding to user queries)
DataUser ID, organisation ID, role, feedback category, free-text body (may contain PII the user chooses to include), submission URL, user agent, release version
Recipientsdatabase and storage provider, transactional email provider (reply delivery)
Retention5 years from submission date, then anonymised to category + sentiment only (POPIA s14 — no longer than necessary) · free-text redacted to [deleted] on earlier deletion request
Cross-borderYes — SCCs (s72(1)(a))
A5Uptime monitoring and health probesuptime_monitoring
External probes of the /api/health and /api/health/deep endpoints to detect platform outages. Heartbeat monitoring on critical daily crons. Public status page reflecting component health and 30-day uptime history.
Lawful basiss11(1)(f) — legitimate interest (platform availability monitoring is necessary for service reliability)
DataNone — probe traffic is system-to-system and contains only component health status text
Recipientsuptime monitoring provider (see §C), Slack (alert delivery)
Retention30 days rolling at the uptime monitoring provider
Cross-borderYes — SCCs (s72(1)(a)) · no personal information transmitted in probe traffic
A6Cost and usage observabilitycost_usage_observability
Track per-organisation resource consumption (emails, WhatsApp/SMS, AI calls, application hosting provider invocations, database provider compute) for unit-economics understanding, customer-facing usage counters, and overage billing where applicable.
Lawful basiss11(1)(b) — contract (subscription and usage tracking) + s11(1)(f) — legitimate interest (platform economics)
DataOrganisation ID, AI purpose codes, model, token counts, cost in cents, latency, success/error codes. No prompt text, no response text, no PII in metadata.
Recipientsdatabase and storage provider, application hosting provider (function invocation counts via management API)
RetentionAI usage rows: 2 years · cost snapshots: 36 months · messaging usage and subscription charges: 5 years (Tax Administration Act)
Cross-borderYes — SCCs (s72(1)(a))
A7Marketing waitlistmarketing_waitlist
Capture email addresses of prospective customers via the /early-access waitlist page. Send a confirmation email and, when early access is opened, a launch notification. Marketing list is explicitly opt-in per POPIA s69 direct-marketing rules.
Lawful basiss11(1)(a) — consent (user explicitly submits the waitlist form)
DataEmail address, self-declared role, consent timestamp, IP address, user agent
Recipientsdatabase and storage provider, transactional email provider (confirmation and launch emails)
RetentionUntil account creation (waitlist linked to user via matching email), or 12 months from submission if no account created
Cross-borderYes — SCCs (s72(1)(a)) and s72(1)(b) consent basis
A8Platform-level billing and subscriptionsplatform_billing
Manage Pleks’s own subscription billing to agencies — tier selection, per-lease premium charges, overage billing, invoicing, and payment processing via the payment gateway (see §C).
Lawful basiss11(1)(b) — contract (Terms of Service) + s11(1)(c) — compliance with law (Tax Administration Act, VAT Act)
DataOrganisation billing contact name, email, phone, billing address, VAT number, invoice history, charge history, tier and feature selection, subscription state
Recipientsdatabase and storage provider, transactional email provider (invoices), payment gateway (payment processing)
Retention5 years from the date of the most recent charge (Tax Administration Act s29)
Cross-borderYes — SCCs (s72(1)(a)) + s72(1)(c) necessity for performance of contract · payment gateway is SA-domiciled (domestic)
A9Support communicationssupport_communications
Inbound email to support@pleks.co.za from users or non-users requesting assistance, and outbound responses. Includes POPIA data-subject requests that reach Pleks directly (routed to the correct Responsible Party).
Lawful basiss11(1)(b) — contract (support is implicit in the Terms of Service) + s11(1)(f) — legitimate interest
DataEmail address, name, message body (may contain arbitrary PII), attachment content, correspondence thread
Recipientstransactional email provider (inbound/outbound email handling), database and storage provider (if archived in-platform)
Retention3 years from the date of the most recent correspondence, or indefinitely for threads that are part of an ongoing legal matter
Cross-borderYes — SCCs (s72(1)(a))
A10Audit loggingaudit_log
The audit_log table records every state-changing operation in Pleks — creation, update, deletion, and approval of records across the platform. Each row captures the actor, target, event type, timestamp, IP address, and change payload. The log is immutable — no UPDATE or DELETE policies exist on it.
Lawful basiss11(1)(c) — compliance with law (POPIA s17 accountability; ECT Act s14 — electronic records as originals) + s11(1)(f) — legitimate interest (security monitoring and fraud prevention)
DataActor user ID, actor IP address, target entity identifiers, event type, before-and-after values of changed fields (may incidentally include PII), timestamp
Recipientsdatabase and storage provider
Retention7 years (SA business records retention and PPRA audit timelines) · subject-initiated erasure never removes audit_log rows
Cross-borderYes — SCCs (s72(1)(a))
A11In-product analyticsNot deployedproduct_analytics
Understand how platform users navigate the product and which features they use. Currently not deployed — Pleks does not run a dedicated product-analytics tool on authenticated routes. This entry is recorded so that the absence of analytics is explicit rather than implicit.
Lawful basiss11(1)(f) — legitimate interest (would apply when deployed, with balancing test documented)
DataCurrently none
RecipientsCurrently none · any future deployment will trigger a DPIA and a register version bump
RetentionNot applicable
Cross-borderNot applicable
A12Platform administration and customer-success observabilityplatform_administration
Cross-agency operational observability for Pleks platform administrators — the /admin/platform-health dashboard (revenue vs cost, cost outliers, inactive-org flags), /admin/trust-health (overdue trust closes, FFC expiry), and /admin/popia-requests (routing inbox for data-subject requests that reach Pleks directly). Pleks routes agency-data matters to the correct Responsible Party and never executes agency-data operations directly.
Lawful basiss11(1)(f) — legitimate interest (understanding platform health is necessary to serve customers reliably; no agency personal data exposed in aggregate form)
DataOrganisation ID, name, agency FFC number and expiry, last-user-login timestamp, aggregated activity signals, cost attribution
Recipientsdatabase and storage provider, transactional email provider (customer-success outreach)
RetentionOperational signals: 5 years from last activity (POPIA s14 — no longer than necessary) · account closure: purged after billing-record retention window expires (5 years)
Cross-borderYes — SCCs (s72(1)(a))

B · Pleks as Operator

Operator purposes

These 26 purposes are those for which an agency using Pleks is the Responsible Party and Pleks is the Operator. Every purpose here is processed on behalf of the agency, under the lawful basis the agency holds for the processing, under ToS §09. Lawful basis caution: the basis shown for each purpose is the basis typically applied by agencies in the SA rental property management sector. It is not a determination by Pleks, and it does not bind any individual agency. An agency may operate on a different basis (e.g., relying on s11(1)(f) legitimate interest rather than s11(1)(b) contract for a given purpose). Each agency must confirm and document its own lawful basis in its own register. Where the agency relies on s11(1)(f) legitimate interest, it must conduct and retain a balancing test.

§02 Charter · Mandate mechanics

No inbound rail — how rent collection works

Pleks does not initiate payments. Rent collection runs through a DebiCheck or NAEDO mandate held between the tenant’s bank and the agency’s bank — Pleks is not a party to that mandate and holds no bank account numbers for this purpose. What Pleks does is read your bank statement after the collection run, match the incoming receipts to your trust ledger, and flag any mismatches. The 26 Operator purposes in this section reflect that reconciliation-observer role — not a payment-initiation role.

B1Property portfolio managementproperty_portfolio
Record and maintain the agency’s property portfolio — properties, buildings, units, managing schemes, insurance, brokers, furnishings, inspection profiles, unit types, clause profiles. Supports the agency’s core property-management function.
Lawful basiss11(1)(b) — contract (mandate agreement with landlord) + s11(1)(f) — legitimate interest (portfolio management is necessary for core business)
DataProperty address, landlord relationship, broker identity, managing scheme contact details, insurance broker and policy contact, emergency contact
Recipientsdatabase and storage provider, the AI model provider (AI-assisted property setup when used — see B22)
RetentionDuration of agency mandate + 5 years post-termination
Cross-borderYes — AI processing via the AI model provider (SCCs)
B2Landlord CRM and relationship managementlandlord_crm
Maintain landlord profiles, contact details, bank details for statement payouts, relationship history, and communication preferences. Supports owner statements, communications, and the landlord portal.
Lawful basiss11(1)(b) — contract (mandate agreement with landlord) + s11(1)(c) — compliance with law (PPRA disclosure and tax obligations)
DataName, ID number, date of birth, contact phone, contact email, addresses, bank account details (masked at rest, encrypted for operational use), marital status where relevant
Recipientsdatabase and storage provider, transactional email provider (landlord communications), SMS and WhatsApp aggregator
RetentionDuration of mandate + 5 years post-termination (PPRA trust record retention)
Cross-borderYes — SCCs (s72(1)(a))
B3Tenant application processingtenant_application

Accept rental applications from prospective tenants via the public /apply/[slug] portal. Capture form data, supporting documents (ID, proof of income, bank statements, employer letter), and consent records. Support the agency’s shortlist-and-screen workflow. Also processes personal information of third parties named in the application: references, employer contacts, household members, emergency contacts.

Reference contacts as data subjects (POPIA · S12 / S18). References named by an applicant are data subjects in their own right. Under s12 (collection directly from the data subject) and s18 (notification), references must be informed that their personal information has been collected and for what purpose. ToS §09.1 contractually requires the agency to send a s18 notice to each reference at the point of first contact — stating that they have been named as a reference for a rental application, what information will be requested from them, how long it will be retained, and how to exercise their rights. Pleks provides a template s18 notice that agencies may use. Compliance with this obligation is auditable via the communication log.

Children’s personal information (POPIA s34–s35). Applications routinely include dependent details and household members who are minors. Under POPIA s34, processing a child’s personal information requires consent from a competent person (parent or legal guardian). By submitting an application that includes dependent or household-member details for a person under 18, the applicant represents that they are the competent person within the meaning of s34 and are providing consent on behalf of that minor. Processing of minors’ information is limited strictly to housing-suitability necessity — establishing occupancy count and dependent-support obligations relevant to affordability. No credit check, identity verification, or marketing processing is performed against minor household members.

Lawful basiss11(1)(a) — consent (applicant submits the form and consents to processing for the specific application) + s11(1)(b) — pre-contractual steps at the data subject’s request
DataFull name, ID number, DOB, contact phone/email, employment details, salary, dependent details, previous rental history, landlord/employer/character references, supporting documents
Recipientsdatabase and storage provider, the payment gateway (application fee — B9), the credit bureau aggregator (credit check — B4), the AI model provider (income extraction — B22), e-signature provider (if application leads to lease signing)
RetentionDeclined/withdrawn applications — raw screening data (identity documents, bank statements, income records, the credit bureau report, contact details, and the AI-generated narrative): 90 days from the terminal decision (automatic purge) · decision-accountability record (FitScore composite/band/per-dimension components, inputs hash, engine and interpretation versions, categorical decision-reason and adverse-factor codes, decision date/stage/deciding-agent identity, the screening-policy version, and the audit-log reference): up to 5 years from the terminal decision (POPIA s14(1)(b) — accountability and defence of legal rights); active legal holds suspend purge · Approved applications: absorbed into lease retention (5 years post-termination)
Cross-borderYes — SCCs (s72(1)(a)) for AI and hosting
B4Credit checking (credit bureau aggregator)credit_check_searchworx

Obtain a credit bureau report on an applicant for the purpose of assessing tenancy suitability. The credit bureau aggregator (see §C) consolidates TransUnion, Experian, Compuscan, and XDS. A DPIA (Data Protection Impact Assessment) is in progress for this purpose and will be completed before the feature ships to production — credit data is among the highest-sensitivity personal information categories. No credit check is performed without explicit written consent under POPIA s11(1)(a), in compliance with the Credit Bureau Code of Conduct (issued under POPIA, October 2020) and the credit bureau aggregator’s user agreement (see §C). The NCA s69 register of credit agreements does not provide the consent basis for bureau enquiries — that basis is POPIA s11(1)(a) alone. Consent is captured and verified through a two-step SMS verification — a one-time code sent to the applicant’s own mobile number must be entered before any bureau enquiry is initiated — so the consent is demonstrably the applicant’s own (operationally live since 2026-05-14).

Single-bundle architecture. Credit checks are offered as one standard bundle — a Searchworx report consolidating TransUnion, Experian, Compuscan, and XDS. Each person screened pays for their own check, after their own consent. For a commercial (juristic) applicant, the signatory pays the company’s check for the company only, and each surety director pays for their own — see B9 and B5.

Dual-output reports. Each check produces two outputs: a Consumer Report (PDF delivered to the applicant via a 7-day TTL signed URL under POPIA s18 transparency obligations — contains only the applicant’s own credit data) and an Agent Report (structured credit result and FitScore inputs surfaced in the agent’s applicant dashboard — not transmitted to the applicant). The Consumer Report is generated regardless of the check outcome.

Lawful basiss11(1)(a) — explicit consent (applicant consents to the specific purpose of a credit check before it is run; consent may be withdrawn for future checks but not to unwind a check already performed)
DataApplicant ID number, full name, DOB, residential addresses (current and historical), employment history, credit history, default records, civil judgments, credit score, affordability result
Recipientscredit bureau aggregator — SA-domiciled, domestic processing (see §C); underlying bureaus via credit bureau aggregator; database and storage provider; AI model provider (FitScore generation — B5)
RetentionDeclined / withdrawn applicants — raw bureau report: 90 days from pull date (automatic purge — matches the B3 raw-screening tier) · derived scoring outputs surviving in the B3/B5 decision-accountability record: up to 5 years (POPIA s14(1)(b)); active legal holds suspend purge · Approved applicants: 12 months from the check or the lease's end, whichever is later · consent log entry retained 5 years from the consent event, then deleted (POPIA s17 — Documentation)
Cross-borderNo for the credit check itself (credit bureau aggregator and SA credit bureaus are domestic) · Yes for derivative AI processing (FitScore via the AI model provider — SCCs)
B5FitScore generation and applicant comparisonfitscore

Generate a numeric affordability-and-suitability score for a rental applicant by combining credit check results (B4), verified income (B22 income extraction), rental history, and employment stability. Displayed to the agent alongside a human-readable rationale. Where an application has more than one party, the application’s consolidated assessment — its score and band, the affordability line, and the parties it was computed on — is also shown to each party who completed their part and consented to that sharing; no party’s individual report or per-party result is shown to another party. FitScore is an assistive tool — it does not constitute an automated decision under POPIA s71. Final decisions are made solely by the agency or landlord.

Commercial composite FitScore. For juristic applicants (companies applying for commercial or semi-commercial tenancies), a commercial composite FitScore is generated by combining the company’s credit result with individual FitScores for each named surety director. Each director generates a separate FitScore under their own individual B4 consent — the composite result reflects both entity-level creditworthiness and principal-level affordability. The number of surety directors is configurable per application.

The agency isolation guarantee extends to FitScore data specifically: results are scoped to the originating agency at the point of computation and cannot be queried across org boundaries at any layer. See the four-layer enforcement structure for how this isolation is verified at the database, application, computation, and integration levels.

Lawful basisFollows Purpose B4 — s11(1)(a) explicit consent (applicant consented to the credit check knowing results would inform a suitability assessment)
DataDerivative of B4 (credit result) + declared income, verified income, rental history, employment information
RecipientsThe AI model provider (FitScore rationale narrative generation — B22), database and storage provider; the other parties to the same application (the consolidated assessment only, to a party who completed and consented to the sharing)
RetentionTwo-tier for declined/withdrawn applicants — the FitScore inputs and source documents are purged with the raw screening data at 90 days; the structural FitScore outputs (composite, band, per-dimension components, inputs hash, and engine/interpretation/narrative-prompt versions) survive in the decision-accountability record for up to 5 years (POPIA s14(1)(b)); active legal holds suspend purge · Approved applicants: 5 years post-lease-termination
Cross-borderYes — AI processing via the AI model provider (SCCs + s72(1)(b) consent basis)
B6Lease generation, signing, and document managementlease_generation_signing
Generate a lease document from the agency’s configured template + clause profile + unit-level overrides; render to PDF; route through the e-signature provider (see §C) for digital signing; store signed lease PDF and signatures. Covers lease creation, amendment, renewal, and termination document flows. ECT Act signature class note: standard residential lease agreements are validly signed with an ordinary electronic signature under ECT s13(1). Suretyship obligations under the General Law Amendment Act s6 are not covered by ECT s13 and may require an Advanced Electronic Signature or wet signature — agencies should seek legal advice before accepting a surety via the platform. This register does not constitute legal advice on signature validity.
Lawful basiss11(1)(b) — contract (the lease is the contract) + s11(1)(c) — compliance with law (RHA s5 written lease requirements, CPA s14, ECT Act signature requirements)
DataFull names, ID numbers, DOBs, contact details, employment details, signatures, co-tenant and landlord signatures, sureties if any
Recipientsdatabase and storage provider, e-signature provider (self-hosted, same infrastructure as Pleks), transactional email provider (signing invitations), AI model provider (clause conflict checking — B22)
Retention5 years post-termination (Prescription Act + PPRA mandate practice)
Cross-borderYes — SCCs (s72(1)(a)) and s72(1)(c) necessity for performance of contract
B7Lease lifecycle managementlease_lifecycle
Manage the lease over its full lifecycle — activation, escalation at anniversaries, CPA s14 auto-renewal notice (sent not more than 80 nor less than 40 business days before expiry, per CPA s14(2)(d)), notice acknowledgement, amendment (with audit trail), termination, move-out, and deposit reconciliation. Where the lease is not subject to the CPA (e.g., landlord not supplying services in the ordinary course of business), the contractual notice period specified in the lease applies instead.
Lawful basiss11(1)(b) — contract + s11(1)(c) — compliance with law (RHA and CPA specific notice obligations). RHA commencement note: the written-lease requirement cites RHA s5 as amended by the Rental Housing Amendment Act 35 of 2014. Commencement of that Amendment has been irregular across provinces; agencies operating in provinces where the Amendment has not commenced should confirm the applicable statutory basis with their attorneys.
DataTenant contact details, lease state, notice history
Recipientsdatabase and storage provider, transactional email provider and SMS and WhatsApp aggregator (notice delivery)
RetentionFollows Purpose B6 — 5 years post-termination
Cross-borderYes — SCCs (s72(1)(a))
B8Rent invoicing and payment trackingrent_invoicing_tracking
Generate monthly rent invoices and maintain the rent ledger per lease showing invoiced amounts, received amounts (matched from trust reconciliation — B12), and outstanding balances. Pleks does not execute rent collection under any payment rail — all money moves directly between the tenant’s and agency’s SA banks.
Lawful basiss11(1)(b) — contract (the lease establishes the rent obligation) + s11(1)(c) — compliance with law (PPRA record-keeping, Tax Administration Act)
DataTenant name, lease identifier, rent amount, invoice history, payment receipt history. No tenant bank account numbers are stored by Pleks.
Recipientsdatabase and storage provider
Retention5 years post-lease-termination (PPRA record retention + Tax Administration Act s29)
Cross-borderYes — database and storage provider (SCCs)
B9Application fee processing (payment gateway)application_fee_processing

Accept the applicant’s rental application fee directly via the payment gateway (see §C). The fee is a Pleks-to-applicant service charge covering the cost of the underlying credit bureau report and Pleks’s cost of operating the application-processing service. The agency receives no portion of any application fee under any tier or commercial arrangement.

Pricing. Each person screened pays their own screening fee, after their own consent; the fee covers that person’s credit check, Consumer Report PDF delivery, and bank-statement income analysis (B22). In a joint application each co-applicant pays for their own check — no one pays for another person’s. Commercial / juristic applicants: the signatory pays the company’s screening fee for the company only, and each surety director pays their own per-person fee.

Refund mechanics. The screening service commences upon successful payment. The screening checks are then initiated and the resulting reports are generated as part of that service. Fees are not refundable merely because the applicant changes their mind after screening has commenced, subject to any rights or remedies that cannot lawfully be excluded.

If a bureau or screening provider experiences a technical failure and, after reasonable retries, no screening report is generated, Pleks will refund the screening fee to the extent required by applicable law.

Lawful basiss11(1)(a) — consent (applicant initiates payment knowing the purpose) + s11(1)(b) — contract
DataApplicant name, email, payment amount, transaction reference, payment method indicator (not full card number — payment gateway is the PCI boundary)
Recipientspayment gateway — SA-domiciled (see §C)
Retention5 years (Tax Administration Act s29)
Cross-borderNo — payment gateway is SA-domiciled (domestic processing)
B10Owner (landlord) statementsowner_statements
Generate monthly statements for each landlord showing rent collected, deductions (management fees, maintenance, municipal, deposit transactions), and net payable. Deliver via email or landlord portal.
Lawful basiss11(1)(b) — contract (mandate requires financial reporting) + s11(1)(c) — compliance with law (PPRA statement-of-account requirements)
DataLandlord name, contact details, property portfolio breakdown, financial transaction data
Recipientsdatabase and storage provider, transactional email provider (email delivery), AI model provider (welcome pack narrative — B22)
Retention5 years from statement date (Tax Administration Act s29)
Cross-borderYes — SCCs (s72(1)(a))
B11Rent ledger, arrears, and letters of demandrent_ledger_arrears
Maintain the rent ledger per lease, track arrears cases, and escalate arrears through a graduated sequence — informal reminder → formal reminder → letter of demand → final notice before cancellation. Record payment arrangements and resolve cases.
Lawful basiss11(1)(b) — contract + s11(1)(c) — compliance with law (formal demand requirements, RHA s4B) + s11(1)(f) — legitimate interest (protecting landlord’s income)
DataTenant contact details, payment history, arrears amount, communications sent, arrears case state
Recipientsdatabase and storage provider, transactional email provider and SMS and WhatsApp aggregator (communication delivery), AI model provider (LOD text generation — B22)
Retention5 years post-termination (Prescription Act + PPRA + Tribunal evidentiary practice)
Cross-borderYes — SCCs (s72(1)(a))
B12Trust account reconciliationtrust_reconciliation
Monthly reconciliation of the agency’s Section 54 trust account. Bank statement import (OFX/CSV/QIF), matching rent receipts against ledger entries, verification of disbursements, three-balance comparison, and sign-off. Produces an PPRA-compliant audit export (PDF + XLSX) with SHA-256 manifest hash for tamper-evidence.
Lawful basiss11(1)(c) — compliance with law (Property Practitioners Act s54, PPA Regulation 33 — 5 years from the end of the financial year, PPRA audit requirements, Tax Administration Act s29)
DataTenant names on trust transactions, landlord and supplier names on disbursements, transaction amounts, payment references, dates, bank statement narrative text, masked bank account numbers (encrypted at rest)
Recipientsdatabase and storage provider, AI model provider (variance explanation narrative — B22)
Retention5 years (PPRA trust record retention + Tax Administration Act s29)
Cross-borderYes — AI processing via the AI model provider (SCCs) · bank data arrives by local file upload, or through the bank-feed aggregator (United States, SCCs) when the agency connects a feed
B13Deposit managementdeposit_management
Record deposit receipts, accrue interest (prime-linked, fixed, repo-linked, or manual), generate interest statements, handle deposit deductions at move-out (wear-and-tear vs damage classification with per-item justification), and issue itemised deduction schedule within 21 days per Rental Housing Act s5(7).
Lawful basiss11(1)(b) — contract + s11(1)(c) — compliance with law (Rental Housing Act s5 deposit rules, PPRA trust account rules)
DataTenant name, deposit amount, interest accrued, deduction history with per-item details, photos of damage claimed, wear-and-tear assessments
Recipientsdatabase and storage provider (including photo storage), transactional email provider (statement delivery), AI model provider (deduction justification narrative — B22)
Retention5 years post-termination (PPRA trust record retention)
Cross-borderYes — AI processing via the AI model provider (SCCs)
B14Inspection managementinspection_management
Schedule and conduct property inspections (move-in, periodic, move-out). Capture condition per room and per item. Preserve photo EXIF data (GPS and timestamp) for Tribunal evidentiary purposes. Generate inspection PDF with agent and tenant signatures. Photo protocol: agents must not photograph identifiable persons (including children present at inspection). Where a person is inadvertently captured, the image must be blurred or cropped to remove the identifiable person before upload and storage. Agents are notified of this requirement within the inspection workflow. Photos of tenant belongings or personal effects visible in the property are retained only where necessary to document condition relevant to deposit deductions.
Lawful basiss11(1)(b) — contract + s11(1)(c) — compliance with law (Rental Housing Act inspection requirements)
DataTenant name and signature, agent name and signature, property address, photos of the property interior and exterior (EXIF GPS and timestamp preserved; may incidentally include tenant belongings or persons)
Recipientsdatabase and storage provider, AI model provider (wear-and-tear assessment — B22)
Retention3 years post-termination · 5 years if a Tribunal dispute arises within the retention window
Cross-borderYes — AI processing via the AI model provider (SCCs)
B15Maintenance managementmaintenance_management
Accept maintenance requests from tenants (via portal, WhatsApp, or SMS), AI-triage for severity and category, assign to contractors, track progress, record completion, split costs between landlord / tenant / other parties, and handle delays and contractor communication.
Lawful basiss11(1)(b) — contract + s11(1)(c) — compliance with law (RHA s4B habitability duty)
DataTenant name and contact details, description of the issue, photos of the issue, contractor assignment, cost allocation
Recipientsdatabase and storage provider, SMS and WhatsApp aggregator (contractor notifications), AI model provider (maintenance triage — B22), transactional email provider (email notifications)
Retention3 years post-completion (Tribunal evidentiary practice)
Cross-borderYes — SCCs (s72(1)(a)) for AI, email, and SMS/WhatsApp routing (SMS and WhatsApp aggregator is Kenya-domiciled)
B16Critical incident handlingcritical_incident
Handle high-severity maintenance incidents (fire, burst pipe, major break-in, geyser failure) with an expedited workflow. Notify broker (for insurable events), owner, and managing scheme in parallel. Record the incident and the decisions taken. Integrates with insurance claim preparation.
Lawful basiss11(1)(c) — compliance with law (habitability duty; insurer disclosure obligations) + s11(1)(f) — legitimate interests of the Responsible Party and the insurer as affected third party (s11(1)(e), which applies to public bodies, does not apply here)
DataAs B15 plus insurance broker and policy contact details, owner notification preferences, scheme notification preferences
Recipientsdatabase and storage provider, transactional email provider (broker and scheme notifications), SMS and WhatsApp aggregator (urgent contractor dispatch)
Retention5 years (insurance claim evidence + Tribunal evidentiary practice)
Cross-borderYes — SCCs (s72(1)(a))
B17Tenant communications lifecycletenant_communications
The tenant-facing communication layer across the full tenancy — rent invoices, payment receipts, monthly statements, arrears escalation, lease lifecycle events, inspection reminders, maintenance updates, deposit events, portal invitations, retry cascades, and delivery tracking. WhatsApp-primary with SMS and email backup.
Lawful basiss11(1)(b) — contract + s11(1)(c) — compliance with law (RHA and CPA mandatory notice obligations; mandatory comms bypass tenant opt-out preferences)
DataTenant name, contact phone, contact email, message body, delivery status, WhatsApp template variant used, communication preferences for non-mandatory comms
RecipientsSMS and WhatsApp aggregator (WhatsApp via WhatsApp Business Platform provider, SMS), transactional email provider, database and storage provider (full-body retention for Tribunal evidence)
Retention5 years post-termination (aligned with trust records; Tax Administration Act support)
Cross-borderYes — WhatsApp Business Platform provider is US/IE; transactional email provider is US. SCCs (s72(1)(a))
B18Supplier / contractor managementsupplier_management
Maintain the agency’s list of contractors and suppliers, their trade categories, FFC/PPRA status where applicable, contact details, job history, invoice submissions, and payments. Support the contractor portal for job communication and status updates.
Lawful basiss11(1)(b) — contract (contractor mandate for specific jobs) + s11(1)(c) — compliance with law (agency duty to verify contractor legitimacy)
DataContractor name, contact details, trade, rates, FFC number if applicable, bank details for payment (encrypted), job history, invoice submissions
Recipientsdatabase and storage provider, transactional email provider and SMS and WhatsApp aggregator (communications)
Retention5 years from last engagement (Tax Administration Act s29)
Cross-borderYes — SCCs (s72(1)(a))
B19Municipal bill processingmunicipal_bill_processing
Parse municipal bills (rates, water, electricity, refuse) via AI extraction when uploaded by the agent. Allocate charges across properties when the bill covers multiple units. Flag anomalies (sudden increases, unusual consumption). Support payment tracking.
Lawful basiss11(1)(b) — contract (mandate to manage property expenses) + s11(1)(c) — compliance with law (PPRA property-management record keeping)
DataProperty address, account holder (usually the landlord), municipal account number, consumption and charge data
Recipientsdatabase and storage provider, AI model provider (bill extraction — B22)
Retention5 years (Tax Administration Act s29)
Cross-borderYes — AI processing via the AI model provider (SCCs)
B20HOA / Body Corporate / Managing Schemehoa_scheme_management
For properties in a Homeowners Association or Body Corporate, manage levy schedules, AGM documents, reserve fund contributions, levy arrears, and scheme contact details.
Lawful basiss11(1)(b) — contract + s11(1)(c) — compliance with law (Sectional Titles Schemes Management Act)
DataScheme contact details, levy payment history per owner, AGM attendance and voting records where relevant
Recipientsdatabase and storage provider, transactional email provider (AGM and levy communications), AI model provider (AGM notice drafting — B22)
Retention5 years (STSMA and tax retention) · AGM records per scheme bylaws (indefinite in most cases)
Cross-borderYes — AI processing via the AI model provider (SCCs)
B21Document generation and storagedocument_generation
Generate, store, and deliver documents that combine data from multiple Part B purposes — welcome packs for new tenants, landlord reports, property rules documents, inspection certificates, arrears bundles, and compliance packs for Tribunal proceedings.
Lawful basiss11(1)(b) — contract + s11(1)(c) — compliance with law (varies by document type; follows the source purpose)
DataNames, contact details, financial data, and other personal information drawn from source purposes; AI-generated narrative text
Recipientsdatabase and storage provider, transactional email provider (document delivery), AI model provider (narrative generation — B22)
RetentionFollows the source data (typically 5 years post-termination for lease records)
Cross-borderYes — SCCs (s72(1)(a))
B22AI-assisted processingai_assisted_processing

Bounded, assistive AI processing across multiple workflows — income extraction and classification from bank statements, FitScore rationale, maintenance triage, deposit deduction justification, lease clause conflict checking, arrears letter drafting, wear-and-tear assessment, municipal bill extraction, AGM notice drafting, and trust audit narrative. AI processing is assistive only: Pleks does not make automated decisions about tenants or applicants. All decisions remain with the agency or landlord. Prompts and responses are not retained — the AI model provider (see §C) operates under a zero-retention Enterprise DPA. PII minimisation is applied before cross-border transfer: prompts contain structured context values (amounts, dates, categories) and exclude direct identifiers (name, ID number, contact details) where the task does not require them. This minimisation reduces but does not eliminate identifiability — structured context (property address, exact rent, exact arrears, dates) may remain reasonably linkable to an individual and constitutes pseudonymised, not anonymised, personal information under POPIA s1. All cross-border AI transfers therefore remain personal information transfers and are governed by SCCs under POPIA s72(1)(a). The agency remains solely responsible for ensuring deductions comply with the Rental Housing Act and applicable Tribunal standards. Agencies are expected to review AI-generated outputs for accuracy, fairness, and contextual appropriateness before relying on them operationally.

Bank statement income and classification. A single Sonnet call performs six simultaneous analyses on each uploaded bank statement: (1) identity match — name on statement against applicant ID document; (2) statement-quality validation — detects missing months, unexplained gaps, account closures, and statement-period truncation; (3) 13-category recurring-debit classification — rent, vehicle finance, insurance, telco, streaming, gym, maintenance levies / HOA, school fees, medical aid, loan repayments, food / utilities, gambling / FICA-flag items, and other; (4) declared-rent fuzzy match — validates the amount the applicant claims to pay in rent against actual debit entries; (5) Pleks invoice-reference detection — identifies whether invoices from Pleks-managed properties appear as expected in the statement; (6) income-reasonableness check — flags implausible declared income against visible credits. The classified output feeds the B5 FitScore affordability model and is included in the B4 Agent Report. Under POPIA s71 this output is advisory — no automated decision is made on the basis of bank statement classification alone.

Lawful basisMultiple — follows the lawful basis of the sub-purpose (e.g., B4 consent for FitScore, B7 contract for lease clause checking)
DataStructured context specific to the sub-purpose only. Direct identifiers (name, ID number, contact details) are stripped where not required by the task. No prompt text or response text retained by Pleks or the AI model provider.
RecipientsAI model provider — see §C (zero-retention Enterprise DPA + SCCs)
RetentionNo retention — zero-retention DPA with the AI model provider (see §C); derivative outputs follow the source purpose’s retention period
Cross-borderYes — AI model provider (see §C) is US-based. SCCs (s72(1)(a)) + zero-retention Enterprise DPA
B23POPIA data-subject request handlingpopia_subject_requests
Process data-subject requests — access (s23), correction (s24), deletion (s25), objection (s11(3)), restriction, and portability — received via the in-platform subject-rights dashboard or direct contact. For Part B requests, Pleks routes to the correct agency (Responsible Party) and supports the agency’s 30-day response window. For Part A requests, Pleks responds directly.
Lawful basiss11(1)(c) — compliance with law (POPIA Chapter 5 and Chapter 10 obligations)
DataData subject identity, request type, correspondence, resolution decision, consent log entries, audit trail of request processing
Recipientsdatabase and storage provider, transactional email provider (response communications)
Retention10 years (POPIA accountability obligations; audit trail of rights exercises)
Cross-borderYes — database and storage provider (SCCs)
B24FICA / KYC documentation storagefica_kyc_storage
Store FICA / KYC documentation for agencies that are Accountable Institutions under the Financial Intelligence Centre Act — copies of founding documents, director ID documents, proof of address, tax numbers. Supports the agency’s own FICA compliance obligations.
Lawful basiss11(1)(c) — compliance with law (Financial Intelligence Centre Act s22/s23 record-keeping obligations for Accountable Institutions)
DataName, ID number, proof of address, banking details, SARS tax number — all stored encrypted at rest via the database and storage provider (see §C)
Recipientsdatabase and storage provider (encrypted)
Retention5 years post-termination of business relationship (FICA s23 record-keeping obligation)
Cross-borderYes — database and storage provider (SCCs)
B25Agency-originated direct marketing to tenants and landlordsReserved — not deployedagency_direct_marketing
Reserved placeholder for a future capability that would allow agencies to send opted-in marketing communications (e.g., property listings, market commentary) to their own tenant or landlord contacts via the Pleks platform. Not currently deployed. Any deployment will require a new consent basis, a register version bump, and re-consent notification per the maintenance discipline.
Lawful basiss11(1)(a) — explicit consent (would be required before any deployment)
DataCurrently none
RecipientsCurrently none · any deployment requires DPIA and register version bump
RetentionNot applicable
Cross-borderNot applicable
B27Property and landlord verification (property-intelligence)property_intelligence

Pull public-register information about properties and landlords to verify mandate legitimacy and support property valuation decisions. Three product families: (1) Deeds Office searches — confirming the registered owner of a property matches the person presenting themselves as the landlord at mandate-taking; (2) Lightstone Erf Valuation Short — indicative property market value for owner pitches, FFC due diligence, and insurance value confirmation; (3) CIPC Company and Director lookups — verifying that juristic landlords exist, are in good standing, and that the natural persons claiming to act for them are listed as directors. CIPC Director pulls are limited to first-layer corporate ownership — directors of the named juristic landlord only. Beneficial-ownership chains beyond the first layer constitute a distinct processing purpose with their own balancing test and are out of scope here.

Lawful basis — nature of data matters. For Deeds Office and CIPC pulls (which surface personal information about landlords and directors): POPIA · S11(1)(c) compliance with law — including mandate-taking and due-diligence obligations under the Property Practitioners Act, its Regulations, and the PPRA Code of Conduct — stacked with POPIA · S11(1)(f) legitimate interest — agency-side mandate-fraud prevention and protection of the genuine landlord’s interests against impersonators. The balancing test under s11(1)(f) favours processing: the data subjects’ privacy interests are minimally impacted because the Deeds Office and CIPC are statutorily public registers accessible to any member of the public. For Lightstone Erf Valuation Short in isolation: POPIA does not apply — the return values are property-domain only (no natural-person data subject). Where valuation data is stored alongside Deeds-pulled owner identity data, the combined record is personal information and falls under the Deeds Office analysis above — this prevents a “no POPIA” framing from being misread as a categorical exemption for the combined record.

Distinction from Purpose B4 (credit screening). B27 is structurally distinct from B4 despite both using Searchworx as aggregator. (1) Lawful basis: B4 is POPIA · S11(1)(a) explicit consent — the applicant actively consents to a credit check; B27 stacks s11(1)(c) compliance with law and s11(1)(f) legitimate interest because the data subjects are landlords and directors whose information is in public registers and the agency has a statutory mandate-due-diligence obligation — consent is neither required nor appropriate. (2) Data classification: B4 surfaces credit-bureau data (privacy-sensitive even where lawful); B27 surfaces public-register data (statutorily accessible). (3) Retention: B4 applies POPIA minimisation against credit data (12 months); B27 follows PPA s54 + Regulation 33 mandate-records retention (5 years from end of mandate, or longer where the record supports an audit trail). Conflating B27 with B4 produces incorrect retention enforcement and an incorrect consent posture.

Safeguards. ID numbers from Deeds Office and CIPC Director pulls are stored encrypted at the column level and masked in all display surfaces (last four digits by default; full disclosure gated behind an explicit action and audit-logged) — matching the §03 safeguards pattern applied to FICA records (B24) and credit-screening records (B4). Prior-owner data disposition: where prior-owner data appears incidentally in a deed-history response, it is retained in the raw vendor-response audit payload but not surfaced in the agency UI, not parsed into operational extracted fields, and not used for any operational purpose. POPIA · S18 notification posture: individual s18 notification is not provided to incidental data subjects (first-layer directors and prior owners surfaced in vendor responses). Reliance is placed on the s18(4) notification exceptions — the personal information is derived from a statutory public register; notification would prejudice a lawful fraud-prevention purpose; notification is not reasonably practicable given the manner and source of collection. Operationally engaged directors receive notification through the agency relationship itself per standard s18 practice.

Lawful basisDeeds Office + CIPC pulls: s11(1)(c) — compliance with law (Property Practitioners Act s54, PPA Regulations, PPRA Code of Conduct mandate-taking obligations) stacked with s11(1)(f) — legitimate interest (mandate-fraud prevention; protection of genuine landlord’s interests) · Lightstone Erf Valuation Short in isolation: POPIA inapplicable (property-domain data only, no natural-person data subject); combined record with Deeds-pulled owner data falls under the s11(1)(c)/(f) analysis above
DataDeeds Office: registered owner name, ID number, purchase date, purchase price, deed number, title deed reference, transfer date · CIPC Company: registered name, registration number, status, registered address, business start date · CIPC Director (first-layer only): director name, ID number, appointment date, status, position · Lightstone: estimated property value, value-band low/high, confidence indicator, last-sale date and price (no personal information in isolation)
RecipientsSearchworx (credit bureau aggregator — see §C; B27 accesses Deeds Office, CIPC, and Lightstone product families via the same Searchworx vendor relationship as B4); Lightstone (commercial property-data vendor; sub-Operator to Searchworx for the valuation product family — Lightstone POPIA compliance incorporated by reference into the Pleks/Searchworx commercial agreement per POPIA s21(2)); database and storage provider; payment gateway (per-pull transaction processing)
RetentionDeeds Office and CIPC pulls: 5 years from end of mandate (Property Practitioners Act s54 + Regulation 33; PPRA mandate-record practice) — where the pull supports an audit-trail record, the longer 7-year period applies (POPIA s17 + Companies Act s24) · Lightstone valuations: operational life of associated property record; where combined with Deeds-pulled owner data, follows the longer applicable retention period · Pulls are permanent operational records — re-pulls create new rows without overwriting prior ones (preserving the “agency verified ownership at date X” audit lineage)
Cross-borderNo for source data — Searchworx, Deeds Office of South Africa, CIPC, and Lightstone all operate domestically (domestic processing; no SCCs required for source pulls) · Yes for storage and hosting downstream (database and storage provider, application hosting — SCCs under s72(1)(a))
DPIANot required (statutory) — established legitimate-interest processing of public-register data; no s26 special-information categories; no automated decision-making producing legal or similarly significant effects; narrow purpose; low data-subject impact · Informal DPIA planned before B27 reaches general availability across all tiers (or Q3 2026 at latest) to strengthen the s11(1)(f) balancing-test documentation — not a precondition for early-access availability

C · Appendix A

Operators directory

Every third party Pleks uses in the course of processing personal information. For each: what they do, where they are domiciled, what contractual instrument governs the relationship, and which purposes they serve.

OperatorRoleDomicileInstrumentPurposes
Supabasedatabase · storage · authBackend-as-a-service — Postgres database, authentication, storage, realtimeIreland (EU — eu-west-1)Terms of Service + Data Processing Addendum with SCCs. Sub-processor: AWS.A1–A12, B1–B25, B27
AnthropicAI model providerClaude Haiku 4.5, Sonnet 4.6, Opus 4.6 — bounded assistive-only AI processingUS (San Francisco)Anthropic Commercial Terms + DPA with SCCs + zero-retention Enterprise agreement (no API inputs or outputs retained for training)B22
Yodleebank-feed aggregatorBank-feed aggregation — reads the agency's connected bank account transactions for trust reconciliation, when the agency connects a feedUSEnvestnet | Yodlee Terms + DPA with SCCsB12
Sentryerror monitoringException tracking for platform defect detection. All events PII-scrubbed before transmission.US (San Francisco)Sentry Terms of Service + DPA with SCCsA3 only
Resendtransactional emailTransactional and marketing email delivery. Suppression list and DKIM/SPF/DMARC enforced.USResend Terms of Service + DPA with SCCsA1, A4, A7–A9, A12; B2, B7, B10, B11, B17, B21, B23
Africa's TalkingSMS · WhatsApp aggregationSMS and WhatsApp Business Platform aggregation for SA mobile networks. Routes WhatsApp through Meta.Kenya (Nairobi)Africa's Talking Terms of Service + DPAB2, B11, B15–B18
PayFastpayment gatewayPayment processing for application fees and Pleks subscription payments. PCI DSS Level 1 certified.South Africa (domestic)PayFast Merchant Agreement. Pleks never sees full card PAN — PayFast is the PCI boundary.B9, B27, A8 (limited)
DocuSeale-signature · self-hostedDigital signature and document-signing workflow. Self-hosted on Hetzner SA (South African infrastructure) — no cross-border transfer.South Africa — Hetzner SA (domestic; no SCCs required)DocuSeal open-source licence. No third-party DPA required — no data leaves Pleks's infrastructure.B6
MetaWhatsApp BusinessUpstream WhatsApp Business Platform provider — reached via Africa's Talking. Meta-approved templates for transactional messages only.US (California) / Ireland (EU)Meta's terms mediated through Africa's Talking relationshipB17
Better Stackuptime monitoringUptime monitoring, heartbeat tracking, and alerting. No PII in probe traffic.US (Delaware)Better Stack Terms of Service + DPA with SCCsA5 only
Vercelapplication hostingNext.js hosting, edge-function invocation, CDN. Hosts the entire Pleks application.US (San Francisco), global edgeVercel Terms of Service + DPA with SCCs. Logs are POPIA-scrubbed consistent with observability policy.A1–A12, B1–B25, B27
Searchworxcredit bureau aggregatorMulti-product data intermediary — aggregates TransUnion, Experian, Compuscan, and XDS (credit products); Deeds Office of South Africa (property ownership); CIPC (company and director data); Lightstone (property valuations); Home Affairs (DHA); TPN. Explicit applicant consent required per credit check (B4). Property-intelligence pulls (B27) operate under s11(1)(c)/(f) — no applicant consent required. Lightstone operates as a sub-Operator to Searchworx for the valuation product family.South Africa (Johannesburg — domestic)Searchworx Services Agreement + POPIA-compliant DPA. Searchworx is itself bound by NCA, POPIA, and FICA regulatory obligations. Data residency: asserted as SA-domiciled; Pleks is seeking written confirmation from Searchworx that all credit data (including data transiting to underlying bureaus TransUnion, Experian, XDS, Compuscan) remains within SA infrastructure. This entry will be updated on receipt of confirmation. Lightstone POPIA compliance incorporated by reference per POPIA s21(2).B4, B27
Lightstoneproperty valuationsCommercial property-data vendor providing Erf Valuation Short — estimated market value, value-band, last-sale data. Accessed exclusively via the Searchworx operator chain; Lightstone does not receive or process Pleks customer personal information directly.South Africa (domestic)Lightstone data licence via Searchworx operator chain. Lightstone POPIA compliance posture incorporated by reference into the Pleks/Searchworx commercial agreement per POPIA s21(2). No direct Pleks–Lightstone DPA required — relationship governed through Searchworx.B27 (property valuation sub-purpose only)
GitHubsource code hostingSource-code hosting. Processes contributor PII (commit author identities) only — no customer personal information.US (San Francisco)GitHub Terms of Service. Secret-scanning and Dependabot enabled. No customer data in code.None for customer data
Google Maps Platformaddress autocompleteAddress autocomplete when an agent adds a property. Receives the typed address text and the agent's browser IP; no tenant, applicant or ID data.US (Mountain View)Google Maps Platform Terms of Service + Google's data protection terms for Maps PlatformB1

This register is maintained as a living document. Every new processing purpose or new Operator introduced by a subsequent Pleks build specification requires an entry here before the feature ships. The version number increments on every material change (new purpose, new Operator, new cross-border transfer, retention period change, lawful basis change). Material changes also trigger a re-consent notification flow to affected agencies.

For questions about this register or to exercise your rights as a data subject, contact our Information Officer — see §02 above. The data-processing obligations that give this register contractual force for Part B purposes are set out in section 09 of the Pleks Terms of Service. Agencies evaluating Pleks for procurement are encouraged to review ToS §09 alongside this register before contracting.

PEND · PROCESSING REGISTER · v2.6.0Effective 1 May 2026
pleks

Built from the inside out.
Every feature earned in the field.

Checking status…
  • Why Pleks
  • The work
  • Charter
  • Pricing
  • Founding agents
  • Contact
  • Cookie Policy
  • Credit Check Policy
  • Definitions
  • PAIA Manual
  • POPIA Register
  • Privacy Policy
  • Terms of Service
  • hello@pleks.co.za
  • support@pleks.co.za
  • legal@pleks.co.za

© 2026 Pleks (Pty) Ltd. Built in South Africa.

Built by Yoros