Wolfpak
Privacy Policy
1. Who this covers
This policy explains how Wolfpak handles personal information. It applies to the Wolfpak control room (the website), the Wolfpak mobile application, and the radio trackers that report positions into the service.
It is written for two audiences: the organisation that uses Wolfpak — a farm watch, a community policing forum, a security company — and the individual members whose position the service reports.
2. Who is responsible for what
This matters because it decides who you ask about what, and the answer is not the same for everything.
- Your group is the responsible party for operational information — who its members are, where they were, the incidents it logged and what its operators wrote. Your group decides who is tracked, when, and why. We hold and process that information on your group's instructions, as its operator in the sense POPIA uses the word.
- We are the responsible party for the small amount of information we need in order to run the service at all — your account details, the fact that your group exists, support correspondence, and technical logs.
If you are a member of a group and you want to know why you are being tracked, or you want your data corrected or removed, ask your group first. They decide. We will help them act on it, and we will not override them.
3. Location, including in the background
This is the most significant thing the service does with personal information, so it is set out on its own.
What the app does with your location
- While you are on shift, the app reports your position to your own control room. It does this continuously, and it does this in the background — with the app closed, minimised, and the screen locked. On iOS you will see the system's location indicator while it is doing so; on Android there is a permanent notification saying you are on shift.
- Why it must work in the background: a control room that can only see you while you are holding your phone cannot send you anywhere, and cannot tell whether you are where you were sent. Foreground-only reporting would make the product pointless.
- When you go off shift, it stops. No position is reported and none is recorded. There is no facility for a group to track a member who is off shift.
- You can refuse or revoke the permission in your device settings at any time. The app will keep working, but your control room will not be able to see you, and they may not be able to dispatch you.
- Who sees it: your group's control room operators, and other responders assigned to the same incident as you — so that units working the same scene can see each other. Nobody outside your group. No advertiser. Nobody at Wolfpak reads it in the ordinary course.
- A radio tracker assigned to you reports in the same way, over long-range radio rather than the mobile network, and its position is treated as yours while it is recent.
Positions are also recorded against events in the incident log — for example, where you were when you acknowledged a tasking or reported arriving. See section 10.
4. Everything we collect
Account information
Your name, email address, callsign if you have one, your password (stored only as a one-way hash, which means we cannot read it), the groups and roles you hold, and when you were last active.
Location information
Latitude and longitude, the accuracy your device reported, and the time of the fix. From a radio tracker we also receive speed, heading and battery level, and a record of how the position was authenticated. A history of these positions is kept — see section 9.
Operational information
Incidents your group opens, including the type, description and location; taskings, including the destination, the label and any note to the units; each responder's acknowledgement, en route and arrival; and notes your operators or responders type.
Device information
A push notification token so we can alert your device, the platform (iOS or Android), and an identifier we generate for the app installation so that reinstalling retires the old registration. We do not collect your advertising identifier, your contacts, your photos, your microphone or your call history.
Technical information
Ordinary server logs, which include IP addresses, timestamps and which requests were made. We use them to run and secure the service.
What we do not collect
We do not use advertising or analytics trackers. We do not build a profile of you. We do not collect payment card details — during a pilot there is nothing to pay.
5. Why we collect it
Under POPIA we need a lawful basis for each purpose. Ours are:
- To provide the service you asked for — showing positions, delivering taskings, keeping the incident record. This is necessary to perform our agreement with your group.
- Consent, for tracking a member's location. Your group must obtain this from each member and be able to show that it did. Going on shift is the member's own action, and the app asks for the device permission before anything is reported.
- Legitimate interests — keeping the service secure, preventing abuse, diagnosing faults, and improving the product.
- Legal obligation, where we are required to retain or disclose something.
We do not use your information for automated decision-making. Every operational decision in Wolfpak is made by a person in your control room.
6. Information about other people
An incident record often contains information about somebody who is not a member of your group — a caller, a complainant, a neighbour, a person somebody has described. Your operators type this in.
That information is your group's responsibility. You must have a lawful basis for recording it, you must not record more than you need, and you should assume that what is typed into an incident note will still be there afterwards. Please tell your operators this: it is not a place for opinions about people, and identifying details should only be recorded where there is a reason to.
8. Information leaving South Africa
Some of the providers above operate outside South Africa, including in the United States and the European Union. That means some personal information is processed outside the country.
We rely on section 72 of POPIA: these providers are bound by contractual terms requiring a level of protection substantially similar to POPIA's principles, and the transfer is necessary to perform our agreement with your group.
9. How long we keep it
- Account information — while your account exists, and for a short period afterwards so that a group can be restored if it was closed by mistake.
- Position history — while your group is active. We keep a history so that a control room can see where a unit has been during an incident and so that an incident record is complete.
- Incidents and their logs — while your group is active. These are the records you may need long after the incident, which is the point of them.
- Push tokens — until the device is unregistered, you sign out, or the push service reports the token as dead.
- Technical logs — a short period, in the ordinary course of running a server.
If your group asks us to delete its data, we will — all of it, or a specified part such as position history older than a given date. Ask at support@wolfpak.co.za. We may keep what we are legally required to keep, and we may keep aggregated information that no longer identifies anybody.
To decide before this is relied on: a fixed retention period for position history — 90 days is a reasonable default — and an automatic job that enforces it. Today deletion happens when a group asks for it, which is honest but means this section promises no automatic expiry. Once the job exists, state the period here.
10. Incident logs cannot be edited
The incident log is deliberately append-only. Entries are added and never altered or removed, because a record that somebody can quietly revise afterwards is worth very little — and these records exist for exactly the situations where that matters.
This has a consequence worth stating plainly. If information in a log entry is wrong, the correction is a new entry saying so; the original stays. If somebody exercises a right that would require an entry to be changed or erased, we cannot edit the line — what we can do is delete the incident, or the group's records, in full. We will work with your group to find the right answer in the circumstances.
11. Your rights
Under POPIA you may:
- Ask what personal information we hold about you, and get a copy.
- Ask for information that is wrong or incomplete to be corrected.
- Ask for information to be deleted where we have no lawful reason to keep it.
- Object to processing based on legitimate interests.
- Withdraw consent — for a member, by going off shift or revoking the location permission on your device.
- Complain to the Information Regulator.
Where to ask. If you are a member of a group, start with your group — they are the responsible party for operational information and they decide. For account information, or if your group does not respond, write to us at support@wolfpak.co.za. We will respond within 30 days and may need to verify who you are first.
Exercising a right costs nothing and will not affect your standing in your group as far as we are concerned.
12. Security
We take reasonable technical and organisational measures to protect personal information: traffic is encrypted in transit, passwords are stored only as one-way hashes, tracker credentials are stored hashed and shown once, sessions can be revoked, and one group's data is separated from another's throughout the service.
No system is perfectly secure, and we do not claim otherwise. If a breach occurs that creates a real risk to anybody, we will notify the affected groups and the Information Regulator as POPIA requires.
A phone is part of this too. A responder's device holds incident details on its lock screen. Use a device passcode.
13. Children
Wolfpak is not intended for people under 18 and we do not knowingly collect their information. A group must not invite a person under 18 as a member. If you believe we hold a child's information, tell us and we will delete it.
14. Changes
We will update this policy when the service changes. Where a change materially affects how we handle personal information we will tell your group's administrators by email and give reasonable notice before it takes effect.
The version and effective date at the top tell you which policy applies.
15. Contact and complaints
Privacy questions and requests:
support@wolfpak.co.za
Anything else: hello@wolfpak.co.za
To be completed: the name and contact details of your registered Information Officer, and Wolfpak's registration number and physical address. POPIA requires an Information Officer to be registered with the Information Regulator, and a privacy policy that does not name one is incomplete.
You may also complain to the Information Regulator of South Africa: inforegulator.org.za, POPIAComplaints@inforegulator.org.za.