Prospect Privacy Notice
PureEnergy Ventures (Pty) Ltd, trading as PureEnergy Systems, is responsible for this processing.
- Registration number:
- 2024/675073/07.
- Business/service address:
184 Upper Buitenkant Street, Oranjezicht, Cape Town, 8001.
This is a correspondence and mail route, not a walk-in office.
- Information Officer:
- Imaad Fakier.
- Privacy contact:
- privacy@pureenergy.systems.
- Telephone:
- +27 72 042 4584.
Information and purpose
For our limited South African consent-request process, we use the minimum professional information needed to assess a relevant business fit and ask once for consent: name, current role and business, a directly published professional email address, the exact source and access date, fit evidence, verification outcome, and consent, response or suppression state. We exclude private consumer, children's and special personal information from this sourcing process.
We assess the legitimate interests, necessity, reasonable expectations and privacy effects of the limited sourcing and fit assessment, with a separate record for each proposed recipient. Public availability and a verified email address do not amount to consent or authorise marketing. We record and accurately identify the precise public-professional source in the consent request. We do not use a generic provider name in place of the known source. The initial route excludes inferred addresses, bulk-list imports and unverified prior-contact histories.
The first and only unsolicited communication is a standalone request for voluntary, specific and informed affirmative consent to email about workflow analysis, workflow automation, operational reporting and related implementation support. Responding is voluntary. Silence is not consent or refusal. We send no reminder and make no automatic transition into marketing. A later marketing communication requires recorded affirmative consent and a separately approved release within its scope.
How processing works
PureEnergy keeps admitted provenance, stop, consent, research and communication-outcome records in its current control system. The consent-request route is currently operated manually. Each proposed message through Google Workspace requires separate review of its source, prior-contact and suppression evidence, legal scope and Founder approval; a record in the control system is not by itself permission to send. Provider state cannot create consent, reverse a stop, grant authority or release capacity.
Hunter is used only within an approved research and verification boundary. For the initial consent-request route, we may submit a directly published professional email address for verification and retain the minimum result and provenance required to evaluate that route. Verification is not proof of consent, lawful sourcing or current employment. Hunter does not send our messages, operate sequences, determine legal eligibility, or override suppression. We do not upload recipient lists or mailbox contents to Hunter for this route.
Google Workspace provides mailbox hosting, storage, transmission, authentication and logging. Separate credentials isolate sending, ordinary metadata/history monitoring, and specifically authorised read-only access to message content where needed to determine the outcome of an exact controlled event. Our software restricts content access to the relevant canonical message/thread and related response or delivery event. Google's read-only OAuth scope is broader than that software restriction; it does not itself limit access to those records. We do not authorise unrestricted mailbox searches, unrelated correspondence reading or reuse of the consumed historical reconciliation exception.
Zoho provides the monitored privacy@pureenergy.systems correspondence route. The Information Officer handles privacy and rights correspondence and reconciles resulting stops into the canonical control system. Newfold is not relied upon for this process. We do not send prospect or mailbox content to an external reasoning/model provider in this initial route.
Provider roles and international processing
Google and Zoho act under the retained Google Cloud Data Processing Addendum and executed Zoho data-processing agreement for the applicable mailbox functions. Hunter's role depends on the function and data: its published terms distinguish instructed processing from independent controller uses, including its profile database and account/usage information. PureEnergy separately remains responsible for its sourcing and use. We assess the applicable contractual, security, incident, subprocessor, retention and deletion terms before enabling a function.
These providers may process information outside South Africa and use subprocessors in other countries. Zoho's retained account-specific representation identifies its United States data centre. Hunter's published subprocessor list includes email-verification infrastructure in France and other processing in countries including the United States. Google and onward subprocessors operate internationally. We do not claim that every component is located in one country or that public contractual text proves account-specific settings.
Our transfer assessment relies on the applicable binding contractual protections and onward-transfer restrictions, supported by the retained provider assessments. Where uncertainty remains about an account-specific fact or the adequacy/application of a safeguard, it is recorded and governed before use; a brand name or a standard agreement alone is not a finding of compliance. Material provider, term, country or data-flow changes cause reassessment and may stop the route. Contact the Information Officer for information about the safeguards applicable to your data.
Retention, replies and stops
We retain active prospect information only while needed for the limited fit assessment, one consent request, an authorised relationship, or a verified rights or incident matter. We review dormant and closed records for minimisation, retaining only the evidence necessary to demonstrate a decision or consent and prevent repeat contact. No universal fixed retention period is claimed. An outstanding complaint or lawful preservation requirement may require relevant evidence to be retained until resolved.
Refusal, objection, withdrawal, unsubscribe and hard-bounce evidence creates a canonical stop. Wrong-person, departure, OOO, ambiguous outcomes and uncertain send state cause a hold and human review. No alternate address or replacement person is automatically contacted. Silence closes the no-response route with a no-repeat hold. A reply is not automatically consent. A minimal stop marker may be retained after other active data is deleted so that a later list cannot cause recontact.
We do not use open or click tracking, behavioural scoring, engagement-triggered branching, reminders or automated marketing decisions in this consent-request process. Manual review and recorded outcomes govern the current route; software does not infer consent.
Your rights
You may ask whether we hold your information and request access, correction or deletion; object to processing; withdraw consent; stop marketing; or complain about our handling of your information. Reply "unsubscribe" to a message or contact privacy@pureenergy.systems to stop marketing free of charge. No account, payment or unrelated information is required to make a stop request. We assist with the applicable objection or correction/deletion form, or a substantially similar accessible request, and retain only the information necessary to handle it and honour the stop.
You may complain to the Information Regulator of South Africa. Current official contact information is available at https://inforegulator.org.za/contact-us/.
