Instruman’s Privacy Policy
Privacy Policy
Last Updated: January 2026
Instruman (“Instruman”, “we”, “us”, or “our”) is committed to protecting the privacy and personal information of our customers, employees, suppliers, partners, and website visitors. This Privacy Policy is drafted in accordance with the Protection of Personal Information Act, 4 of 2013 (“POPIA”), the Electronic Communications and Transactions Act (“ECTA”), and applicable South African law.
1. Who We Are
Instruman is a South African provider of Time & Attendance systems, Access Control solutions, biometric identification systems, CCTV, and related security and workforce management technologies, including associated software and support services.
2. Scope of This Policy
This Privacy Policy applies to all personal information processed by Instruman, including information relating to:
- Visitors to our website(s)
- Customers and prospective customers
- Employees and contractors
- Suppliers and business partners
3. Personal Information We Collect
3.1 Identifying Information
- Full names
- Identity numbers (where legally required)
- Company and employee identifiers
3.2 Contact Information
- Email addresses
- Telephone and mobile numbers
- Physical and postal addresses
3.3 Employment & Operational Data
- Clocking and attendance records
- Shift and access logs
- System audit trails
3.4 Technical Information
- IP addresses
- Browser and device information
- Website usage data and cookies
3.5 Financial Information
- Billing and invoicing details
- Payment and transaction records
4. Special Personal Information (Biometrics)
Instruman may process biometric information, such as fingerprint or facial recognition templates, strictly for identification, security, and access control purposes.
- Biometric data is stored as encrypted templates
- Raw biometric images are not retained
- Processing occurs only with lawful justification
- Biometric data is never sold or used for marketing
5. How We Collect Information
Personal information may be collected directly from you, from your employer or authorised representative, automatically via our website, or through lawful third-party system integrations.
6. Purpose of Processing
We process personal information for purposes including:
- Provision and support of products and services
- Time & Attendance and Access Control operations
- System configuration, monitoring, and auditing
- Customer communication and support
- Billing and account administration
- Legal and regulatory compliance
- Security and fraud prevention
7. Lawful Basis for Processing
Instruman processes personal information on one or more of the following lawful grounds:
- Consent of the data subject
- Performance of a contract
- Compliance with legal obligations
- Legitimate business interests
8. Disclosure of Personal Information
Personal information may be shared with authorised employees, service providers, hosting partners, software vendors, or regulatory authorities where required by law. Instruman does not sell or trade personal information.
9. Cross-Border Data Transfers
Where personal information is transferred outside South Africa, Instruman ensures that adequate data protection safeguards are in place in accordance with POPIA.
10. Data Security Measures
Instruman implements appropriate technical and organisational safeguards, including encryption, access control, secure hosting, and staff confidentiality obligations, to protect personal information.
11. Data Retention
Personal information is retained only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Biometric data is removed or anonymised when no longer required.
12. Data Subject Rights
In terms of POPIA, you have the right to:
- Access your personal information
- Request correction or deletion
- Object to certain processing activities
- Withdraw consent, where applicable
13. Cookies
Our website uses cookies to improve functionality, analyse traffic, and support marketing activities where consent has been provided. You may control cookies through your browser settings.
14. Marketing Communications
Instruman will only send marketing communications where consent has been obtained or where permitted by law. You may opt out at any time.
15. Information Regulator
You may lodge a complaint with the Information Regulator of South Africa:
Email: inforeg@justice.gov.za
Website: https://www.justice.gov.za/inforeg/
16. Contact Details
For privacy-related enquiries or requests, please contact:
Information Officer – Instruman
Email: i.admin@instruman.co.za
Telephone: +27 13 656-3594/5
17. Policy Updates
Instruman reserves the right to update this Privacy Policy from time to time. Any changes will be published on our website with an updated revision date.