Legal

Privacy notice

LMNR Group (Pty) Ltd, trading as Averin · Effective 15 October 2026 · Version 1.0

This notice explains how we handle personal information under the Protection of Personal Information Act 4 of 2013. It covers two different relationships, and the difference matters: we decide how we use information about our customers, but we only act on instructions when it comes to information about their debtors.

1. Who we are

LMNR Group (Pty) Ltd is a private company registered in the Republic of South Africa under registration number 2026/828138/07, trading as Averin. Our registered office and place of business is 11 Olievenhoutbosch Road, Highveld, Centurion, Gauteng, 0144.

Our Information Officer can be reached at lu@averin.co.za, or by post at the address above.

2. The two kinds of information we handle

Information about our customers. When a bookkeeper, accounting firm or business signs up, enquires or corresponds with us, we are the responsible party. We decide why and how that information is used.

Information about our customers' debtors. When a customer loads a debtors book, we are an operator in terms of section 20 of the Act. The customer remains the responsible party. We process that information only on their documented instruction, under a written operator agreement as section 21 requires. If you are a debtor and want your information corrected or removed, the business that owes the relationship to you is the right place to start, and we will support them in answering you.

3. What we collect

From customers: name, work email address, company name, telephone number, the content of correspondence with us, and billing details.

From a loaded debtors book: the debtor's account name, contact person, email address, telephone number, amount outstanding, days overdue, invoice reference and preferred language. As we work the book we also generate records of each message sent, each call placed, call recordings and transcripts, replies received, and the outcome of each contact, including any payment commitment and its date.

We do not collect special personal information as defined in section 26 of the Act, and we do not ask for bank account credentials or connect to any bank feed.

4. Why we process it, and on what basis

For customers, we process information to provide the service, to bill for it, to support you and to respond to enquiries. The basis is performance of our contract with you and, for enquiries, your consent in approaching us.

For debtor information, the basis is that processing is necessary for the legitimate interests of the responsible party in recovering a debt lawfully owed to them, as contemplated in section 11(1)(f) of the Act, and for the performance of the contract between us and our customer.

5. Calls are recorded

Outbound calls placed through the service are recorded so that outcomes can be verified, disputes resolved and the audit trail kept complete. The recipient is told at the start of the call that it is an automated call and that it is being recorded.

6. Who else handles the information

We use the following operators to deliver the service. Each is bound to process information only on our instruction and to keep it secure.

We do not sell personal information, and we do not share it with anyone for their own marketing.

7. Information leaving South Africa

Because the operators above are located outside the Republic, personal information is transferred across the border. We rely on section 72(1)(a) of the Act: each recipient is bound by a written agreement that upholds principles for lawful processing substantially similar to those in the Act, and that places the same restrictions on onward transfer. A copy of our sub-processor terms is available to customers on request.

8. How long we keep it

Customer records are kept for the life of the account and for five years afterwards, which matches the retention period in the Companies Act and the Tax Administration Act for records of this kind. Debtor records and call recordings are kept for the period the customer instructs, and are deleted or returned when the operator agreement ends. Where a record is needed as evidence in a dispute or legal proceeding, it is kept until that matter is resolved.

9. How we protect it

Access to the application requires authentication. Information in transit is encrypted. Access to production data is limited to people who need it to run the service. We review these measures as the service grows, as section 19 requires. If a security compromise affects your personal information, we will notify the Information Regulator and the people affected as soon as reasonably possible, in line with section 22.

10. Your rights

You may ask us what personal information we hold about you and request a copy, under section 23. You may ask us to correct or delete information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully, under section 24. You may object to processing on the grounds set out in section 11(3). You may withdraw consent where our processing rests on consent.

Write to lu@averin.co.za and we will respond within a reasonable period. A request for access under the Promotion of Access to Information Act 2 of 2000 is made on Form 2 and may carry a prescribed fee.

11. Complaints

If you are not satisfied with how we have handled your information, you may complain to the Information Regulator of South Africa:

Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
PO Box 31533, Braamfontein, Johannesburg, 2017
complaints.IR@justice.gov.za
inforegulator.org.za

12. Changes to this notice

We will post any change on this page and update the version and date at the top. Where a change materially affects how we use your information, we will tell customers directly.

Questions about this notice go to lu@averin.co.za.