Privacy Notice
How CubVest collects, uses and protects information about parents, guardians and children — written to be read, not skimmed past.
Pre-launch draft. CubVest is in final development and not yet publicly available. This privacy notice will be finalised after legal review before public launch.
01Who we are
CubVest is a family financial-learning platform. It is a product of AdGawk (Pty) Ltd (registration number 2023/813936/07), 257 Albertus Street, La Montagne, Pretoria, 0184, South Africa (“AdGawk”, “CubVest”, “we”, “us”). For the purposes of POPIA, AdGawk is the responsible party for the personal information described in this notice.
CubVest is designed to process personal information in accordance with applicable South African data-protection requirements, including the Protection of Personal Information Act 4 of 2013 (POPIA).
CubVest is currently in final development and testing and is not yet publicly available. This notice covers the waiting list and website today, and the complete CubVest service once it launches.
02Information we collect
Waiting-list information
When you join the waiting list, we collect your email address, the plan you showed interest in (if any), the page you signed up from and the date and time of your request.
Parent and guardian information
When you create a CubVest account, we collect information such as your name, contact details and login credentials, and the settings you choose for your family. Where the law or our payment providers require it for real-money features, you or our payment providers may need to verify your identity.
Child information
A parent or guardian sets up each Cub’s profile. We collect only what the service needs, such as a first name or nickname, age or age range, and profile preferences. See Children’s personal information.
Account information
Details about how your family account is set up: linked Cub profiles, the plan you’re on, parent controls and approvals, approved friends and security settings such as PINs (which we store in a protected form).
Wallet and transaction information
Practice-money balances and activity on every plan. On Plus and Premium, real-money information such as wallet funding, transfers to your Cubs, allowances, Spend, Save and Give activity, CubCard and Scan-to-Pay transactions (for example amount, date and merchant) and withdrawals. Payment card details you enter to fund your wallet or pay for a subscription are processed by Paystack.
Learning, missions, goals and achievements
Missions and rewards, goals, achievements and XP, Growth Path progress, FutureScore, Money Lab and Learning Library activity, and Investment Playground activity, which uses simulated money only.
CubGuide
CubGuide is CubVest’s educational assistant. When your Cub or you use CubGuide, we process the questions asked and the answers given so the feature works, stays age-appropriate and can be improved. If CubGuide relies on a third-party technology provider to produce answers, we will name that provider in this notice before CubVest launches.
Subscription and billing information
Your plan, billing status, payment references, cancellation and refund requests. Subscription payments are processed by Paystack.
Technical information
Information your device sends when you use the website or app, such as IP address, browser or device type and basic logs needed to run and secure the service.
Messages you send us
If you email us, we keep the message and our reply so we can help you.
03How we use information
We use personal information to:
- run the waiting list and tell you when CubVest is ready;
- create and manage family accounts, Cub profiles and parent controls;
- provide wallets, practice money and — on Plus and Premium — real-money features, together with our payment providers;
- deliver missions, goals, learning content, CubGuide, the Growth Path, achievements, XP and FutureScore;
- process subscriptions, billing, cancellations and refunds;
- keep CubVest safe, prevent fraud and misuse, and secure accounts;
- provide support and respond to requests;
- improve CubVest, using information that is aggregated or de-identified where practical;
- meet our legal and regulatory obligations.
We process personal information where you have consented (including a parent or guardian’s consent for a child), where it is needed to provide the service you asked for, where the law requires it, or where it is in our legitimate interests and those interests are not overridden by yours.
04Children’s personal information
The short version
A parent or guardian is always in charge of a child’s CubVest profile. We collect as little about children as the service needs, we never sell it, and we don’t use it for third-party advertising.
CubVest is designed for children aged 5–17, used through a parent or guardian’s account. Children’s personal information is processed with the consent of a parent or guardian (a “competent person” under POPIA). Children should not create accounts on their own.
We do not sell children’s personal information, and we do not use it for third-party advertising. Parents and guardians can review, correct or delete their child’s information at any time — see Your rights.
05Parent and guardian involvement
CubVest is built on a simple idea: you set the boundaries. Parents and guardians create and manage Cub profiles, choose which features each Cub can use, approve friends for giving, and — on Plus and Premium — fund wallets and approve spending within the controls they set. Parents can see their Cubs’ activity and history.
06Third-party service providers
We share personal information only with service providers who help us run CubVest, and only what they need. They may use it only to provide their services to us or as their own terms and the law allow. We do not sell personal information.
| Provider | What they do for CubVest |
|---|---|
| Paystack | Parent wallet funding, subscription payments and billing, and withdrawals from the platform. |
| iKhokha | CubVest Scan-to-Pay. |
| FormSubmit | During the pre-launch and beta period, delivers waiting-list form submissions (your email address and form details) to hello@cubvest.co.za. |
| Google Fonts | Serves the typefaces used on our website. Your browser connects to Google’s servers, which receive technical information such as your IP address. |
| Hosting and infrastructure providers | Host and run the CubVest website and service, and store data. |
| CubCard | If CubCard functionality on Plus and Premium involves additional service providers, we will name them here before it is available. |
Paystack and iKhokha are payment service providers, not banks operated by CubVest, and their own terms and privacy notices also apply to the services they provide. We may also disclose information where the law requires it, to protect people’s safety, or in connection with a sale or restructuring of our business, subject to this notice.
07International processing
Some of our service providers may process information outside South Africa. Where that happens, we take steps required by POPIA, such as relying on providers subject to adequate data-protection laws or binding agreements.
08Analytics
The CubVest website does not currently use analytics tools such as Google Analytics. If we add analytics in future, we will update this notice and our Cookie Notice before doing so.
09Security
We use reasonable technical and organisational measures designed to protect personal information, such as limiting access to people who need it and protecting accounts with passwords and PINs. No system can be completely secure. If a security compromise affects your personal information, we will notify you and the Information Regulator as POPIA requires.
10How long we keep information
We keep personal information only for as long as we need it for the purposes in this notice, or as long as the law requires — for example, financial and transaction records may need to be kept for a set period. Waiting-list information is kept until CubVest launches and our launch updates end, or until you unsubscribe or ask us to delete it. When we no longer need information, we delete or de-identify it.
11Your rights
You have the right to:
- ask what personal information we hold about you or your child and request a copy;
- ask us to correct or delete it;
- object to certain processing, including direct marketing;
- withdraw consent, where we rely on it (this doesn’t affect processing that already took place);
- lodge a complaint with the Information Regulator (South Africa) — inforegulator.org.za.
To make a request, email our Information Officer at hello@cubvest.co.za. We may need to verify your identity first.
12Marketing communications
If you join the waiting list, we will email you about the waiting list, the product launch and related CubVest updates. Every marketing email includes a way to unsubscribe, and you can also email us to stop them. We do not send marketing messages directly to children.
13Cookies
Our Cookie Notice explains how the website uses cookies and similar technologies.
14Changes to this notice
We will update this notice as CubVest develops — including before launch, when the complete service and its providers are finalised. We will post the new version here with a new “last updated” date and, for significant changes, let you know directly.
15Contact us
Questions about privacy or this notice? Contact our Information Officer.
- Company
- AdGawk (Pty) Ltd
- Registration number
- 2023/813936/07
- Address
- 257 Albertus Street
La Montagne
Pretoria
0184
South Africa - hello@cubvest.co.za
- Information Officer
- Melodious Sakarombe
hello@cubvest.co.za