Privacy Policy

APC App

Effective Date: September 2026

This Privacy Policy explains what the APC clinical guide app (the “App”) records, why it records it, and what you can do about it. It applies wherever in the world you use the App, whether you use it through a web browser or install it on your device, and whether you use it online or offline.

1. Responsible party and contact details

1.1 The App is provided by Knowledge Translation Foundation NPC (“KTF”), registration number 2024/333268/08, a non-profit company incorporated in South Africa. KTF is the responsible party for the processing described in this Privacy Policy, and “we”, “our” and “us” mean KTF.

1.2 Our Information Officer is Faye Eshraghi, who is registered with the Information Regulator of South Africa. You can reach us at info@knowledgetranslation.co.za or SG109 Great Westerford, 240 Main Road, Rondebosch, Cape Town, 7700.

2. Personal Information we process and the purposes of processing

2.1 “Personal Information” means information relating to an identifiable, living natural person, as defined in POPIA. The App processes the following Personal Information, and nothing else:

2.1.1 The country and region you choose when you set up the App, so that we deliver the right version of the guide and can report on where it is being used, and, if you choose “Other”, the country and region names you type in yourself (up to 64 characters each). Please do not type a person’s name, a facility name or any other identifying detail into those fields;

2.1.2 A code that the App assigns to your device, so that we can count unique devices and measure use over time. The App generates this code, and it stays on your device between sessions. It is not your name, and it is not your device’s own identifier, but because it persists, we treat it as Personal Information;

2.1.3 Which pages you open, how long you spend on them and the order you view them in, including the time you start and stop reading a page, which guide you are reading and its title, so that we can keep the guide accurate, fix problems and target training;

2.1.4 The internet address (IP address) and browser or device type that our servers record automatically whenever your device connects to us, so that we can deliver the App and keep it secure. We use the full address only while handling your request and keep a shortened version of it in our server logs;

2.1.5 Whether you are using the App as an installed application or in a browser tab, so that we can support both and measure how the App is used; and

2.1.6 A session identifier and the time our server last received data for that visit, which we use to group a single visit together and to investigate technical faults.

2.2 We record this because it is necessary to provide the App to you, and because we have a legitimate interest in understanding and improving how the guide is used. If we ever want to use it for something materially different, we will ask you first.

2.3 The App does not record your name, contact details, identity number, employer or any patient information. We do not sell information, we do not advertise in the App, and we do not build profiles of individual users.

2.4 If you email us, we keep that correspondence, which will include your email address.

3. Content updates and communications

3.1 The App downloads updates to the clinical content and health alerts, such as disease-outbreak notifications, when it connects to the internet. We also publish announcements in the App, for example to tell you about a correction or an update to the Content. Announcements are displayed when you next open the App. It does not send push notifications, and communication through the App is one way: you cannot reply to us through the App and you cannot message other users through it. Announcements are shown to all users of an edition or region and are not selected for you personally, so we do not use your Personal Information to decide what you are shown. We can only reply to you personally if you have emailed us first.

4. Recipients of Personal Information

4.1 Our hosting and technical service providers, who process the information only on our instructions and under a written agreement requiring them to keep it secure.

4.2 Health departments, ministries, universities and funders in the countries where the App is used, in the form of reports on how the guide is being used. These reports contain grouped figures only. They do not identify any user, and we leave out figures where the numbers are small enough that a user could be identified.

4.3 A regulator, court or other authority, where the law requires it, and where we need to protect the rights or safety of our users or ourselves.

5. Storage location and use of the App outside South Africa

5.1 The information is stored on servers in South Africa (Microsoft Azure, South Africa region) and on your own device, where the App keeps content for offline use.

5.2 Apart from our hosting provider, no third party processes this information for us. The App does not use advertising, analytics or push notification services, and we do not transfer the information outside South Africa.

5.3 KTF is based in South Africa, so we handle your information under the Protection of Personal Information Act 4 of 2013 (“POPIA”) wherever in the world you use the App. If you use the App from another country, the information described in clause 2.1 is sent to and stored in South Africa. Your local data protection law may also give you rights, and we will deal with your request under that law where it applies to us.

6. Retention

6.1 We keep the information described in clause 2.1 for as long as you use the App and for as long as we need it for the purposes in clause 2. We delete user usage records upon request of the user. Our server logs are kept for no longer than 30 days.

7. Security and notification of a compromise

7.1 We take appropriate, reasonable technical and organisational measures to protect the information, including the information the App stores on your device. No system is completely secure.

7.2 If we have reasonable grounds to believe that information has been accessed or acquired by someone who should not have it, we will notify the Information Regulator and affected users as soon as reasonably possible, as required by section 22 of POPIA.

8. Your rights as a data subject

8.1 You can ask what we hold about you, ask us to correct or delete it, object to our processing, and complain to the Information Regulator. You can also clear the App’s data or uninstall the App, which removes everything stored on your device.

8.2 Because the App does not record your name or contact details, we usually cannot link stored information to a particular person, and POPIA does not require us to collect more information in order to do so. If you want us to delete the records held on our servers, contact us using the details in clause 1.2. Those records are linked only to the code the App assigns to your device, and you can find that code in the App under Privacy notice, where there is a button to copy it. We can delete the records once you give us that code. Reports we have already produced and shared contain grouped figures only, do not identify you, and cannot be recalled.

8.3 Objecting is free and you can do it by any means convenient to you, including email. A request for access is handled under the Promotion of Access to Information Act 2 of 2000 and our PAIA manual, which is available on request.

8.4 You can complain to the Information Regulator (South Africa) at POPIAComplaints@inforegulator.org.za or through https://inforegulator.org.za. A complaint must be made on the form the Regulator prescribes.

9. Children

9.1 The App is intended for health workers and other adults. We do not knowingly record information about children. If you believe we have, contact us and we will delete it.

10. Amendments to this Privacy Policy

10.1 We may update this Privacy Policy. We will post the updated version with the date on which it was last updated, and where a change is material, we will bring it to your attention in the App.