Who we are
Steady Private Wealth (Pty) Ltd ("Steady", "we"), of Waterfall, Johannesburg, is responsible for your personal information under the Protection of Personal Information Act, 2013 (POPIA).
Write to our Information Officer at katleho.b.sebiloane@gmail.com about anything in this notice.
This notice covers this website, the online application and the Steady app, for applicants, members and advisors.
What we collect, and where it comes from
We collect only what we need to review your application and run your membership.
| What | Examples | From |
|---|---|---|
| Contact details | Your name, mobile number and email address | You |
| Identity | Your South African ID number, a photo of your ID, a selfie and proof of address | You; the result of the check comes from our identity-verification partner |
| Your finances | What lands in your account each month, what you owe and own, your business, three months of bank statements, payslips and business statements | You |
| Your credit report | Your report from a credit bureau | You, or our licensed partner with your consent |
| Your goals | What you want from coaching, in your own words | You |
| Your signature | Your typed name, the code we emailed you, and the time and document you signed | You |
| Your membership | Your plan, payees and their account numbers, payday runs, consents, Club 25 contributions, loans and votes, session notes, and documents you keep in your vault | You, your advisor, and our partner bank |
| Using Steady | Sign-ins, the device you sign in from, and a record of who opened sensitive details | Our systems |
We do not collect special personal information (such as health or religious beliefs) and we do not ask for it. Steady is for adults: we do not knowingly collect information about anyone under 18.
Why we use it
| Purpose | What we rely on (POPIA section 11) |
|---|---|
| Reviewing your application: confirming it is you, checking you can afford membership, matching you with an advisor | Taking steps you asked for before a contract; your consent for the credit report |
| Running your membership: your plan, payday runs, payments to your payees, your advisor's sessions, your vault | Our contract with you |
| Club 25: your stake, loans, the ledger and votes | Our contract with you and the club's constitution |
| Keeping records the law requires, and answering regulators | A legal obligation |
| Keeping Steady secure: sign-in codes, PINs, records of who opened your ID or account numbers | Our legitimate interest in protecting you and Steady |
A person decides every application. We do not decide anything about you by automated means alone. Payday runs are automated, but only on the plan you accepted and the mandate you signed.
We do not use your information for marketing, and we never sell it.
Who sees it
- Your advisor, and an advisor who reviews your application. Advisors see what they need for your plan and nothing about other members.
- Steady's team, where their role needs it. Each time someone opens your ID number or a payee's account number, we record who and when.
- Our partner bank, which holds your accounts in your name and runs payments on your mandate.
- Our identity-verification partner, which checks your ID and selfie.
- Our credit partner, a registered credit bureau or a licensed partner, which obtains your credit report with your consent.
- Our licensed financial services provider partner, only if you ask for advice on an insurance or investment product.
- Other Club 25 owners, who see the club's ledger, loans and votes, as the constitution requires. Your personal finances are not on the ledger.
- Our service providers: hosting (xneelo, in South Africa) and an email service that sends sign-in and signing codes. They work on our instructions under written agreements and may not use your information for anything else.
- Regulators and courts, where the law requires it.
Where it is stored
Your information is stored on servers in South Africa. If a service provider handles any of it outside South Africa, we only use providers bound by laws or agreements that protect it as POPIA does (section 72).
How long we keep it
| What | How long |
|---|---|
| Sign-in and signing codes | Never stored as the code itself; each one stops working after 10 minutes |
| A file you upload but never attach to your application | Deleted after one day |
| If you are not approved: statements, payslips and other documents | Deleted 30 days after the decision. You can reapply before then and keep them |
| If you are not approved: your ID number, ID photo, selfie and proof of address | Kept as your identity record for as long as the law requires |
| While you are a member | Everything your membership needs |
| After you leave | Identity, payment and Club 25 records for as long as the law requires, then deleted |
How we protect it
- Everything travels encrypted (HTTPS) and is stored encrypted, on servers in South Africa.
- Your ID number and payees' account numbers are encrypted again on their own, and every time someone opens them is recorded.
- Files are scanned for viruses when they arrive.
- You sign in with a one-time code, and your PIN opens the app and confirms every payment and consent.
- Each person at Steady sees only what their role needs.
If we learn that someone got to your information without permission, we will tell you and the Information Regulator as soon as we reasonably can (POPIA section 22).
Your rights
You can ask us, free of charge:
- what information we hold about you, and who has seen it;
- to correct anything that is wrong or out of date;
- to delete information we no longer need or are not allowed to keep;
- to stop using it where we rely on our legitimate interest;
- to withdraw a consent you gave. Withdrawing doesn't undo what we did before, and we may not be able to keep your membership running without it.
Write to our Information Officer at katleho.b.sebiloane@gmail.com. We reply within 30 days. You can see and change most of your details yourself in the app.
If you're unhappy with our answer, you can complain to the Information Regulator: inforegulator.org.za, POPIAComplaints@inforegulator.org.za.
The website and cookies
This website sets no cookies for tracking or advertising. When you sign in to apply, it sets one cookie to keep you signed in, and your browser remembers which step you were on. Your ID number and documents are never kept in your browser.
The website's font comes from Google Fonts, so your browser asks Google's servers for it, and Google sees your IP address.
Changes to this notice
We will post any change here with its date, and tell members in the app before it applies.
Last updated 21 October 2026