Who we are
Keepbrook helps South African funeral insurers reach policyholders whose debit order has failed, so the premium is paid before the policy lapses. Keepbrook is a product of Infini Colon (Pty) Ltd, registration number 2026/192440/07. In this policy “Keepbrook”, “we” and “us” mean Infini Colon (Pty) Ltd, of Johannesburg, South Africa. This policy explains how we handle personal information under the Protection of Personal Information Act, 2013 (POPIA).
Information Officer: Panky Mbhalati, keepbrook@infinicolon.co.za, 082 899 6575.
Information Regulator (South Africa): Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191. Phone 010 023 5200. General enquiries enquiries@inforegulator.org.za; POPIA complaints POPIAComplaints@inforegulator.org.za. Website inforegulator.org.za.
Two roles
Operator for the insurer. When we contact policyholders about a failed premium, the insurer is the responsible party. We process policyholder information only on the insurer’s written instructions, under an operator agreement (POPIA sections 20 and 21), and for no other purpose.
Responsible party for our own users. For visitors to this website, people who contact us, and the insurer staff who use the Keepbrook app, we decide why and how information is used, and this policy is our notice to you.
What we process about policyholders
- Name and policy number.
- Mobile number.
- Premium amount, the date the debit order failed and the reason the bank gave.
- Preferred language.
- Replies the policyholder sends us.
- The payment outcome (paid, promised, not paid).
We never ask for or store ID numbers, bank account numbers or card numbers. Money never passes through Keepbrook: payments go straight to the insurer’s own account through the payment provider the insurer chose.
Why, and on what legal basis
- The insurer’s duty to notify. When a premium is not received, the Policyholder Protection Rules (Rule 15A) require the insurer to tell the policyholder within the grace period. We help the insurer do that.
- The insurer’s legitimate interest in keeping cover in force that the policyholder wants to keep, and in collecting premiums that are due (POPIA section 11(1)(f)).
- Calls. If voice calls are enabled, every call starts with a notice that it is recorded, in line with the Regulation of Interception of Communications and Provision of Communication-Related Information Act (RICA).
How we contact policyholders
- WhatsApp first, using message templates the insurer has approved word for word.
- Voice calls only if the insurer has enabled them.
- Monday to Friday 08:00 to 20:00, Saturday 09:00 to 13:00. Never on Sundays or public holidays.
- Reply STOP at any time and we stop contacting you about that policy, and tell the insurer.
Automated decisions
Our software chooses which pre-approved script to send next, for example a reminder or an answer to “which policy is this?”. It never writes messages of its own. Nothing about the policy itself (cover, claims, lapse, reinstatement) is decided by Keepbrook: those decisions stay with the insurer, and anything unusual goes to the insurer’s staff.
Who we share with
| Recipient | What it is | Why |
|---|---|---|
| The insurer | The policyholder’s insurer (or its administrator) | It is the responsible party: it sends us the failed collections and receives every outcome. |
| Meta (WhatsApp) | WhatsApp Business Platform | To deliver the insurer’s approved WhatsApp messages and receive replies. |
| Payment provider | Chosen by the insurer (for example Stitch, PayFast or Ozow) | To take the payment into the insurer’s own account. Keepbrook never receives the money or card details. |
| Supabase | Database hosting, Frankfurt (EU) | Stores case records, encrypted at rest and in transit. |
| Anthropic | AI model provider | Helps read a policyholder’s reply so the right pre-approved script is chosen. Information is not used to train its models. |
| Voice provider | Only if the insurer enables voice | Places the backup call and plays the recording notice. |
| SMS provider | Only if the insurer enables it | Sends the follow-up SMS. |
| Cash payment provider | Only if the insurer enables it | Issues the till reference and confirms the payment. |
| Debit order provider | Only if the insurer enables it | Sets up or corrects the debit order the policyholder approves. |
We never sell personal information, and we never use policyholder information for marketing.
Transfers outside South Africa
Our database is hosted in the European Union (Frankfurt), and some of the providers above process information in other countries. We only transfer personal information outside South Africa as POPIA section 72 allows: to recipients bound by written data processing agreements that give protection substantially similar to POPIA, and, for policyholders, as the insurer has instructed.
Security
Information is encrypted in transit and at rest. Access is limited to the people who need it, uses individual accounts, and is logged. Each insurer’s information is kept separate from every other insurer’s. If we suspect a security compromise, we tell the insurer without delay so that it can notify the Information Regulator and the people affected, as POPIA section 22 requires.
How long we keep it
We keep policyholder information as the insurer instructs, and no longer than five years after the case is closed. Then we delete it or make it anonymous. Website enquiries are kept only for as long as we need them to reply and follow up.
Your rights
You may ask whether we hold information about you and ask for a copy; ask us to correct or delete it; and object to its processing. If you are a policyholder, we will pass your request to your insurer, which is responsible for your information, and help it respond. You may complain to the Information Regulator at any time (details above).
Website visitors and insurer users
- Forms on this website: your name, role, company, work email and the details you type. We use them only to reply to you and to discuss Keepbrook with you.
- Analytics: this website does not use an analytics tool and sets no cookies. See our cookie policy.
- Insurer staff using the Keepbrook app: name, work email and a record of what you do in the app, to give you access and keep an audit trail for the insurer.
- Our hosting provider keeps standard server logs for security.
Changes to this policy
We will update this page when our practices change, and change the date at the top. If a change affects how we process policyholder information, we will tell the insurers we work for first.
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