Privacy Policy

1. Introduction

Buffr Checkpoint is a digital visitor and access-management platform built in Namibia. This Privacy Policy explains how we collect, use, store, and protect personal information when you use our platform, website, or services.

This policy is grounded in Namibia's data-protection direction, the Electronic Transactions Act 4 of 2019, and the principles of privacy by design and data minimisation that govern the Buffr Checkpoint architecture.

2. Controller and Processor

In the context of visitor records, the client organisation (the bank, government office, healthcare facility, or other entity deploying Buffr Checkpoint) is the data controller. Buffr Checkpoint acts as the data processor on behalf of the client, processing visitor data only in accordance with the client's instructions and the applicable data-protection framework.

3. Data We Collect

Buffr Checkpoint collects only the minimum data necessary for the purpose of the visit. The exact fields depend on the visitor type, site configuration, and risk tier, but typically include:

• Visitor name and contact reference (phone number, stored encrypted)
• Host or department
• Purpose category (not free-text by default)
• Check-in and check-out timestamps
• Capture channel (kiosk, NFC, QR, USSD, SMS, assisted)
• Identity assurance level (V0–V4)
• Verification outcome and reference (not full credential payload)
• Device and site identifiers
• Consent or acknowledgement record where required

National ID numbers, photos, health information, and biometric data are disabled by default and require documented compliance approval before activation.

4. How We Use Data

Visitor data is used solely for the purpose of managing visitor access, notifying hosts, maintaining audit trails, and meeting retention and compliance obligations. We do not use visitor data for marketing, profiling, or any purpose unrelated to the visitor-management function.

5. Data Retention and Deletion

Retention periods are configured per site and visitor type, in accordance with the client's data-protection obligations. When a record reaches its retention threshold, it is either auto-deleted or flagged for legal hold if a hold is active.

Data-subject deletion requests (DSARs) are routed to the client's Compliance/Audit Officer, who verifies the requester's identity and authority before executing deletion or explaining a lawful exception. Every action is logged as an auditable event.

6. Data Security

Buffr Checkpoint implements encryption in transit (TLS) and at rest (database, object store, device cache, backups). Access is controlled through role-based access control (RBAC) enforced at the data and API layer, with tenant and site scoping on every query.

Audit events are written for every sensitive read, export, correction, and deletion, forming an append-only, hash-linked chain that supports evidence-pack generation for regulators and auditors.

7. Subprocessors

We use the following categories of subprocessor:

• Hosting: Flexible deployment options, including client-controlled private-cloud and on-premise deployments, per contract. Development and testing environments may use offshore infrastructure with synthetic data only; production deployments are scoped and confirmed per client.
• Messaging: Licensed MTC, Telecom Namibia, or approved local aggregator for SMS and USSD.
• Identity: DigiNam/NPKI verifier, where formally enabled by relying-party arrangement.

A current subprocessor list is maintained in the client contract and updated as arrangements change.

8. Cookies

The Buffr Checkpoint website uses essential cookies for session management and theme preferences. No tracking or advertising cookies are used without explicit consent. The admin application uses a session cookie strictly necessary for authentication, which does not require consent.

9. Your Rights

Visitors have the right to request access to, correction of, or deletion of their personal data. Such requests should be directed to the client organisation (the data controller), who will process the request through the DSAR workflow in accordance with applicable law.

10. Contact

For privacy-related enquiries, please contact us at privacy@buffrcheckpoint.com or through our contact page.