Privacy Policy

Avnon Pte Ltd ("Avnon", "we", "our") takes the protection of personal information seriously. This policy describes how we collect, store, use, process, and protect information that can be associated with you or another identifiable person ("personal information") when you use the Mothusi platform and related services.

In this policy, "platform" refers to the Mothusi AI-powered business partner platform and associated services. "Websites" refers to mothusi.ai, incubatorportal.com, avnon.co, avnon.io, and any customer subdomains.

1. Information We Collect

General contact information

When you register on the platform or submit a request via a contact form, we collect your name and contact details (such as email address and telephone number).

Personal information (individuals)

Name, address, contact details, date of birth, identity number, designation, education and employment history, salary data, and where provided, special personal information including race, gender, and national, ethnic, or social origin.

Personal information (juristic persons)

Company name, address, contact details, registration details, financials, B-BBEE scorecard, description of operations, bank details, employee details, tax and VAT numbers, team members, financial data, and development plans.

Navigational information

IP address, browser type, geographical location, visit duration, and pages visited.

Device information

Hardware and software versions, operating system, browser type, and plug-ins of devices used to access the platform.

Mentoring and coaching session data

When you participate in AI-assisted mentoring, coaching, or diagnostic sessions through Mothusi, the content of those sessions is recorded. This includes discussion notes, diagnostic responses, business health data, action items, and session summaries. Session records are used to provide continuity between sessions and to generate reports, scorecards, and growth plans.

Files and documents

Files, logos, trademarks, information, and data uploaded by you remain your property. You grant Avnon the right to use this data solely for the purposes of providing the service.

2. How We Use Your Information

We use the information collected to:

• provide, operate, and improve the Mothusi platform and related services;
• deliver AI-assisted mentoring, coaching, diagnostic, and business support services;
• generate scorecards, health scores, growth plans, business reports, and other outputs based on your business data;
• identify opportunities, tenders, and connections relevant to your business profile;
• generate documents on your behalf, including business plans, proposals, tender responses, and financial projections;
• provide programme administrators (such as RBED) with reports, analytics, and oversight of programme member progress, in accordance with the terms of the applicable programme;
• send you communications related to the service, including session summaries and opportunity notifications;
• monitor and improve the quality, accuracy, and relevance of AI-generated outputs; and
• comply with legal obligations.

We process your personal information on one or more of the following legal bases: (a) your consent, given at registration and renewed through session-level confirmation; (b) the performance of the service you have requested; (c) compliance with a legal obligation; and (d) the legitimate interests of the programme in which you participate, where applicable.

3. AI-Assisted Processing

The Mothusi platform uses artificial intelligence to deliver its core services, including mentoring, coaching, diagnostics, document generation, compliance monitoring, and business reporting. This section explains how AI processing works and how your data is protected.

How it works: When you interact with Mothusi, your input is processed by third-party AI models to generate responses, recommendations, documents, and other outputs. The platform sends only the data necessary for the specific interaction to the AI model, which processes the request and returns a response.

Stateless processing: The third-party AI models used by the platform are stateless. This means they do not retain any data beyond the duration of a single request. Once a response is generated, the AI model retains nothing. No conversation history, business data, or personal information is stored by the AI provider.

Where your data is stored: All conversation history, session records, diagnostic data, business information, memory, and transcripts are stored and managed exclusively on the Mothusi platform infrastructure, hosted on Microsoft Azure servers located in Johannesburg, South Africa. Your data does not leave South Africa for storage purposes.

No training on your data: Your data is not used to train, fine-tune, or improve any third-party AI model. The AI providers do not use any data submitted through the Mothusi platform for model training or development purposes. Your information is used solely to generate a response to your specific request and is not retained by the provider thereafter.

Cross-border data transmission: During processing, data is transmitted to third-party AI service providers whose processing infrastructure may be located outside South Africa. This transmission is transient and stateless: the data is sent, processed, and the response returned within a single request. No personal information is stored outside South Africa. All persistent data storage remains on Microsoft Azure infrastructure in Johannesburg, South Africa, as described above.

4. Third-Party Service Providers

The platform uses the following categories of third-party service providers to deliver its services:

• AI language models - for conversational interactions, report generation, document creation, and business analysis;
• AI vision models - for reading and analysing uploaded documents;
• Image generation services - for creating logos, brand graphics, and visual materials;
• Cloud infrastructure - for hosting and data storage (Microsoft Azure, Johannesburg, South Africa);
• Calendar services - for integration with Microsoft Calendar and Google Calendar (where you have connected your calendar); and
• Payment processing - for subscription and transaction management.

In all cases, third-party service providers process data only as necessary to perform the specific function requested and are contractually or architecturally prevented from using your data for their own purposes. AI language and vision models operate on a stateless basis as described in Section 3.

5. Sharing of Information

We do not sell your personal information to any third party.

We may share your information in the following limited circumstances:

• Programme administrators: If you are a member of a programme or network operated through the platform (such as RBED), your programme or network administrator will have access to your session records, diagnostic data, scorecards, growth plans, and related programme information. This is necessary for programme and network oversight and support delivery. At the start of each mentoring session, Mothusi will confirm that session records are shared with your programme or network administrator.
• Third-party service providers: As described in Section 4, we use service providers to operate the platform. These providers process data only to perform their specific function and do not retain your data beyond the immediate processing request.
• Legal requirements: We may disclose information if required by law, legal process, or to protect our rights or the safety of our users.

6. Data Location and Security

Location: All platform data, including personal information, business data, session records, and files, is hosted on Microsoft Azure infrastructure located in Johannesburg, South Africa.

Security measures: We implement appropriate technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure, or destruction. These include encryption in transit and at rest, access controls, and regular security assessments.

Access controls: Access to your data within the platform is restricted to you, authorised programme administrators (where applicable), and authorised Avnon personnel for support and maintenance purposes.

7. Your Rights

Depending on your jurisdiction, you may have the following rights in relation to your personal information:

• The right to access the personal information we hold about you;
• The right to request correction of inaccurate or incomplete information;
• The right to request deletion of your personal information, subject to legal retention requirements;
• The right to object to or restrict processing of your personal information;
• The right to request a copy of your personal information in a portable format; and
• The right to withdraw consent to processing, where processing is based on consent.

To exercise any of these rights, please contact us at info@avnon.co.

8. Protection of Personal Information Act (South Africa)

Where the platform is used to process the personal information of data subjects located in South Africa, we comply with the Protection of Personal Information Act, 2013 (POPIA). In particular:

• We process personal information lawfully, in a manner that does not infringe the privacy of the data subject, and only for the purpose for which it was collected;
• Personal information is stored on infrastructure located in South Africa (Microsoft Azure, Johannesburg);
• We take reasonable technical and organisational measures to secure the integrity and confidentiality of personal information;
• Third-party AI providers process data on a stateless basis and do not retain personal information beyond the immediate processing request;
• Data subjects may lodge a complaint with the Information Regulator (South Africa) if they believe their personal information has been processed in a manner that does not comply with POPIA. Contact details for the Information Regulator and the designated Information Officer are provided in Section 16.

9. Data Ownership

All files, logos, trademarks, information, and data uploaded by you or generated on your behalf remain your property. You grant Avnon the right to use your data solely for the purposes of providing the service under these terms.

You may request export or deletion of your data at any time by contacting us at info@avnon.co.

10. Integration with Third-Party Calendars

The platform allows you to connect your Microsoft Calendar and/or Google Calendar. Once connected, we access your calendar entries to check for scheduling conflicts and add new entries for events you are scheduled to attend. We do not access or store calendar data beyond what is necessary for this function.

11. Data Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. When personal information is no longer required, it will be securely deleted or anonymised.

If you are a member of a programme, your data may be retained for the duration of the programme and any applicable reporting period thereafter, in accordance with the terms agreed between Avnon and the programme operator.

12. Data Breach Notification

In the event of a security breach that compromises the confidentiality, integrity, or availability of your personal information, we will:

• take immediate steps to identify and contain the breach;
• notify the Information Regulator (South Africa) as soon as reasonably possible after becoming aware of the breach, where required under Section 22 of POPIA;
• notify affected data subjects as soon as reasonably possible, providing details of the breach, the categories of information affected, and the steps being taken to address it; and
• take appropriate measures to prevent a recurrence.

13. Cookies

The platform uses cookies and similar technologies to support functionality, analyse usage, and improve your experience. Cookies may collect navigational and device information as described in Section 1. You may manage your cookie preferences through your browser settings. For full details, refer to our cookie notice on the platform.

14. Children

The platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify you via the platform or by email. Your continued use of the platform after any changes constitutes acceptance of the updated policy.

16. Information Officer

In accordance with POPIA, the following person has been designated as the Information Officer responsible for ensuring compliance with data protection requirements and handling data subject requests:

Information Officer: Daniel Avnon
Email: privacy@mothusi.ai

If you wish to exercise any of your rights under this policy, lodge a complaint, or raise a concern about how your personal information is being processed, please contact the Information Officer using the details above.

If you are not satisfied with the response from the Information Officer, you may lodge a complaint with the Information Regulator (South Africa):

• Website: https://inforegulator.org.za
• Email: enquiries@inforegulator.org.za

17. Contact Us

For general enquiries about this Privacy Policy, please contact us at info@avnon.co.