PRIVACY POLICY, TERMS OF USE & DATA PROCESSING NOTICE

1. INTRODUCTION

This website, mobile experience, quoting platform, policy onboarding system, claims environment, customer portal, communication channels, and related digital services (“Platform”) are operated by BetterPet and administered by Black Cygnet Life (Pty) Ltd (“Black Cygnet Life”, “we”, “our”, or “us”), an authorised Financial Services Provider, FSP No. 44723.

BetterPet is a digital pet insurance and pet care platform designed to assist pet owners with insurance, claims support, policy administration, communication services, and related pet wellness offerings through authorised insurers, operators, partners, and technology providers.

By accessing, browsing, registering on, submitting information through, or using the Platform, you acknowledge and agree that you have read, understood, and accepted:

• these Terms of Use;
• this Privacy Policy;
• applicable policy wording and underwriting rules;
• electronic communication consent;
• and all applicable South African laws and regulations.

If you do not agree to these terms, you must immediately discontinue use of the Platform.

2. REGULATORY & LEGAL COMPLIANCE

BetterPet and Black Cygnet Life process information in accordance with:

• The Protection of Personal Information Act, 4 of 2013 (“POPIA”);
• The Financial Advisory and Intermediary Services Act (“FAIS”);
• Applicable Insurance Legislation;
• The Electronic Communications and Transactions Act (“ECTA”);
• Consumer protection laws;
• and all other applicable laws and regulations of the Republic of South Africa.

Black Cygnet Life acts as the authorised financial services provider and operational administrator of the Platform.

3. INFORMATION WE COLLECT

We may collect, process, verify, analyse, store, transfer, and retain the following categories of information:

4. PURPOSE OF PROCESSING

Your information may be processed for:

• insurance quotations;
• underwriting assessments;
• policy administration;
• premium collections;
• claims processing;
• fraud prevention;
• customer support;
• communication delivery;
• regulatory compliance;
• service improvements;
• analytics;
• and operational administration.

Certain information, including pet breed and age, may directly affect:

• product eligibility;
• premium calculation;
• underwriting acceptance;
• policy terms;
• or claim assessment requirements.

5. AI-ASSISTED PROCESSING & AUTOMATION

The Platform may utilise artificial intelligence (“AI”), automation tools, and machine-assisted technologies for:

• workflow automation;
• document extraction;
• claims support;
• invoice interpretation;
• communication assistance;
• fraud detection support;
• operational efficiencies;
• and data classification.

AI systems may process:

• policy information;
• customer communications;
• veterinary invoices;
• and claim-related documentation.

However:

• AI tools do not independently make final underwriting, policy issuance, or claims decisions.
• All final decisions remain subject to human review, insurer rules, policy wording, underwriting criteria, claims validation procedures, and applicable South African law.

Users acknowledge that AI-assisted outputs may contain inaccuracies, interpretation limitations, or incomplete information and do not constitute veterinary, financial, legal, or insurance advice.

6. THIRD-PARTY OPERATORS & SERVICE PROVIDERS

BetterPet may share information with authorised third parties where reasonably necessary for operational, insurance, payment, claims, hosting, communication, analytics, or regulatory purposes.

These parties may include:

• insurers and underwriters;
• payment providers;
• claims assessors;
• veterinary service providers;
• cloud hosting providers;
• communication providers;
• analytics providers;
• operational partners;
• and authorised service providers.

Technology and operational providers may include:

• Root Platform
• OMART Insure
• Paystack
• Peach Payments
• Supabase
• OpenAI
• Resend
• and authorised operational service providers.

Certain information may be processed or hosted outside South Africa, including within the European Union, such as Ireland, where cloud infrastructure or technology providers operate.

By using the Platform, you expressly consent to the lawful cross-border transfer, storage, and processing of your information where reasonably necessary for service delivery and operational functionality.

All reasonable steps are taken to ensure that third-party operators maintain appropriate confidentiality and security safeguards.

7. PAYMENTS & RECURRING BILLING

Recurring premium collections and payment processing may be facilitated through approved payment providers and authorised collection systems.

BetterPet and Black Cygnet Life do not intentionally store full card details. Payment information may be tokenised, encrypted, or securely processed through authorised third-party payment operators.

By proceeding with payment authorisation, users acknowledge and agree that:

• recurring card mandates;
• debit order instructions;
• electronic payment authorisations;
• and digital payment confirmations

may constitute legally enforceable payment instructions.

8. DATA RETENTION & RECORDKEEPING

Information may be retained for:

• insurer obligations;
• regulatory compliance;
• legal proceedings;
• fraud investigations;
• operational continuity;
• claims validation;
• and insurance recordkeeping requirements.

Certain records may be retained for a minimum period of five (5) years following policy termination, cancellation, lapse, or claim settlement where required by law, insurer obligations, or operational necessity.

Deletion requests may be restricted where:

• legal retention obligations apply;
• disputes remain unresolved;
• investigations are ongoing;
• or records are required for regulatory purposes.

9. CUSTOMER RIGHTS

Subject to applicable South African law, users may request:

• access to personal information;
• correction of inaccurate information;
• deletion of eligible information;
• withdrawal of marketing consent;
• objection to certain processing activities;
• and information relating to stored records.

Requests may be declined where processing or retention remains legally required.

10. CYBERSECURITY & ACCEPTABLE USE

Users may not:

• scrape or harvest data;
• reverse engineer the Platform;
• abuse APIs or integrations;
• deploy automated bots;
• submit fraudulent claims;
• upload malicious files;
• perform unauthorised penetration testing;
• attempt prompt injection attacks against AI systems;
• bypass authentication controls;
• impersonate other individuals;
• interfere with platform security;
• submit false or misleading information;
• or unlawfully access systems or data.

Any such conduct may result in:

• immediate suspension;
• termination of access;
• reporting to regulators or authorities;
• civil proceedings;
• criminal prosecution;
• and insurer notification.

11. FRAUD PREVENTION & CLAIMS VALIDATION

BetterPet reserves the right to:

• validate information submitted;
• request supporting documentation;
• investigate suspicious activity;
• suspend policies or claims;
• and share information with insurers, regulators, investigators, law enforcement, or fraud prevention agencies where reasonably necessary.

Fraudulent activity may result in:

• repudiated claims;
• policy cancellation;
• recovery proceedings;
• blacklisting;
• and criminal prosecution.

12. ELECTRONIC COMMUNICATION & DIGITAL CONSENT

Users consent to:

• electronic communication;
• digital notices;
• email delivery;
• WhatsApp communication;
• call recordings;
• electronic signatures;
• and digital acceptance records.

Electronic logs, timestamps, communication records, and digital acknowledgements may be relied upon as evidence in disputes, claims assessments, underwriting matters, investigations, or legal proceedings.

13. INTELLECTUAL PROPERTY

All platform content, workflows, branding, interfaces, systems, AI workflows, documentation, graphics, software structures, and related intellectual property remain the property of BetterPet, Black Cygnet Life, or their licensors.

Users may not:

• reproduce;
• copy;
• distribute;
• commercialise;
• exploit;
• or reverse engineer

any portion of the Platform without prior written consent.

14. LIMITATION OF LIABILITY

To the fullest extent permitted by law:

• BetterPet;
• Black Cygnet Life;
• insurers;
• operators;
• employees;
• technology providers;
• and authorised partners

shall not be liable for:

• indirect losses;
• consequential damages;
• data loss;
• cyber incidents;
• system interruptions;
• third-party failures;
• AI interpretation inaccuracies;
• delayed communications;
• or unauthorised access beyond reasonable control.

The Platform is provided on an “as is” and “as available” basis.

While commercially reasonable safeguards are implemented, no digital platform can guarantee uninterrupted functionality or absolute security.

15. DISPUTES, ARBITRATION & JURISDICTION

Any dispute arising from:

• use of the Platform;
• policy onboarding;
• claims processing;
• payment disputes;
• communications;
• or data processing activities

shall first be referred to good-faith negotiation between the parties.

Failing resolution, disputes may be referred to confidential arbitration within the Republic of South Africa.

These terms shall be governed exclusively by the laws of South Africa.

South African courts shall retain jurisdiction where arbitration is not enforceable or applicable.

16. CHANGES TO THESE TERMS

BetterPet and Black Cygnet Life reserve the right to amend, replace, update, or modify these terms at any time.

Updated versions may be published on the Platform and become effective upon publication.

Continued use of the Platform constitutes acceptance of the updated terms.

17. CONTACT & INFORMATION OFFICER