Privacy Policy – Gutsy Community

Effective date: 21 October 2026

Gutsy is owned and operated by Gutsy (Pty) Ltd (registration number 2024/683273/07), a private company registered in South Africa. When we say “we”, “us”, “our” or “Gutsy” in this policy, we mean Gutsy (Pty) Ltd. Under the Protection of Personal Information Act, 2013 (“POPIA”), Gutsy (Pty) Ltd is the “responsible party” for the personal information described in this policy.

This page explains what personal information we collect when you use the Gutsy website (gutsy.global), the Gutsy mobile app, and our related services, events and communications (together, our “Service”), why we collect it, who we share it with, and the choices and rights you have. We will not use or share your information with anyone except as described in this Privacy Policy. We do not sell your personal information.

Who we are and how to contact us

Responsible party: Gutsy (Pty) Ltd, registration number 2024/683273/07
Registered address: Block F, Belvedere Office Park, Bella Rosa Street, Bellville, Western Cape, 7530, South Africa
Information Officer: Johannes Adolf Kleinhans (Adolf Kleinhans)
Privacy email: [email protected]

Deleting your account and your data

At Gutsy we take your data protection seriously and want you to stay in control of your data. If you no longer want to use Gutsy, or you want us to remove the data in your account, you can do it yourself. Log in to your account, go to your account settings, and choose “Delete Account”. This deletes your account, your profile and contact details, the content you created (such as posts, comments, photos and journal entries) and the account data stored on our servers.

Please note:

Deleting your account is permanent and cannot be undone.
If you subscribed through the Apple App Store or Google Play, deleting your Gutsy account does not cancel that subscription. Please cancel it in your app store account as well.
We must keep some records even after you delete your account, for example payment and invoice records that tax and company law require us to keep, and records we need to resolve disputes or prevent fraud. We keep only what we need, for as long as the law requires (see “How long we keep your information”).
Copies may remain in our secure backups for a short period until those backups are overwritten in the normal course.

You can also ask us to delete your information by emailing [email protected].

What type of personal information do we collect

The most common types of personal information we collect are:

Account and profile information: your name, username, email address, mobile number, date of birth, password (stored in encrypted form), profile photo and anything else you add to your profile.
Membership and payment information: your membership level, subscription and transaction history, invoices and payment status. Card payments are handled by our payment providers; we do not see or store your full card number.
Health and fitness information (see the next section): for example your weight and other body measurements, workout and challenge progress, journal entries, nutrition information, and, if you choose to connect a wearable device or health app, activity and health data from that device or app.
Community content: posts, comments, photos, videos, messages, reactions and other content you share in groups, forums and activity feeds.
Event and booking information: tickets you buy or reserve, attendance, indemnity forms you complete, and details you give us for events, hikes and partner sessions.
Communications: support requests, feedback, survey and form responses, and messages you send to us or to Honey Badger, our AI assistant.
Device, usage and log data: your IP address, device type and operating system, app version, browser type, the pages and features you use, the dates and times of your visits, referring websites, push-notification tokens, and crash and diagnostic information.
Marketing preferences: whether you have subscribed to or unsubscribed from our newsletters and emails, and whether you open or click them.

Health and other special personal information

Some of the information you can choose to give us, such as your weight, body measurements, fitness, nutrition, pregnancy or post-pregnancy status, and data from wearable devices and health apps, is information about your health. POPIA treats health information as “special personal information” and gives it extra protection.

We only process your health information with your consent, and only to provide the features you choose to use, such as progress tracking, programs, challenges, workout recommendations and Honey Badger’s answers. Connecting a wearable device or health app is optional, and you can disconnect it at any time in the app or in your device settings. We do not use your health information for advertising, and we do not share it with other people except our service providers who help us run the Service, or where you ask us to (for example when you book a session with a partner dietitian or coach). You can withdraw your consent at any time by disconnecting the device, deleting the information, or contacting us. Withdrawing consent does not affect processing that already happened.

We do not ask for your race, religion, political opinions, biometric information (such as fingerprints or face scans) or criminal history. Please do not share this kind of information in public community spaces.

How we collect personal information

We collect personal information:

Directly from you, when you register, buy or renew a membership, buy event tickets, fill in a form, complete an indemnity, enter a challenge or competition, subscribe to our newsletter, post in the community, use the journal or trackers, chat to Honey Badger, or contact us.
Automatically, as you use the website and app, through cookies, similar technologies and server logs.
From third parties you connect, such as a wearable device or health app you link to Gutsy, or a social account (such as Facebook) you use to sign in. We only receive the information you allow that service to share.
From our payment providers and app stores, who tell us whether a payment or subscription succeeded.

If you choose not to provide personal information, we may not be able to provide you with our services and you may not be able to carry out transactions or use all the features of the Service.

Why we use your personal information

POPIA only allows us to process your personal information if there is a lawful reason. We use your information:

To provide the Service you signed up for (performing our contract with you): creating and running your account, giving you access to your membership, programs, courses, workouts, challenges, events and the community, processing payments, and providing support.
With your consent: to process health information and wearable data, to send you newsletters and marketing if you are not yet a customer, to send push notifications, and for any other purpose we ask your consent for.
For our legitimate interests, where these are not outweighed by your rights: keeping the Service safe and secure, preventing fraud and abuse, moderating community content, understanding how the Service is used so we can improve it, and telling existing members about similar Gutsy products and services (you can opt out at any time).
To comply with the law: keeping tax and accounting records, responding to lawful requests from authorities, and protecting our legal rights.

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects on you.

Community content is visible to other members

Gutsy is a community. Your profile, and the posts, comments, photos and other content you share in groups, forums and activity feeds, can be seen by other members (and, for content in public areas, possibly by visitors). Please think carefully before sharing personal details, especially health information, in community spaces. Your private journal entries and progress trackers are not shown to other members.

Honey Badger, our AI assistant

When you chat to Honey Badger, the messages you send are processed by a third-party AI model provider to generate answers, and this may take place outside South Africa. Honey Badger gives general information only and is not medical advice. Please avoid sharing information you do not need to share, such as your ID number or detailed medical history.

Direct marketing

We send newsletters and marketing emails only:

if you have given us your consent, or
if you are an existing member, about similar Gutsy products, services and events, as POPIA allows.

Every marketing email includes an easy way to unsubscribe, and you can also email us to opt out. We will still send you messages about your account, payments and important changes to the Service, because these are not marketing.

When may we disclose your personal information?

We may disclose personal information to:

Service providers (called “operators” under POPIA) who process information on our behalf to help us run the Service. They may only use it to provide their services to us, must keep it confidential and secure, and are bound by written agreements or their own data-protection terms. The main ones are listed below.
Our professional advisers (lawyers, accountants, auditors, financial advisers).
Event, coaching and nutrition partners, but only the details needed and only when you sign up for or book their session or offer.
Regulators, government authorities, courts and law enforcement, where the law requires or allows it.
A purchaser or prospective purchaser of all or part of our business or assets, and their professional advisers, under confidentiality obligations, in connection with the sale.
Other people where you have asked us to or have given your consent, or where we are authorised or required by law to do so.

Our service providers

We use carefully selected service providers (called “operators” under POPIA) to run the Service, in these categories: website and app hosting, security and content delivery; mobile app services such as notifications; payment processing (including the Apple App Store and Google Play for in-app subscriptions); email and communications; the AI service behind Honey Badger; media and podcast hosting; and accounting. They may only use your information to provide their services to us, must keep it confidential and secure, and are bound by written agreements or their own terms to do so. Payment providers handle your card details under their own privacy policies; we do not store your full card details.

Sending information outside South Africa

Some of our service providers store or process information outside South Africa, for example in the European Union and the United States. When this happens, we make sure, as section 72 of POPIA requires, that the recipient is subject to laws, binding rules or a written agreement that give your information a level of protection substantially similar to POPIA, or that the transfer is otherwise allowed under POPIA (for example because it is necessary to provide the Service you asked for, or you have consented).

How do we store and protect your personal information?

We store personal information on secure servers managed by us and our service providers. We use reasonable technical and organisational measures to protect it, including encrypted connections (HTTPS), encrypted password storage, firewalls and security monitoring, access controls so that only authorised people can see personal information, and keeping our software up to date. Any paper records, such as signed indemnity forms, are kept in a secure location.

No system is completely secure. If we have reasonable grounds to believe that your personal information has been accessed or acquired by an unauthorised person, we will notify you and the Information Regulator as POPIA requires.

How long we keep your information

We keep personal information only for as long as we need it for the purposes in this policy, or as long as the law requires:

Account, profile and community content: while your account is active. When you delete your account, it is removed from our live systems, and copies in backups are overwritten in the normal course.
Payment, invoice and accounting records: for the periods required by South African tax and company law (generally five to seven years).
Marketing records: until you unsubscribe, after which we keep only a record of your opt-out so that we do not contact you again.
Support requests, forms and indemnities: for as long as needed to deal with the request or event and any claims that could arise from it.

After this, we delete the information or de-identify it so that it can no longer be linked to you.

Children

Gutsy is meant for adults. You must be 18 or older to create an account. Under POPIA, a child is anyone under 18, and we do not knowingly collect personal information from children without the consent of a parent or guardian. If you believe a child has given us personal information, please contact us and we will delete it.

Your rights and how to access your personal information

You can see and update much of your information by logging in to your Gutsy account. Under POPIA you also have the right to:

ask whether we hold personal information about you, and ask for a copy of it;
ask us to correct, update or delete information that is inaccurate, out of date, incomplete, excessive or unlawfully obtained;
object to us processing your information for our legitimate interests, and object to direct marketing at any time;
withdraw your consent where we rely on it;
not be subject to decisions based solely on automated processing that significantly affect you; and
complain to the Information Regulator.

To exercise these rights, email [email protected]. We may need to confirm your identity first. We will respond within a reasonable time and will not charge you for simple requests. You can also request records under the Promotion of Access to Information Act, 2000 (PAIA) by contacting our Information Officer.

Cookies and web analytics

Cookies are small files that a website stores in your browser. We use them to keep you logged in, remember your preferences, keep the Service secure, speed up the site, play embedded videos and understand how the Service is used. For more general information about cookies, see allaboutcookies.org.

The cookies we use fall into these groups:

Essential cookies, which the website needs to work, such as cookies that keep you logged in, keep your session and membership checkout working, and protect the site against attacks.
Preference and performance cookies, which remember your settings and help pages load faster.
Third-party cookies, set by services embedded in our pages, such as YouTube and Vimeo videos and our payment provider, under their own policies.
Analytics cookies, which help us understand which pages and features are used so that we can improve the Service.

Cookies, together with our server logs, may record information such as your IP address, browser and operating system, the pages you visit, the date, time and length of your visit, and the website that referred you. Because some of this information, such as your IP address, can identify you, we treat it as personal information under this policy.

You can set your browser to refuse all cookies or to tell you when a cookie is being sent. If you block essential cookies, some parts of the Service, such as logging in, may not work.

Log data

When you use the Service, our servers and service providers automatically record log data such as your IP address, device and browser information, the pages and features you use, and the date and time of each request. We use this data to run, secure and fix the Service, and to understand how it is used so that we can improve it. Where we use third-party analytics or diagnostic tools to help with this, those providers act as our operators and also have their own privacy policies.

Changes to this policy

We may update this policy from time to time. We will post the new version on this page with a new effective date and, if the changes are significant, tell you by email or in the app.

How can you contact us

If you have any questions about our privacy practices, want to exercise your rights, or have any concerns about how we have handled your personal information, please contact our Information Officer:

Email: [email protected]
Post: The Information Officer, Gutsy (Pty) Ltd, Block F, Belvedere Office Park, Bella Rosa Street, Bellville, Western Cape, 7530, South Africa

If you are not satisfied with our response, you have the right to complain to the Information Regulator (South Africa):

Website: inforegulator.org.za
Complaints: [email protected]
General enquiries: [email protected], 010 023 5200
Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191