1. Who We Are
Emergen24 (Pty) Ltd ("Emergen24", "we", "us", or "our") operates an emergency response platform and mental health companion service accessible via WhatsApp and our web applications at emergen24.co.za, admin.emergen24.co.za, and luna.emergen24.co.za.
Registered Address:
Emergen24 (Pty) Ltd
37 Magwa Crescent, Waterfall City, Midrand
Gauteng, 2090, South Africa
Information Officer:
Email: privacy@emergen24.co.za
Phone: +27 64 611 5037
This Privacy Policy applies to all users of our services including emergency users, Luna users, registered responders, company administrators, and website visitors.
2. Our Commitment to Your Privacy
We are committed to complying with the Protection of Personal Information Act 4 of 2013 (POPIA), the Electronic Communications and Transactions Act 25 of 2002 (ECTA), and all applicable South African law. We process personal information only because doing so is necessary to operate a life-saving emergency response service.
3. Information We Collect
3.1 Emergency Users (WhatsApp)
When you contact us in an emergency, we collect: your WhatsApp phone number (your primary identifier), your name, your location (GPS coordinates or text address), medical information you voluntarily provide, your emergency contact's name and phone number, your preferred language, all WhatsApp messages and voice notes exchanged with our service, and session activity timestamps.
3.2 Luna Users
In addition to the above: full session content including emotional disclosures and mental health information, mood ratings you provide, automated emotion classification on your messages (using our AI classifier), session history, subscription and billing records (processed by Paystack), and web session data on luna.emergen24.co.za.
3.3 Responders
Name, phone number, specialisation, company affiliation, home base location, real-time GPS location during active emergencies, and performance data (response times, acceptance rates, ratings).
3.4 Company Administrators
Account information, company registration details, dashboard activity (fully audit-logged), and subscription and billing information.
3.5 Automatically Collected
IP addresses, browser and device type, pages visited, referring URLs, cookies, and session identifiers.
4. How We Use Your Information
| Purpose | Lawful Basis |
|---|---|
| Dispatching emergency responders to your location | Vital interest â necessary to protect life |
| Providing AI first-aid guidance during emergencies | Vital interest â necessary to protect life |
| Operating the Luna mental health companion service | Consent and/or contractual necessity |
| Notifying your emergency contact when you go silent | Vital interest and legitimate interest |
| Verifying your identity via WhatsApp OTP | Contractual necessity |
| Processing subscription payments via Paystack | Contractual necessity |
| Improving our AI models and platform safety | Legitimate interest |
| Generating anonymised incident reports | Legitimate interest |
| Detecting and preventing fraud and abuse | Legitimate interest and legal obligation |
| Complying with legal obligations | Legal obligation |
We will never sell your data to third parties, use it for targeted advertising, or profile you for commercial marketing without explicit consent.
6. Special Categories
âšī¸ Protected Information
Health and medical information, mental health information (Luna conversations), and location data receive heightened protection. Luna session content is never shared with employers, insurers, or other third parties without explicit consent. It is never used to make automated decisions affecting your rights.
7. Data Security
We implement: TLS 1.2+ encryption in transit, encryption at rest for all sensitive Firestore and Storage data, role-based access controls, full audit logging of all administrative access, and breach notification procedures compliant with POPIA.
8. Your Rights Under POPIA
âšī¸ Your Data Subject Rights
You have the right to: access your personal information, request correction or deletion, object to processing, withdraw consent, and lodge a complaint with the Information Regulator.
Information Regulator: inforeg@justice.gov.za | www.inforegulator.org.za | JD House, 27 Stiemens Street, Braamfontein, Johannesburg.
To exercise your rights: privacy@emergen24.co.za. We respond within 30 days.
9. Data Retention
| Data Category | Retention Period | Reason |
|---|---|---|
| Emergency records (messages, location, AI guidance) | 7 years | Legal and insurance purposes |
| Incident reports | 7 years | Legal/regulatory compliance |
| Luna session content and transcripts | 3 years from last session | Service continuity and safety review |
| Responder performance records | 5 years after deregistration | Legal claims period |
| Billing and payment records | 5 years | Tax and financial compliance |
| Audit logs | 3 years | Security and compliance |
| User onboarding data | 2 years of inactivity | Service provision |
| OTP codes | 10 minutes | Security |
11. Children's Privacy
Our services are not directed to children under 18. In emergency situations involving a minor, a parent or guardian should initiate contact. Contact privacy@emergen24.co.za if a minor has registered without parental knowledge.
12. Luna â Additional Privacy
â ī¸ IMPORTANT DISCLAIMER
Luna conversations do not constitute clinical health records. Luna is not bound by therapist-client confidentiality. If Luna detects imminent risk to life (suicidal ideation, self-harm), your session may be reviewed by our safety team. In extreme circumstances, information may be shared with emergency services where we reasonably believe there is an imminent risk to your or another person's life.
Emotion classification is used only to improve Luna's in-session responses and flag high-severity sessions for safety review. It is never used to make automated decisions affecting your rights.
13. Changes to This Policy
We will notify you via WhatsApp or in-app notice for material changes, with at least 14 days' notice before they take effect.
14. Contact
Information Officer, Emergen24 (Pty) Ltd
Email: privacy@emergen24.co.za
WhatsApp: +27 64 611 5037
Contact Us
For any questions about this policy, please contact our Information Officer:
Email: privacy@emergen24.co.za
WhatsApp: +27 64 611 5037
Registered Address:
Emergen24 (Pty) Ltd
37 Magwa Crescent, Waterfall City
Midrand, Gauteng, 2090
South Africa