Privacy Policy

Last updated: 3 July 2026

Pulego Technologies (Pty) Ltd (“Pulego”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal information of our customers, users, website visitors, business contacts, partners and other data subjects.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you use our website, communicate with us, use our digital products or services, or access Co-City, Pulego’s citizens and community engagement solution made available through Microsoft Marketplace, including any related web application, mobile application, SaaS service, managed service, API, dashboard, support service, documentation or related offering.

This Privacy Policy must be read together with any applicable service terms, customer agreement, statement of work, end-user licence agreement, Microsoft Marketplace listing, product documentation or support terms that apply to Co-City or any other Pulego service.

Who we are

Pulego Technologies (Pty) Ltd is an Information and Communication Technology company based in South Africa.

Our contact details are:

Pulego Technologies (Pty) Ltd
The Enterprise Building, Mark Shuttleworth Street
The Innovation Hub
Pretoria, 0087
South Africa

Email: info@pulego.co.za
Telephone: 012 844 0753

Scope of this Privacy Policy

This Privacy Policy applies to personal information processed through:

the Pulego website;
Co-City, Pulego’s citizens and community engagement solution made available through Microsoft Marketplace;
Pulego products, platforms, mobile applications, web applications, portals, APIs, dashboards and support services;
any Pulego offer published or made available through Microsoft Marketplace, Microsoft AppSource, Azure Marketplace, Partner Center or related Microsoft channels;
customer onboarding, support, billing, account management and service delivery;
marketing, enquiries, demonstrations, proposals, events and business communications.

Where we provide services to an organisation, that organisation may also have its own privacy notice or internal policies that apply to its users. In such cases, Pulego may process personal information on behalf of that organisation in accordance with the relevant contract and lawful instructions.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Pulego Technologies Pty Ltd, The Enterprise Building, 1 Mark Shuttleworth Street, The Innovation Hub, Pretoria, 0087.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: South Africa
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Pulego Technologies, accessible from https://pulego.co.za
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Personal information we collect

Depending on how you interact with us and which service you use, we may collect the following categories of personal information:

Contact and identity information

This may include your name, surname, job title, organisation, email address, telephone number, country, address, user profile details and related business contact information

Account and authentication information

This may include usernames, account identifiers, authentication status, role or permission details, organisation identifiers, tenant identifiers, subscription identifiers and related access-management information.

We do not require you to disclose your Microsoft password to us. Where Microsoft authentication is used, authentication should take place through Microsoft-approved authentication flows.

Marketplace and transaction information

Where you acquire, trial, access or enquire about Co-City or any other Pulego offer through Microsoft Marketplace or related Microsoft channels, we may receive limited customer, lead, subscription, tenant, offer, transaction or support information from Microsoft. We use this information only for legitimate marketplace-related purposes, including responding to your enquiry, activating or supporting the offer, managing the customer relationship, fulfilling the transaction, providing service communications, and complying with applicable marketplace, contractual and legal obligations.

Service usage and technical information

We may collect technical and usage information such as IP address, device type, browser type, operating system, pages or screens visited, time and date of access, session information, diagnostic data, logs, error reports, performance data, security events, feature usage, configuration data and similar information required to operate, secure and improve our services.

Support and communication information

When you contact us for support or communicate with us, we may collect information such as your message content, support request details, attachments you provide, call or meeting details, issue descriptions, screenshots, diagnostic information and correspondence history.

Customer content

Some Pulego services, including Co-City, may allow customers or users to submit, upload, process, store or transmit content. This may include documents, reports, form submissions, messages, images, files, operational records, case information, service records, incident reports, citizen engagement records, feedback submissions or other information provided by the customer or user.

We process customer content only for the purposes of providing, securing, supporting and improving the relevant service, or as otherwise instructed by the customer or required by law.

Cookies and analytics information

Our website and certain services may use cookies, pixels, tags, scripts, analytics tools and similar technologies to operate the service, remember preferences, improve user experience, monitor performance, understand usage trends, secure the service and measure the effectiveness of communications.

You may configure your browser to refuse or delete cookies. Some features may not function properly if necessary cookies are disabled.

How we collect personal information

We may collect personal information:

directly from you when you complete a form, create an account, request support, use a service, contact us or submit information;
from your employer, organisation, administrator or authorised representative;
from Microsoft Marketplace, Microsoft Partner Center or related Microsoft services where you engage with Co-City or any other Pulego offer;
automatically when you use our website, applications, platforms or services;
from service providers, business partners or integration systems where this is necessary for service delivery;
from publicly available sources, where lawful and relevant.

Why we process personal information

We process personal information for the following purposes:

to provide, operate, host, maintain and support our services;
to provide, operate, configure, secure and support Co-City;
to create, manage and authenticate user accounts;
to activate, configure and administer subscriptions, trials or service access;
to respond to enquiries, support requests, demonstrations and customer communications;
to provide service notifications, security updates, operational alerts and administrative messages;
to monitor service performance, availability, reliability and security;
to detect, prevent and investigate fraud, misuse, unauthorised access, cyber incidents or technical issues;
to improve our website, products, services, documentation and user experience;
to manage customer, supplier, partner and business relationships;
to process transactions, invoices, orders and related administrative records;
to comply with Microsoft Marketplace requirements and related certification, listing, support and transaction obligations;
to comply with applicable laws, regulations, court orders and lawful requests;
to enforce our agreements, terms, policies and legal rights;
to send marketing communications where permitted by law or where you have consented, with the ability to opt out.

Legal basis for processing

We process personal information where we have a lawful basis to do so, including where:

processing is necessary to perform a contract with you or your organisation;
processing is necessary to take steps at your request before entering into a contract;
you have given consent;
processing is required by law;
processing is necessary to protect legitimate interests, including service security, fraud prevention, customer support, business administration, service improvement and legal protection;
processing is necessary to protect the rights, safety or interests of users, customers, Pulego or third parties.

Where consent is required, you may withdraw consent at any time, subject to any lawful basis that may allow or require us to continue processing certain information.

Microsoft Marketplace customer information

If Microsoft provides us with customer contact information, lead information or transaction-related personal information in connection with Co-City or any other Pulego offer on Microsoft Marketplace, we will use that information only for legitimate transactional, operational, support, service activation, customer management or enquiry-response purposes related to the relevant Marketplace offer.

We will not use Microsoft-provided customer contact information to direct customers to purchase the same offer on competing marketplaces. We will obtain appropriate consent or rely on another lawful basis before using such information for marketing or other unrelated purposes.

How we share personal information

We do not sell personal information.

We may share personal information only where necessary and lawful, including with:

Microsoft, where required for Microsoft Marketplace, Partner Center, Azure, AppSource, certification, transaction, lead management, support or related service purposes;
cloud hosting providers, infrastructure providers and technology service providers;
payment, billing, accounting and administration service providers;
customer relationship management, analytics, communications and support platforms;
professional advisers, auditors, insurers and legal representatives;
subcontractors or service providers who assist us in delivering services;
customers or administrators where the user belongs to a customer organisation and the disclosure is required for service administration;
regulators, courts, law enforcement agencies or other authorities where required by law;
third parties involved in a merger, restructuring, acquisition or sale of all or part of our business, subject to appropriate confidentiality and legal safeguards.

Where we appoint service providers to process personal information on our behalf, we require them to protect personal information and process it only for authorised purposes.

Storage and retention of personal information

We retain personal information only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law, contract, audit requirements, dispute resolution, security, tax, accounting or legitimate business needs.

Retention periods may differ depending on the type of information and the relevant service. For example:

account and service information may be retained while the account, subscription or customer relationship remains active;
support records may be retained for service quality, audit and dispute-resolution purposes;
transaction and financial records may be retained as required by applicable law;
security logs and diagnostic records may be retained for a reasonable period to protect systems, investigate incidents and maintain service integrity;
customer content may be retained or deleted in accordance with the relevant customer agreement, service configuration, retention settings or lawful instructions.

When personal information is no longer required, we will delete, anonymise, de-identify or securely retain it where required by law.

Security safeguards

We use reasonable technical, organisational and administrative safeguards to protect personal information against loss, unauthorised access, misuse, disclosure, alteration and destruction.

These safeguards may include, where appropriate:

secure hosting and network controls;
access controls and role-based permissions;
encryption in transit and, where applicable, encryption at rest;
multi-factor authentication for administrative access;
logging, monitoring and audit trails;
backup and recovery controls;
vulnerability management and security reviews;
staff confidentiality obligations and awareness measures;
supplier and subcontractor controls;
incident response procedures.

No method of transmission or electronic storage is completely secure. We therefore cannot guarantee absolute security, but we take reasonable steps to protect personal information in accordance with applicable legal, contractual and security requirements.

International transfers

Pulego is based in South Africa, but some of our technology providers, cloud platforms, support systems, customers or partners may process or store information in other countries.

Where personal information is transferred outside South Africa or outside the country where it was collected, we will take reasonable steps to ensure that appropriate safeguards are in place, including contractual protections, security measures and compliance with applicable data protection laws.

Customer content and customer-controlled data

Where Pulego processes personal information on behalf of a customer, the customer may be the responsible party, controller or equivalent legal decision-maker for that information. Pulego will process such information in accordance with the customer’s lawful instructions, the applicable contract and relevant data protection requirements.

Customers are responsible for ensuring that they have the necessary authority, notices, consents and lawful basis to provide personal information to Pulego for processing through our services, including through Co-City.

AI, analytics and automated processing

Some Pulego services may use analytics, automation, reporting, artificial intelligence or machine-learning features to improve service delivery, summarise information, classify requests, identify trends, support decision-making, detect security issues or improve user experience.

Where such features are used, we will process personal information lawfully and in accordance with the relevant service description, customer agreement and applicable law. We will not use automated processing to make decisions that have a legal or similarly significant effect on individuals unless this is clearly disclosed, lawfully permitted and subject to appropriate safeguards.

Direct marketing

We may send marketing communications about Pulego services, events, updates or related offerings where permitted by law or where you have consented.

You may opt out of marketing communications at any time by using the unsubscribe option in the communication or by contacting us at info@pulego.co.za.

We may still send non-marketing communications, such as service notices, security alerts, support responses, transaction confirmations or administrative messages.

Your privacy rights

Subject to applicable law, you may have the right to:

be informed about how your personal information is collected and used;
request access to personal information we hold about you;
request correction or update of inaccurate, incomplete or outdated personal information;
request deletion or destruction of personal information where legally permitted;
object to certain processing of your personal information;
withdraw consent where processing is based on consent;
object to direct marketing;
request restriction of processing in certain circumstances;
lodge a complaint with a regulator or supervisory authority.

To exercise your rights, please contact us at info@pulego.co.za. We may need to verify your identity before responding to a request.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our business services and Microsoft Marketplace offers are generally intended for organisations and adult users. We do not knowingly collect personal information from children without appropriate authority, consent or lawful basis.

If we become aware that we have collected personal information from a child without the required authority, we will take reasonable steps to delete or appropriately restrict that information.

Third-party links and services

Our website, products or Marketplace listings may contain links to third-party websites, platforms, integrations or services. We are not responsible for the privacy practices, security or content of third-party services that we do not control.

You should review the privacy notices and terms of any third-party services you use.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, Microsoft Marketplace requirements, security practices or business operations.

When we update this Privacy Policy, we will change the “Last updated” date above. Where required, we may provide additional notice through our website, service interface, email or other appropriate communication channels.

Contact Us

If you have any questions, requests or complaints about this Privacy Policy or how we process personal information, please contact us:

Pulego Technologies (Pty) Ltd
The Enterprise Building, Mark Shuttleworth Street
The Innovation Hub
Pretoria, 0087
South Africa

Email: info@pulego.co.za
Telephone: 012 844 0753