Legal

Privacy Policy

We take your privacy seriously. This policy explains exactly what personal information we collect, why we collect it, how we protect it, and your rights under South African law.

Effective Date: 1 May 2026 Last Updated: 1 May 2026 Governed by: POPIA (Act 4 of 2013)

Table of Contents

  1. Responsible Party
  2. Information We Collect
  3. Purpose of Processing
  4. Legal Basis
  5. Third Parties
  6. Cross-Border Transfers
  7. Data Retention
  8. Security Measures
  9. Your Rights
  10. Breach Notification
  11. Cookies
  12. Operator Architecture
  13. Children's Privacy
  14. Policy Changes
  15. Contact Us
  16. Information Regulator

1. Responsible Party & Information Officer

For the purposes of the Protection of Personal Information Act, 4 of 2013 ("POPIA"), the Responsible Party for personal information collected through the Remunera platform is:

Company Name
Syntera Labs (Pty) Ltd
Registration No.
2026/348010/07
SARS Tax No.
9628009228
Product
Remunera HR & Payroll
Country
Republic of South Africa
Email
info@synteralabs.co.za

Information Officer

As required by POPIA and the 2025 POPIA Amendment Regulations, Syntera Labs has appointed and registered an Information Officer with the Information Regulator of South Africa. Our Information Officer is responsible for ensuring compliance with POPIA and handling all privacy-related requests and complaints.

To contact our Information Officer: info@synteralabs.co.za

Our PAIA (Promotion of Access to Information Act) Manual is available on request at info@synteralabs.co.za.

2. Personal Information We Collect

We collect personal information only to the extent necessary to provide the Remunera HR and payroll service. Below is a full breakdown of the categories of personal information we process:

2.1 Standard Personal Information

2.2 Special Personal Information

The following categories constitute Special Personal Information under POPIA Section 26 and are processed only where a specific legal basis exists:

CategoryWhen CollectedLegal Basis
Race / ethnic originEmployment Equity Act reporting only, if applicableLegal obligation (EEA Section 21)
Health / disability informationOnly if relevant to leave or payroll accommodationExplicit employee consent
GenderEmployment Equity reporting and statutory leave calculationsLegal obligation (BCEA, EEA)

⚠ Special Personal Information is never collected without a valid legal basis and is stored with additional access controls. We do not collect biometric data of any kind.

2.3 Account and Usage Information

3. Purpose of Processing

We process personal information only for the specific, explicit, and legitimate purposes set out below. We will not process information for any purpose incompatible with those listed here without obtaining fresh consent or having another lawful basis.

PurposeDescription
Payroll ProcessingCalculating gross pay, statutory deductions (PAYE, UIF, SDL), and net pay per payroll period
Statutory SubmissionsGenerating and filing EMP201 monthly returns, EMP501 reconciliations, and IRP5/IT3(a) certificates with SARS on behalf of the employer
UIF AdministrationCalculating and declaring UIF contributions to SARS (via EMP201) and the Department of Employment and Labour (via uFiling)
Leave ManagementRecording, approving, and tracking employee leave entitlements, requests, and balances per the BCEA
Payslip GenerationGenerating compliant digital payslips containing all information required by the BCEA
HR AdministrationMaintaining accurate employee records as required by the BCEA and other applicable legislation
Employment Equity ReportingGenerating EEA2 and EEA4 reports for designated employers (where applicable)
SARS Compliance ReportsGenerating EMP201 summaries, IRP5 reports, and EMP501 reconciliation data
Account ManagementCreating and maintaining user accounts, authenticating users, and managing subscription billing
Customer SupportResponding to enquiries, troubleshooting issues, and providing technical assistance
Security & AuditMaintaining audit logs to detect and prevent unauthorised access, fraud, or misuse
Legal ComplianceMeeting our obligations under the Income Tax Act, BCEA, UIF Act, SDL Act, EEA, POPIA, and any other applicable South African law

5. Third Parties Who Receive Personal Information

We share personal information only to the extent strictly necessary and only with parties who are contractually bound to protect it:

5.1 Statutory Recipients (Required by Law)

RecipientInformation SharedLegal Basis
South African Revenue Service (SARS)PAYE, UIF, SDL amounts; IRP5/IT3(a) certificates; EMP501 dataIncome Tax Act, UIF Act, SDL Act
Department of Employment and LabourUIF employer declarations; UI-19 termination formsUIF Act
Compensation FundCOIDA submissions (where applicable)Compensation for Occupational Injuries and Diseases Act

5.2 Service Providers (Sub-Processors)

We use the following categories of sub-processors to deliver the Remunera service. Each sub-processor is bound by a written data processing agreement:

CategoryPurposeLocation
Cloud InfrastructureHosting platform data and databasesUSA / EU (adequacy safeguards applied)
Email DeliverySending payslips, notifications, and system alertsUSA (standard contractual clauses)
PDF GenerationGenerating payslip PDF documentsIn-browser (no data transmitted to third party)
AnalyticsAggregated, anonymised platform usage metrics onlyEU / USA

✓ We do not sell, rent, or trade personal information to any third party for marketing, advertising, or any commercial purpose unrelated to the Remunera service.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of Syntera Labs' assets, personal information held in the Remunera platform may be transferred to the acquiring entity. We will provide 30 days' written notice to affected clients before any such transfer occurs and will require the acquirer to honour this Privacy Policy.

6. Cross-Border Transfers

Some of our infrastructure sub-processors (cloud hosting, email delivery) operate servers outside the Republic of South Africa. Any cross-border transfer of personal information is conducted in compliance with POPIA Section 72, which requires that the recipient country or organisation provides substantially equivalent protection to POPIA, or that we have implemented binding contractual safeguards (standard contractual clauses).

Specifically, transfers to sub-processors in the United States are governed by standard contractual clauses approved under applicable data protection law. No personal information is transferred to a jurisdiction that does not meet the POPIA Section 72 threshold without your explicit consent or an applicable legal exemption.

7. Data Retention

We retain personal information only for as long as is necessary for the stated purposes and to comply with our statutory obligations. The following retention periods apply:

Data CategoryRetention PeriodLegal Basis
Payroll records (payslips, calculations)5 years from date of processingSARS requirement — Income Tax Act
IRP5 / IT3(a) certificates5 years from tax year endIncome Tax Act
EMP201 / EMP501 submissions5 years from submission dateIncome Tax Act
Employee personnel records3 years after termination of employmentBCEA Section 31
UIF declarations and records5 yearsUIF Act
Leave records3 years after employment endsBCEA
Audit logs (system access)2 yearsLegitimate interest — security
Support correspondence2 years after resolutionContractual / legitimate interest
Subscriber account data (post-termination)30 days, then deleted/anonymisedContractual — post-termination clause

Upon expiry of the applicable retention period, personal information is securely deleted or irreversibly anonymised. Where a client terminates their Remunera subscription, they have 30 days to export their data. After 30 days, non-statutory data is deleted. Statutory records (payroll, IRP5, EMP201) are retained for the legally required 5-year period in a secure, restricted-access archive.

8. Security Measures

We implement appropriate technical and organisational measures to protect personal information against loss, theft, unauthorised access, disclosure, copying, use, or modification. Our security measures include:

⚠ No method of electronic transmission or storage is 100% secure. While we use industry-leading measures to protect your information, we cannot guarantee absolute security. We commit to notifying you promptly if a breach occurs that affects your data.

9. Your Rights as a Data Subject

Under POPIA, every data subject (individual whose personal information is processed) has the following rights. These rights apply to employees whose information is processed through the Remunera platform, as well as to Remunera clients (employer-subscribers).

9.1 Right to Access

You have the right to request confirmation of whether we hold your personal information, and to obtain a copy of that information. We will respond within 30 days of receiving a valid request (a hard statutory deadline under the 2025 POPIA Amendment Regulations).

9.2 Right to Correction

You have the right to request that we correct inaccurate, misleading, or out-of-date personal information. Employees should first raise corrections with their employer (the Responsible Party for their data), who will update the information in the Remunera platform.

9.3 Right to Deletion

You have the right to request deletion of your personal information where it is no longer necessary for the purpose for which it was collected, and where no statutory retention obligation applies. Payroll and tax records cannot be deleted during their mandatory 5-year retention period.

9.4 Right to Object

You have the right to object to the processing of your personal information on grounds of legitimate interest, and to object to processing for direct marketing purposes (which we do not conduct). We will cease processing upon a valid objection unless we have compelling legitimate grounds that override your interests.

9.5 Right to Withdraw Consent

Where consent is the legal basis for processing (Special Personal Information), you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Where consent withdrawal would prevent us from delivering statutory payroll services, we will notify you of this consequence.

9.6 How to Submit a Request

Per the 2025 POPIA Amendment Regulations, we accept data subject requests through multiple channels:

We will acknowledge receipt within 3 business days and respond fully within 30 days. Identity verification is required before we release any personal information.

✓ Accessing your personal information is free of charge. We will never charge a fee for responding to a data subject access request.

10. Data Breach Notification

In the event of a security compromise that affects personal information, we are committed to the following response:

Our breach notification will include: the nature of the breach, categories and approximate number of data subjects affected, likely consequences, measures taken or proposed, and contact details for further information.

11. Cookies and Tracking

Our marketing website (remunera.co.za) uses cookies. Under POPIA, cookies that collect personal information require your explicit consent.

Cookie TypePurposeConsent Required
Strictly NecessarySession management, security tokens, login stateNo — essential for the service to function
AnalyticsAggregated, anonymised usage statistics (no personal identification)Yes — opt-in consent required
PreferenceRemembering your display and language preferencesYes — opt-in consent required

We do not use third-party advertising cookies or behavioural tracking cookies. You may withdraw consent for non-essential cookies at any time by clearing your browser cookies and declining consent on your next visit.

The Remunera HR application (app.remunera.co.za) uses only strictly necessary session cookies required for authentication and security. No analytics or marketing cookies are deployed within the application.

12. Operator Architecture — Our Role Under POPIA

It is important to understand that Remunera operates as an Operator under POPIA — not as the Responsible Party — in respect of the personal information of your employees.

As required by POPIA Section 21, a written Operator Agreement governs our processing of employee data on your behalf. This Operator Agreement is incorporated into and forms part of your Remunera Terms of Service. By accepting the Terms of Service, you enter into the Operator Agreement.

As Responsible Party, you are responsible for:

13. Children's Privacy

The Remunera platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18 without verifiable parental or guardian consent, we will delete such information promptly. If you believe a child's information has been processed through our platform in error, please contact us at info@synteralabs.co.za.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the services we offer, or applicable legal requirements. We will:

Your continued use of the Remunera service after the effective date of updated terms constitutes acceptance. If you object to any material changes, you have the right to terminate your subscription per the Terms of Service.

15. Contact Us

For all privacy-related enquiries, data subject rights requests, or POPIA compliance questions, please contact our Information Officer:

General Support

We aim to acknowledge all privacy requests within 3 business days and resolve them within 30 days as required by POPIA.

16. The Information Regulator

If you are not satisfied with how we have handled your personal information or responded to your request, you have the right to lodge a complaint with the Information Regulator of South Africa — the statutory body that enforces POPIA.

Information Regulator (South Africa)