Privacy notice

1. Who we are and what this notice covers

FIFO Law gives conveyancing firms property cost calculators in their own brand: a web app, and apps for Android phones, iPhones and iPads. A firm can also let its clients apply online for some of its services, and publish a library of documents.

FIFO Law is made and run by FIFO Solutions (Pty) Ltd ("FIFO", "we", "us"), Registration No. 2026/071559/07, 25 Bethel Gardens, 22 Church St, Durbanville, Western Cape, 7550.

This notice explains what personal information FIFO Law handles, who is responsible for it, where it is kept and for how long, and your rights under the Protection of Personal Information Act, 2013 (POPIA). It covers:

• people who use a firm's calculators (section 3);
• people who apply online to a firm (section 4);
• firms that subscribe, and their staff (section 5);
• the document library and app notifications (section 6);
• visitors to this website (section 7).

Our Information Officer is Riaan Potas (riaan@fifo.systems, 082 525 4011).

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2. Two roles: the firm's applications and our own records

POPIA gives FIFO two different roles, depending on whose information it is.

2.1 Online applications: the firm is in charge

When you apply online to a firm, for example for an antenuptial contract, a will or bridging finance, you send your details to that firm. The firm is the responsible party: it decides why and how your details are used, and it is the one you deal with.

FIFO is the firm's operator (POPIA sections 20 and 21). We run the application form and keep what you send for the firm, under a written agreement: the operator terms in the schedule to our terms of service. We don't use your details for any purpose of our own, we don't sell them, and we don't market to you.

The form shows the firm's own privacy notice before you send anything. It names the firm and tells you how to contact it.

2.2 Everything else: FIFO is in charge

FIFO is the responsible party for:

• the details of firms that subscribe, and their billing;
• the sign-in accounts of firms' staff on the firm dashboard;
• the technical and security records of the service;
• this website, and the visit records of our "see it" page;
• messages you send us.

2.3 What this means for you

If you applied to a firm, contact that firm about your details. You may also contact us. We'll pass your request to the firm and help it respond (section 11).

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3. The calculators and cost estimates

3.1 Your figures stay with you

The calculators work out the figures on your phone or in your browser. The prices, amounts and other answers you type are not sent to FIFO or to the firm, and we don't save them.

A cost estimate PDF is made on your device. It goes only where you choose to save or send it, through the app you pick, such as WhatsApp or email. That app's own terms apply.

3.2 What our servers see

To show a firm's calculators, your browser or app fetches the firm's branding, content and current rates from our servers. Like any website, those servers record technical details: your IP address, your browser or app type, the page address and the time. Some links fill in a price for you; if you open one, that amount is part of the page address. We use these records only to run the service and protect it from abuse, not to identify you.

In the apps, the calculators and PDFs work without a connection. When the app has a connection, it checks for updated content and rates as it opens.

3.3 Services your device contacts directly

• Maps. The firm's contact page shows a map from OpenStreetMap. Your device fetches the map pictures straight from OpenStreetMap's servers, which see your IP address. The OpenStreetMap Foundation's privacy policy applies. If you tap for directions, your maps app opens under its own terms.
• The web app's graphics engine. In a browser, the web app fetches its graphics engine, some fonts and a Google sign-in component from Google's servers. The calculators don't sign anyone in.
• App notifications. Each copy of the app registers with Google's Firebase Cloud Messaging (section 6.2).

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4. Online applications

This part is for you if you applied online to a firm.

4.1 What an online application is

A firm can offer some of its services through an application form in its app or on its website. Today these are an antenuptial contract (ANC), a will, and bridging finance (an advance on the proceeds of a property sale, or on an estate agent's commission, before registration).

An application asks the firm to contact you. It isn't a contract, and you don't sign anything in it. The firm calls you, takes your instruction and collects whatever is still missing. An antenuptial contract is signed on paper before a notary, and a will is signed on paper before witnesses.

Your application goes only to the firm whose app or website you used. FIFO doesn't pass it to any other firm or person.

4.2 What you give

Some of these answers are about other people: your partner, your children, your heirs, guardians and executor. Please tell them that you are giving their details to the firm.

4.3 Sensitive answers in a will: only if you choose

The will form has an optional step called "Your wishes": funeral wishes, organ or body donation, religious requirements, a dependant's special needs, and a living will. Some of these answers are special personal information under POPIA, because they are about health or religious beliefs.

You choose whether to fill in that step. Turning it on is your consent for the firm to use those answers to prepare your will (POPIA section 27(1)(a)). Nothing else in the form depends on it. If you turn it off again, those answers are removed from your application straight away.

4.4 Information about children

The will form asks for your children's names and dates of birth, so that your will can provide for them. You give them as their parent, and the firm uses them only to prepare your will. POPIA's rules on children's information (sections 34 and 35) apply.

4.5 What else is recorded

• Your link. For an antenuptial contract or a will, we email you a private link to your application when you start. It works for 14 days and is extended while you keep using it. What you type is saved as you go, so you can come back to it. Anyone with the link can open your application, so share it only with your partner.
• When you send. The date and time, the internet (IP) address you sent it from, and your tick confirming that you read the privacy notice.
• The firm's updates. Whether you ticked the box to receive the firm's own updates by email. It starts unticked and is optional. These would be the firm's messages, not ours.
• A summary. A PDF summary of your application, made on your device and sent with it.
• Who opened it. Which of the firm's people opened your application, and when.
• Older applications. Antenuptial contract applications sent before 28 September 2026 may also hold a signature drawn on the screen. The form no longer asks for one. They are deleted on the same 90-day timetable (section 4.7).

4.6 Who sees it

• The firm. Its partners, and the staff the firm allows to see applications, through the firm's dashboard. The firm may give your details to others it must deal with to do the work, such as the notary, the Deeds Office or a finance provider. The firm's own notice says more.
• Email. When you send, we email the firm your answers and the summary PDF, and email you a copy. The firm also gets a private page with your uploaded documents. Each time it opens that page, it gets download links that work for one hour. Copies of these emails in the firm's mailbox and yours are outside our control.
• FIFO's administrator can see applications, but looks only to support the firm when it asks, to keep the service secure, or when the law requires it.
• Our service providers store and send applications for us (section 8).

On the web, a check from Cloudflare (Turnstile) runs when you start an application, ask for your link again or send a bridging application. It looks at technical signals from your browser, not at your answers.

4.7 How long it's kept

FIFO Law is only the way your application reaches the firm, so we don't keep it for long:

• a sent application, with its uploads and summary, is deleted 90 days after you send it, at the end of that day (South African time). The date is shown when you send it and in your confirmation email;
• an application that is never sent is deleted 7 days after its link stops working;
• a bridging application that fails to send is removed within a day;
• deletion runs every night at 02:00 South African time. If an item can't be deleted, it is tried again the next night.

The firm keeps its own record for as long as it needs it and the law requires. For example, the Financial Intelligence Centre Act requires firms to keep identity records for at least five years. Ask the firm about its copy.

4.8 Questions about your application

Ask the firm first: it is responsible for your details. You may also email us at riaan@fifo.systems. Section 11 explains your rights.

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5. Firms and their staff

For the information in this section, FIFO is the responsible party.

5.1 What we keep and why

5.2 What is public

Everything a firm shows in its apps or web app is public: anyone can see it. The private addresses, the dashboard team and the sign-in records are never public, and they are not put in the apps.

5.3 Setting a firm up from its own website

When we set a firm up, we may copy text and team photos from the firm's own website. We use an AI service, Anthropic's Claude, to read that public text and to draft the firm's About page and its app store listing. We check every draft before it is used. This uses only what the firm already publishes. It never includes applications.

5.4 Our lawful reasons

We don't use staff information for marketing without consent. We don't sell it, rent it or share it with anyone for their marketing.

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6. The document library and app notifications

6.1 Documents a firm publishes

A firm on the Plus tier can publish documents (PDFs) in its apps and web app. They are public: anyone with the link can open them. A firm must not publish documents that hold anyone's personal information (terms clause 12).

When someone opens a document through the firm's link, we count it. We record the document, the time, the browser or app type, and the page the link was on. We don't record the IP address in that count.

Before a document is published, we make the file smaller. That step runs in Google's US region (section 9).

6.2 App notifications

A firm's apps can show a notification when the firm adds a document. To make this possible, every copy of the app registers with Google's Firebase Cloud Messaging when it opens, whether or not you allow notifications. Google gives that copy a random installation code and receives basic technical details: the device model, operating system version, language, time zone and app version. These don't identify you. On an iPhone or iPad, Apple delivers the notification.

Your copy of the app then joins a list for that firm's app. We send one message to the list. We don't receive or keep the installation codes, or any list of phones.

The app asks before it shows notifications. You can turn them off at any time in your phone's settings.

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7. Visitors to this website

7.1 No cookies, no analytics

This website, law.fifo.systems, uses no cookies, no analytics, no advertising and no tracking pixels. Its fonts and pictures come from our own servers.

The demo buttons open the web app of our made-up demo firm, Ashgrove Attorneys, which works like any firm's web app (section 3).

7.2 Server records

Google hosts the website. Its servers record technical details such as your IP address, your browser, the page and the time, to deliver the site and protect it from abuse. We don't use these records to identify visitors.

7.3 The "see it" page

We email some conveyancing firms a link to a page that shows FIFO Law at work. When that page is opened from such a link, and when a button on it is pressed, the page records: which button, the firm name and a code from the link (they tell us which email the link came from), the page, your browser type, and the page you came from. It doesn't keep your IP address. We use this to see whether our emails are useful, which is our legitimate interest (POPIA section 11(1)(f)). Opened any other way, the page records nothing.

7.4 Contacting us

If you WhatsApp or email us, we use your message and contact details to reply, and keep them as set out in section 10. WhatsApp and your email provider handle those messages under their own privacy terms.

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8. Who processes it for us

These service providers process personal information on our behalf, under written terms. None of them may use it for their own purposes.

If we add or replace a provider that handles applications, we tell subscribing firms first (terms clause 17.7).

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9. Where it's stored and processed

Our database and files are in Johannesburg, in Google Cloud's africa-south1 region, and most of our server code runs there too. Everything travels encrypted (HTTPS), and Google encrypts it where it is stored.

9.1 What happens outside South Africa

• Web pages and short links. Firebase Hosting can't run code in Johannesburg. So the code that serves the pages of firms' web apps and of this website, the app download links, the document download counter, the support pages and the counter on the "see it" page runs in Google's US region (Iowa). Pages travel through Google's worldwide network.
• The nightly deletion job. Google's scheduler isn't available in Johannesburg, so the job that deletes expired applications runs in the US. It reads which applications are due and deletes them. It doesn't copy them anywhere.
• Older apps. Apps built before 1 October 2026 send their requests, including online applications, to a copy of our server code in the US. What they send is still stored in Johannesburg. We'll remove the US copies once those apps have been replaced.
• Library documents. When a firm uploads a document to its library, a service in the US makes the file smaller before it is stored in Johannesburg. Library documents must not contain personal information.
• Email. Our emails, including applications, go through Brevo in the European Union.
• Other providers. Cloudflare, Codemagic, Apple, Google and Anthropic work as described in section 8, and the map service as described in section 3.3.

9.2 Sending information outside South Africa

POPIA section 72 allows personal information to go to another country in certain cases. We rely on section 72(1)(a): each provider is bound by written terms, such as Google's Cloud Data Processing Addendum and Brevo's data processing agreement, that give protection substantially similar to POPIA's. For online applications, sending them where they need to go is also necessary to do what the applicant asked the firm to do (section 72(1)(c)).

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10. How long we keep it

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11. Your rights

11.1 What you may ask

Under POPIA you have the right to:

1. Access: ask what personal information is held about you (section 23);
2. Correction and deletion: ask for wrong, incomplete or out-of-date information to be corrected or deleted, subject to records the law requires to be kept (section 24);
3. Objection: object, on reasonable grounds, to your information being processed (section 11(3)(a));
4. Withdrawing consent: where you gave consent, such as for the optional wishes in a will, withdraw it at any time (section 11(2)(b));
5. No direct marketing: object to direct marketing at any time (sections 11(3)(b) and 69);
6. Complaint: complain to the Information Regulator (section 11.4 below).

11.2 Who to ask

For an online application, ask the firm you applied to: it is the responsible party. You may also ask us. We'll pass your request to the firm, help it respond, and act on its instructions, for example to delete our copy sooner.

For a firm's details, staff sign-in accounts, billing, this website or messages you sent us, ask us.

11.3 How we respond

Email our Information Officer at riaan@fifo.systems. We respond within 30 days. We may first check that the request comes from you, for example by contacting you at the email address or phone number you gave.

11.4 The Information Regulator

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12. Security

• Applications are locked away. Nobody can read applications, or the links to them, straight from the database. Only our server code can, after it has checked the link.
• Private links. An application link is a long random code that can't be guessed. The firm's page of uploaded documents hands out download links that work for one hour.
• Each person signs in for themselves. On the firm dashboard, each person signs in with a link sent to their own email address and their own PIN. We keep PINs, sign-in links and sessions only as hashes. Five wrong PINs lock sign-in for a while. Partners decide what staff may see.
• Abuse checks. Public forms limit how often they can be used, and the web forms use Cloudflare's check.
• Encryption. Everything travels over HTTPS. Google encrypts stored data.
• Deletion on time. Applications are deleted on the timetable in section 4.7.
• FIFO's own access. Only FIFO's administrator account can see across firms.

No system is completely secure. If personal information in an application is compromised, we tell the firm immediately, as its operator, and help it tell the Information Regulator and the people affected. For information we are responsible for, we notify the Regulator and the people affected ourselves, as POPIA section 22 requires.

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13. Cookies and storage on your device

FIFO Law sets no cookies. The web apps and apps keep a few things in your browser's or phone's own storage so that they work. Nothing here is used for tracking or advertising.

Cloudflare's check runs inside a small frame from Cloudflare, under Cloudflare's own privacy terms. You can clear everything in your browser's or phone's settings.

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14. Children

FIFO Law is for firms and adults. We don't knowingly take applications from children. The will form asks a parent for their children's names and dates of birth (section 4.4).

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15. Changes to this notice

We may update this notice when FIFO Law changes. We tell subscribing firms about material changes by email at least 30 days before they take effect.

This version describes how FIFO Law already works, so it applies from the date at the top. It replaces the privacy policy of 20 February 2026.

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16. Contact and the Information Officer

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