Privacy Policy

Effective date: 23 July 2026
Last updated: 23 July 2026
True Colours Community respects your privacy and is committed to handling personal information lawfully, fairly and transparently.
This Privacy Policy explains what information we collect, why we use it, who may process it on our behalf, how long we keep it and what rights you have.
It applies when you:
  • visit the True Colours Community website;
  • submit an enquiry or join our mailing list;
  • purchase or hold a True Colours membership;
  • use the True Colours Hub on MemberVault;
  • attend a Discovery Session or Fireside Chat;
  • participate in community discussions, questionnaires or activities; or
  • otherwise communicate with True Colours Community.

1. Who is responsible for your information?

True Colours Community is operated by:
Legal entity or responsible party: Spritely (Pty) Ltd
Trading name: True Colours Community
Legal status: Private Company
Company or registration number, if applicable: 2018 / 019802 / 07
Information Officer: Celesté Meyburgh
Physical address: 27 Island View 2, La Paloma Boulevard, Big Bay, Western Cape, 7441
Email: connect@truecolourscommunity.com
Phone: +27 83 648 5606
For purposes of the Protection of Personal Information Act, 4 of 2013 (“POPIA”), the above entity is the responsible party for the personal information described in this policy.

2. What personal information do we collect?

Depending on how you interact with us, we may collect the following categories of information.

2.1 Contact and identification information

This may include:
  • your name and surname;
  • email address;
  • telephone or WhatsApp number;
  • country or general location;
  • login details and account identifiers;
  • communication preferences; and
  • any other information you include in an enquiry.

2.2 Membership and account information

This may include:
  • the membership option you selected;
  • membership start, cancellation and renewal dates;
  • access status;
  • MemberVault profile information;
  • course or module activity;
  • questionnaire responses;
  • comments, posts and community contributions;
  • attendance at live gatherings; and
  • questions, reflections or feedback you choose to submit.

2.3 Payment and transaction information

Payments are processed through PayFast.
PayFast may collect and process payment and identity information required to complete and verify the transaction. We generally receive information such as your name, email address, payment status, amount, date and transaction reference.
Your payment information is also subject to PayFast’s own privacy notice. 

2.4 Live-session information

When you participate through Zoom, information may include:
  • your display name;
  • email address or Zoom account information;
  • profile image;
  • attendance and connection information;
  • audio and video where your microphone or camera is switched on;
  • meeting-chat contributions; and
  • questions or comments you share.
Zoom processes participant and technical information required to provide its meeting services. 

2.5 Website and technical information

When you visit our website, we or our technology providers may collect:
  • IP address;
  • browser and device type;
  • operating system;
  • approximate geographic location;
  • pages visited;
  • date, time and duration of visits;
  • referring website or campaign;
  • clicks and other website interactions; and
  • cookie or similar identifiers.
Google Analytics’ standard implementation may collect user counts, session statistics, approximate location and browser or device information. 

2.6 Email information

When we send email communications, our email platform may process:
  • your name and email address;
  • delivery and bounce status;
  • unsubscribe choices; and
  • where enabled, whether an email was opened or a link was clicked.
Current email provider: MailerLite and Afrihost

2.7 Special personal information

True Colours is an LGBTQ+ affirming personal-development community. Information you voluntarily share may reveal or relate to:
  • sexual orientation or sex life;
  • religious or philosophical beliefs;
  • health or emotional wellbeing;
  • race or ethnic origin;
  • political views;
  • relationships and family circumstances; or
  • other sensitive aspects of your life.
You are not required to disclose special personal information in order to participate. Please consider carefully what you share in profiles, questionnaires, posts and live discussions.
Where you voluntarily provide special personal information, we process it only for purposes reasonably connected with providing and facilitating the True Colours membership, based on your consent or another lawful ground under POPIA. POPIA specifically regulates information about religious beliefs, health and sex life as special personal information.

3. How do we collect information?

We may collect information:
  • directly from you when you enquire, join or communicate with us;
  • when you complete a form, profile, questionnaire or activity;
  • when you attend or participate in a live gathering;
  • through MemberVault and our community platform;
  • through PayFast when you make a payment;
  • automatically through cookies, analytics and website technologies;
  • from email and communication platforms; and
  • where lawful, from a referral or another source you have authorised.

4. Why do we process personal information?

We use personal information to:
  • respond to enquiries;
  • process registrations and payments;
  • create and administer membership accounts;
  • provide access to the True Colours Hub;
  • communicate gathering dates, links and programme information;
  • facilitate Discovery Sessions and Fireside Chats;
  • provide recordings, learning material and resources;
  • personalise and support the member experience;
  • maintain community agreements and protect participants;
  • respond to technical or administrative questions;
  • send service-related emails;
  • send marketing where consent or another lawful basis exists;
  • understand and improve the website and programme;
  • prevent misuse, fraud or security incidents;
  • maintain tax, accounting and business records;
  • establish, exercise or defend legal rights; and
  • comply with legal and regulatory obligations.
We do not sell members’ personal information.
We do not use membership information to make decisions about you based solely on automated processing that have legal or similarly significant consequences.

5. Our grounds for processing

Depending on the circumstances, we may process information because:
  • it is necessary to enter into or perform our membership agreement with you;
  • you have given consent;
  • processing is required by law;
  • processing protects your legitimate interests or those of another person;
  • it supports our legitimate operational interests, provided these do not unjustifiably override your privacy rights; or
  • the information was deliberately made public by you.
Where processing depends on consent, you may withdraw that consent. Withdrawal does not make processing that occurred before withdrawal unlawful, and it may affect our ability to provide parts of the service.

6. MemberVault and the True Colours Hub

We use MemberVault to provide:
  • member accounts and logins;
  • Discovery Session recordings;
  • course material and resources;
  • questionnaires and activities;
  • member progress information;
  • comments and community discussions; and
  • administrative membership functions.
MemberVault processes personal information on behalf of its customers under its terms, privacy policy and data-processing agreement. Its data-processing agreement describes the customer as the controller and MemberVault as the processor for customer data.
Information you post in shared areas of the Hub may be visible to other active members. Please do not post information you would not be comfortable sharing within the membership community.
Community members are required to protect confidentiality, but we cannot guarantee that every member will comply. A breach of confidentiality may result in suspension or termination under the Terms of Service.

7. Zoom, Discovery Sessions and Fireside Chats

7.1 Discovery Sessions

Discovery Sessions may be recorded.
Members will be informed when recording begins. If you do not wish to appear in the recording, you may:
  • keep your camera switched off;
  • keep your microphone muted;
  • use a first name or alternative display name where appropriate; or
  • submit a question privately before or after the gathering.
Recordings may include identifiable audio, video, names, chat messages or contributions made while the recording is active.

7.2 Fireside Chats

Fireside Chats are not recorded.
They are intended to offer a more confidential space for personal reflection and conversation. Zoom may still process technical and attendance information required to deliver the meeting.
Members must not personally record, photograph, screen-record or take screenshots of Fireside Chats.

8. YouTube and Discovery Session recordings

Discovery Session recordings may be uploaded to YouTube as unlisted videos and embedded or linked within the True Colours Hub.
Unlisted videos do not ordinarily appear on the public channel page or in public search results. However, anyone who obtains the link can technically view and share the video. 
Members may not copy, forward, publish or share an unlisted recording link outside the True Colours membership.
When you watch an embedded or linked YouTube video, Google may receive information including your IP address and the page URL and may use cookies or similar technologies. 
Where practical, recordings may be edited to remove sensitive or unnecessary personal contributions. You may contact us if you have a reasonable concern about your identifiable appearance in a recording.

9. Google Analytics

We use Google Analytics to understand how people find and use the website.
This may include information about:
  • page views;
  • session activity;
  • general traffic sources;
  • browser and device type;
  • approximate location;
  • interactions with the website; and
  • other technical usage statistics.
We use this information to understand website performance and improve our communications. We do not intentionally send your name, email address or private community contributions to Google Analytics.
Google requires website operators using Analytics to disclose its use and explain how information is collected and processed. 
Google Analytics user-level and event-level data will be retained according to our selected Analytics retention setting, currently 14 months. Google provides retention controls for this type of data. 

10. Cookies and similar technologies

Cookies are small files or identifiers placed on a device when a person visits a website or uses an online service.
We may use the following categories.

10.1 Essential cookies

These support functions such as:
  • website security;
  • navigation;
  • login sessions;
  • remembering necessary settings; and
  • providing access to MemberVault.
Some parts of the website or Hub may not function properly without essential cookies.

10.2 Analytics cookies

Google Analytics may use first-party cookies or similar identifiers to distinguish visits and understand website usage. 

10.3 Embedded-media cookies

YouTube and other embedded services may place or access cookies when media is loaded or played.

10.4 Email technologies

Emails may contain pixels or tracked links that help us understand delivery, opens or clicks, where supported by our email provider.
You can manage non-essential cookies through our cookie banner and through your browser settings. Blocking some cookies may affect features or embedded content.
We recommend configuring the website so that optional analytics and embedded-media cookies are not activated until the visitor has made an appropriate cookie choice.

11. Email and direct marketing

We distinguish between:

Service communications

These include:
  • payment or account information;
  • gathering dates and links;
  • changes to the programme or Terms;
  • Hub access details;
  • security notices; and
  • other information necessary to provide your membership.
You may not be able to opt out of essential service messages while your membership remains active.

Marketing communications

We may send promotional communications where:
  • you have consented;
  • you are an existing customer and the communication is permitted by law; or
  • another lawful basis applies.
Every marketing email will identify the sender and provide a way to unsubscribe or request that the messages stop.
South Africa’s Information Regulator states that unsolicited electronic direct marketing generally requires consent, subject to the limited existing-customer provisions in POPIA, and recipients must be able to opt out.
Unsubscribing from marketing will not cancel your membership or stop necessary service communications.

12. Who may receive or process information?

We may disclose or make information available to:
  • MemberVault;
  • PayFast;
  • Zoom;
  • Google, including Google Analytics and YouTube;
  • our website and hosting providers;
  • our email and communication providers;
  • professional advisers such as accountants, attorneys or IT specialists;
  • contractors who assist with administration or facilitation and are subject to confidentiality obligations;
  • regulators, law-enforcement bodies or courts where legally required; and
  • another entity involved in a lawful restructuring or transfer of the programme, subject to appropriate safeguards.
These organisations may act as service providers processing information on our instructions, or as independent responsible parties under their own privacy terms.
We share only information reasonably necessary for the relevant purpose.

13. Cross-border processing

MemberVault, Zoom, Google, YouTube and certain other providers may process or store personal information outside South Africa.
POPIA permits cross-border transfers where, for example:
  • the recipient is subject to an adequate law or binding agreement;
  • you consent;
  • the transfer is necessary to perform a contract with you; or
  • another condition in section 72 is met. 
We take reasonable steps to use reputable providers and contractual or other safeguards intended to protect information transferred outside South Africa.
Because members may voluntarily disclose special personal information, we also seek to minimise what is transferred and encourage members not to share unnecessary sensitive information.

14. How long do we keep information?

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, or as required by law. POPIA requires deletion, destruction or de-identification when information is no longer authorised to be retained. 
Our general retention approach is:

Active-member records

Account, access and membership information is retained while the membership is active.
After membership ends, non-financial account information will ordinarily be deleted or de-identified within 90 days, unless:
  • you ask us to retain it for an anticipated return;
  • it is required for a dispute or legal obligation;
  • it forms part of a community discussion involving other members; or
  • deletion remains subject to a provider’s normal backup cycle.

Payment and accounting records

Invoices, transaction records and supporting tax information may be retained for at least five years, or longer where required for an audit, dispute or legal obligation. SARS generally requires relevant supporting records to be retained for five years from submission of the applicable return. 

Enquiries

General enquiries may be retained for up to 24 months after the last meaningful communication, unless there is a reason to retain them longer.

Marketing records

Marketing contact information is retained until you unsubscribe, withdraw consent or the information is no longer required.
We may retain a minimal suppression record so that we remember not to send further marketing communications.

Discovery Session recordings

Discovery Session recordings may be retained for as long as they remain relevant to the True Colours programme archive.
Access to them ends when membership access ends, unless a different written arrangement applies.

Fireside Chats

Fireside Chats are not recorded.

Community posts and comments

Where you request account deletion, we will take reasonable steps to remove or anonymise your profile and personal contributions. Some contributions may need to remain where removal would disrupt an existing group conversation or where retention is legally justified.

15. How do we protect personal information?

We use reasonable technical and organisational safeguards appropriate to the nature of the information, which may include:
  • password-protected systems;
  • access controls;
  • reputable payment and hosting providers;
  • secure connections;
  • limited administrative access;
  • confidentiality requirements;
  • software and account-security updates; and
  • backups and recovery measures where available.
No online system can be guaranteed completely secure. You are responsible for protecting your login details and notifying us if you suspect unauthorised access.
If there are reasonable grounds to believe that personal information has been unlawfully accessed or acquired, we will follow applicable legal notification requirements. POPIA requires notification to the Information Regulator and affected individuals in qualifying circumstances. 

16. Your rights

Subject to applicable law, you may:
  • ask whether we hold personal information about you;
  • request access to that information;
  • request correction of inaccurate or outdated information;
  • request deletion or destruction where we are no longer authorised to retain it;
  • object to certain processing;
  • withdraw consent;
  • opt out of direct marketing;
  • ask who has received or had access to your information; and
  • lodge a complaint.
POPIA expressly provides rights of access and the ability to request correction or deletion in qualifying circumstances. 
To exercise a right, contact:
Information Officer: Celesté Meyburgh
Email: connect@truecolourscommunity.com
We may need to verify your identity before releasing, correcting or deleting information.
Some rights are not absolute. We may retain information where required by law, necessary for legal claims or subject to another lawful retention ground.

17. Complaints

Please contact us first so that we have an opportunity to address your concern.
You may also lodge a POPIA complaint through the Information Regulator’s official eServices portal.
Information Regulator South Africa
Telephone: 010 023 5200
Toll-free: 0800 017 160
Email: enquiries@inforegulator.org.za
The Regulator accepts complaints concerning matters such as unauthorised disclosure, security failures, unlawful collection, special personal information and failures to respond to rights requests. 

18. Children

True Colours membership is intended for people aged 18 and older.
We do not knowingly offer membership to or collect membership information from children. Please contact us if you believe that a person under 18 has provided information without appropriate authority.

19. Links and third-party websites

The website and Hub may link to podcasts, articles, videos or external websites that we do not control.
Those third parties have their own privacy practices. We encourage you to review them before providing information or creating an account.

20. Changes to this Privacy Policy

We may update this policy to reflect changes in:
  • the programme;
  • technology or providers;
  • our information practices; or
  • legal requirements.
The updated version will display a revised date. We will notify active members of material changes by email or through the True Colours Hub.

21. Contact us

Questions, requests and privacy concerns may be directed to:
Celesté Meyburgh
Information Officer
True Colours Community
Email: connect@truecolourscommunity.com
Telephone: +27 83 648 5606
Physical or service address: 27 Island View, La Paloma Boulevard, 7441, Western Cape