Last Updated: 16 November 2025
1. Introduction
This Privacy Policy describes how 420 Twig PTY LTD T/A Clubhub (“we,” “us,” or “our”) collects, uses, and protects the Personal Information of:
- Visitors to our main website (clubhub420.com).
- Our direct customers who register for a Subsite (our “Subsite Admins”).
- All End-Users who register for a “ClubHub Network Account” (“End-Users”).
We are the “Responsible Party” for the Personal Information described in this policy, as defined by South Africa’s Protection of Personal Information Act (POPIA).
This Policy vs. Your Club’s Policy
This policy explains what we (ClubHub) do with your data.
When you interact with a specific club’s Subsite (e.g., to pay for services), that Club is a separate “Responsible Party” for the data they collect (like your membership details or service requests).
You must read the specific Privacy Policy on that club’s Subsite. Our legal relationship with the Club is detailed in our Platform Terms of Service.
2. Our Information Officer
We have appointed an Information Officer to oversee our compliance with POPIA. You can contact them with any questions or concerns about your personal information.
- Email: info@420twig.com
- Subject Line: “POPIA Information Request”
3. Personal Information We Collect
We collect information in the following ways:
3.1. Information You Provide to Us (Subsite Admins):
- Account Information: Your name, your club’s name, email address, and phone number.
- Payout Information: Your nominated South African bank account details.
- Communications: Any information you provide when you contact us for support.
3.2. Information You Provide to Us (End-Users):
- Network Account Information: When you register, we collect your [e.g., full name, email address, and password]. This creates your “ClubHub Network Account” which you use across all Subsites.
3.3. Information We Receive from Clubs (End-Users):
- Member Verification Data: To verify your status, a Subsite Admin (your Club) provides us (as their “Operator”) with a list of their member data. We use this to connect your Network Account to your club membership to grant you access to exclusive content or “guest” status.
3.4. Information We Collect Automatically (All Users):
- Log Data: Our servers automatically record your IP address, browser type, operating system, and the pages you visit on our main website and platform.
- Cookies: We use essential cookies to keep you logged in, remember your preferences, and ensure the security of our platform.
- Transaction Data: We collect records of the transactions processed through Subsite stores for the purpose of calculating our Fulfilment Fee.
4. How and Why We Use Your Information (Purpose)
We process your Personal Information on the following lawful bases:
- To Perform Our Contract (Terms of Service) With You:
- (For Admins): To create and manage your Subsite Admin account, process payouts, and provide support.
- (For End-Users): To create and manage your “ClubHub Network Account” and provide you with single sign-on access to the Platform.
- (For All): To process transactions, calculate our Fulfilment Fee, and remit payouts.
- For Our Legitimate Interests:
- (For End-Users): To perform Member Verification. We process your registered email against the member lists provided by Clubs (our Customers) to determine your access rights (e.g., “Verified Member” or “Guest”) on their Subsite.
- To monitor the Platform for security threats and to prevent fraud or violations of our Acceptable Use Policy.
- To improve our Platform’s performance and features.
- To send you essential service-related announcements.
- To send you marketing communications about our own services, from which you can opt-out at any time.
- To Comply With a Legal Obligation:
- To maintain accurate financial records for tax and accounting purposes.
- To comply with any lawful request from a South African court or law enforcement body.
- With Your Consent:
- To send you marketing communications if you are not yet a customer.
- To place non-essential analytics or advertising cookies on your device.
5. Who We Share Your Information With
We do not sell your Personal Information. We will only share it in the following circumstances:
- Third-Party Service Providers (Our Operators): We share information with trusted third parties who process it on our behalf, such as:
- Payment Providers: To manage and process payouts.
- Cloud Hosting Providers: To host the Platform and store our data.
- Email & Comms Providers: To send you support and service emails.
- We have written agreements (Data Processing Agreements) with these providers to ensure they protect your data.
- Subsite Admins (Clubs): We share your Network Account Information (e.g., your name, email) with the Admins of the Subsites you choose to interact with. This is necessary for them to manage their Subsite and fulfill their service obligations to you.
- Legal Compliance: If required by law, subpoena, or court order, we may disclose your information to law enforcement or government authorities.
6. Security Safeguards (Section 19)
We take our duty to protect your Personal Information seriously. We implement appropriate, reasonable technical and organisational measures to prevent loss, damage, or unauthorised access to your data. These measures include:
- Encryption: Using SSL/TLS encryption for all data transmitted between you and the Platform.
- Access Controls: Limiting access to your Personal Information to only those employees or contractors who have a legitimate need to access it and are bound by confidentiality.
- Secure Infrastructure: Hosting our Platform with a reputable provider that maintains high-security standards.
- Data Breach: In the event of a data breach affecting your Personal Information, we will notify you and the Information Regulator as required by POPIA.
7. Data Retention
We will only retain your Personal Information for as long as is necessary to fulfil the purposes for which it was collected:
- As a Customer (Admin): We retain your data for as long as you have an active account with us, and thereafter for a reasonable period as required by law.
- As an End-User: We retain your Network Account data for as long as your account is active. If you delete your account, your data will be securely removed.
- After Termination: Your account data will be retained in accordance with our Platform Terms of Service (typically 30 days) before being securely deleted.
8. International Data Transfers
We may process and store your information in data centres outside of South Africa. If we do, we will only transfer your data to a country that provides an “adequate” level of data protection (such as the European Union) or under a binding agreement that ensures your data is protected to the same standard as POPIA.
9. Your POPIA Rights (Data Subject Participation)
You have the following rights regarding your Personal Information that we hold:
- Right to Access: You can request a copy of the Personal Information we hold about you.
- Right to Correction: You can ask us to update or correct any inaccurate or incomplete information.
- Right to Deletion: You can ask us to delete your Personal Information. We will do so unless we have a legal obligation to retain it.
- Right to Object: You can object to our processing of your information for direct marketing or on the basis of our legitimate interests.
- Right to Complain: You have the right to lodge a complaint with the South African Information Regulator:
- Email: complaints.IR@justice.gov.za
- Website: https://www.justice.gov.za/inforeg/
To exercise any of these rights (except complaining to the Regulator), please contact our Information Officer at info@420twig.com. We will need to verify your identity before processing your request.
NOTE: To exercise your rights over data held by your Club (e.g., your full membership file, your order history), you must contact the Club’s Information Officer directly, as listed on their Subsite’s Privacy Policy.
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on our website or by sending you an email.
11. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at:
- Company: 420 Twig PTY LTD T/A Clubhub
- Registration: 2022/585039/07
- Email: info@420twig.com
- Address: 944 Wekker Road, Moreleta Park, Pretoria, 0181