What we collect, why, who sees it, and your rights.

1. Who is responsible for your information

Firearmdesk is a trading name of Attestra Tech (Pty) Ltd, registration number 2026/296939/07, whose address for legal service is 97 Davidson Road, George, Western Cape, 6529. Email support@firearmdesk.co.za, telephone 081 770 2885.

The Information Officer is Wayne de Jager, reachable at the address above.

2. What we collect and where it comes from

From the referring firm, when it submits a referral: the firm's name, the referrer's name, email address, mobile number, role and internal file reference. Supplying the referrer's contact details and the name of the deceased is required to open a matter; without them we cannot act. Everything else is voluntary at referral and the portal tells you what is needed at each stage.

From a dealer signing up as a custody partner, on the sign-up page: the business’s registered and trading names; its company registration number or, for a sole proprietor, the owner’s identity number, which is encrypted at once; its VAT number, the address of its licensed premises, its dealer’s licence number, and the type and approximate capacity of its storage; the signer’s full name, capacity, email address and mobile number; and the record of acceptance: the version of the agreement and its fingerprint, the ticks, the typed name and capacity, the version of this notice, the time, IP address and browser at the start and at signing, and the code we email. A signed sign-up is kept unchanged as the record of the agreement; one that is not completed expires after 30 minutes and is deleted 12 months after it was started. Our emails to you about a sign-up carry no business or premises name.

From a family member who asks us to phone them, on the family page: their name, mobile number and, if they give one, email address; how they are related to the person who died, the province, the number of firearms and who is handling the estate; the time that suits them, any message they write and the advert they came from, which we use to phone them back about the estate.

About the estate: the name of the deceased, the date of death, the Master's reference (the estate's file number at the Master of the High Court), the province, the estimated number of firearms, where they are and who has possession, and which documents exist. Information about a person who has died is estate information rather than personal information in law; we protect it with the same care.

About the executor: name, email address and telephone number, supplied by the referring firm, which acts for the estate. We ask the firm, in its acknowledgement, to tell the executor that the matter has been referred and where this notice is; every email we send, including the executor's invitation, links to it. Executors confirm their details when they first sign in and may correct their name and telephone number in the portal; to change the email address, ask the firm or write to us.

During the matter: letters of executorship or authority, identity evidence of the executor, firearm licences and cards, firearm descriptions, serial numbers and photographs, valuation reports, the executor's signed instruction and, where a sale or transfer follows, the details of the buyer or heir and the account that receives sale proceeds.

From a permitted transporter we book: the names of the staff who will collect or deliver the firearms, as its permit and the delivery papers require, so that the custody site can check them at its register.

Automatically: the IP address, browser type and time of each sign-in, secure-link and signing event, and of the actions you take in the portal, which we record as evidence of who did what and when.

3. Why we use it and on what basis

• To open, administer and close the firearm matter the firm referred: verifying the executor's authority, arranging licensed custody, valuation, the executor's instruction and the closure pack. Basis: the referral by the firm on the estate's behalf, and the duties that the Administration of Estates Act 66 of 1965 and the Firearms Control Act 60 of 2000, with its regulations on dealer and custody records, place on the estate, the executor and the custodian.
• For the executor's details supplied by the firm: the firm's referral on the executor's behalf and the estate's legitimate interest in lawful administration (section 11(1)(f) of POPIA), then the executor's own confirmation once invited.
• To keep the records the law and the estate require: chain-of-custody receipts, the audit trail, invoices and settlement statements. Basis: legal obligation and the legitimate interests of the estate, the firm and the custodian.
• To conclude and keep the custody partner agreement with a dealer who signs up, to check the licence, the signatory and the acceptance, and to contact the dealer about onboarding. Basis: performing a contract the dealer asked for, and our legitimate interest in proving the agreement (sections 11(1)(b) and (f) of POPIA).
• To phone back a family member who asked us to on the family page, and to understand which advert brought the request. Basis: the person’s own request and the consent they give by ticking the box on the form (section 11(1)(a) and (b) of POPIA). We use the details only to phone them about the estate’s firearms, never for marketing.
• To send status notifications and secure links by email. Basis: performance of the service.
• To protect the platform and its users: sign-in security, rate limiting, malware scanning of uploads and the audit trail. Basis: legitimate interest and legal obligation.
• To count visits to the public pages and see which pages and referring websites are useful (section 9). Basis: our legitimate interest in running and improving the site.

We may contact firms about the service by telephone or post. We email a firm about the service only if it asked, or agreed when we asked once, and every such message says how to opt out. We never market to executors, heirs or buyers. No decision with legal effect is taken about anyone by automated means alone.

4. Who receives it

• The referring firm, for its own matters only.
• The executor, for the matter they are invited to.
• The licensed custody site allocated to the matter, for the firearms it receives, and the valuer briefed on them. They see what they need for their part and never a firm's other matters. Where the executor moves the firearms, the new custody site receives the same.
• A permitted transporter we book for the estate, for the firearms it carries: what its permit and the consignment note require, and the names and contact details of the people it collects from and delivers to.
• Buyers, heirs and their licensing steps, only where the executor's signed instruction leads there, and only what that step requires.
• The South African Police Service, the Central Firearms Registry, the Master of the High Court or a court, where the law requires it, a notice or report calls for it, or the executor's instruction leads to an application. External steps are recorded as waiting states with the evidence of what was submitted.
• Our hosting and email provider, including the encrypted nightly backup (section 6). Providers act on our instructions and do not use the information for their own purposes.

We do not sell personal information, share it with marketers, or use third-party analytics or advertising services. Page statistics are kept on our own server (section 9).

5. What never goes by email

Notifications are plain text without attachments and carry status and secure links only. Firearm serial numbers, identity numbers, identity documents, photographs and matter documents are held in the secure portal and viewed there; the templates refuse any variable named for a serial or identity number, so this is enforced by the software as well as by policy. Every email links to this notice.

6. Where it is kept and cross-border transfer

The platform, its database, document storage and email run on a server operated for us by Hetzner Online GmbH in Helsinki, Finland, and an encrypted copy is backed up each night to separate Hetzner storage in Germany. Hetzner is subject to the General Data Protection Regulation, a law that upholds principles substantially similar to those of POPIA and restricts onward transfer, and processes the information under a written data processing agreement with us (sections 21 and 72(1)(a) of POPIA). Information does not leave Hetzner’s environment except to the recipients in section 4.

7. How it is protected

• Encryption in transit on every connection; documents are served through signed links that expire within minutes.
• Every uploaded file is scanned for malware before any firm, executor or partner user can open it; a file that fails the scan is never served.
• Uploaded documents, photographs and generated documents are encrypted at rest, and so is the nightly backup; identity numbers and sign-in secrets are sealed in the database.
• Access is scoped to the firm and the matter on the server, not only in the screen.
• Two-factor verification for administrative, finance, compliance and custody-management roles, with step-up verification for actions that need two people; executors sign in by secure link and one-time code, without a password.
• An append-only audit trail enforced in the database: records are corrected by adding a new entry, never edited or deleted in place; at the end of the retention period only the personal details and files named in section 8 are removed.
• Internal storage positions are seen only by custody-site staff and platform operations. Firms see a custody region. The depositor (the executor, or a section 21 holder who deposits before letters) sees the custody partner's trading name and premises address on the portal; the person who delivers has them on the delivery papers, as do the permitted transporter that collects a firearm from the partner for a surrender or a move and, on a move, the custody partner receiving it; the person a release instruction names is given them for the collection; Firearmdesk's insurers and brokers receive them in confidence, and the Registrar's notices state them; never by email or SMS.
• When a password is set, a partial hash of it is checked against a public breach database (k-anonymity); no personal information is sent.

These controls are described on the security and chain of custody page.

8. How long we keep it

The records of a matter are kept for five years after it closes, or ten where it had exceptions, waivers or a legal hold. Invoices, payments and settlement records are kept for eight years from their own date, or until the matter’s ten years end if later (Companies Act, Tax Administration Act and VAT Act), and longer while a SARS audit or a dispute is open, so a matter’s period never ends sooner than eight years after its last financial record. The documents themselves are destroyed as described below.

At the end of the period the personal details of the living people on a matter are removed and the records stay. No matter record is deleted; the only things destroyed are the files this section names. What is removed: email addresses, phone numbers, identity numbers, addresses, the network address and browser recorded against actions on the matter, and the contents of messages we sent; the executors’ identity documents, and the copy of each recipient’s licence or identity document uploaded with an instruction, are destroyed from storage. What stays, because the law or the chain of custody needs it: the deceased’s details, the estate and its references, the firearm, custody, receipt, release, valuation, instruction, invoice, settlement and mandate records, the names on them (for the further period described below), and the audit trail.

Signed documents (mandates, delivery and surrender authorities, the heirs’ approval, consents, receipts and release records, and the next-of-kin affidavit) are kept unaltered as the evidence of what was signed, with the identity copies attached to a hand-signed authority. An identity number, address or signing detail printed in one stays in that signed copy until it is destroyed ten years after the last custody event, or ten years after closure where no firearm entered custody, the period a dealer keeps its register. The names on signed documents and custody records are kept for the same ten years; after that the names of the living people on them are removed from our database, whose records stay, and the signed documents themselves are destroyed. Copies of police and Registrar authorisations and notices, the Master’s letters and approval, the will and the death certificate are kept with the custody record as the proof of authority to hold, and are reviewed when the ten years end; other papers on the file that are not listed here stay as part of it.

Invoices, credit notes, settlement and storage statements and payment evidence are financial records: the document is kept for eight years from its date, or until the end of those ten years if that is later, and is then destroyed. The payer’s name on an invoice, payment or charge record, usually the estate’s, is kept with that record for eight years from its date, longer only while an audit, a dispute or a claim needs it, and is then removed.

Nothing in this section, other than the routine deletions below, is removed while a legal hold, a claim, an incident, an unpaid charge, an open enquiry by the police, the Registrar, the Master or SARS, or an heir who is a minor needs the record, or while another matter of the same estate or the same person is still open. Each removal described in this section, except the routine deletions below, is proposed by the system, approved by two of our people and recorded. Backups age out within twelve months, and a restored backup has every removal and every account closure described in this section applied again.

A portal account is separate from a matter. An executor’s or heir’s account is closed once it has not been used for 24 months and the person has no open matter; the 24 months run from the later of the last sign-in and the day the person’s last matter closed. The sign-in email address, name and phone number are removed, and the sessions, two-step sign-in codes and passkeys end. The copies of those details on a matter’s records go at the end of that matter’s period. The accounts of a custody partner’s or transporter’s people are closed five years after the person is removed or the partner’s agreement ends, unless the partner has a statement still to be paid, a claim, dispute or hold on something the person handled is open, or the person recorded the custody of a firearm that is still within its ten years. The record that an account existed, and the audit trail of what was done with it, stay.

Some records are deleted routinely, without approval, unless we need them to deal with an incident, a claim or an investigation: sign-in attempts after 90 days, a sign-in session 30 days after it ends, and the technical copy of each notice we receive from a payment or other service provider after 12 months. The network address and browser recorded in the audit trail against a sign-in or an account action are removed after 12 months; the entry itself stays. The one exception to this removal is the record of an approval or acceptance whose network address and browser are kept nowhere else, such as the approval of a legal rule or a confirmation of identity before a sensitive action; those keep their network details for as long as that record is kept. Custody partners keep their own registers for the period the Firearms Control Regulations set for them.

A request to be phoned from the family page is kept for 12 months after we close it or, if it is never closed, 12 months after the last thing done on it. Then the name, mobile number, email address, message, the name of the firm or bank handling the estate, the network address, browser and advert click number on the request, the notes we made about the call, and the name and number in the alerts we sent our own staff about it, are removed. We keep the date, the province, how the person is related, the number of firearms, who is handling the estate, the time that suited them and the advert it came from, so that we can see which adverts work. A request is not part of a matter; if an estate does come to us, the executor’s details are kept as this section describes. If the family phones again they can send the form again.

The signed agreements of custody partners and transporters, and the signatories and the licence and identity copies uploaded with them, are kept while the agreement runs and for a further period after it ends. We will state on this page, before the first of them is due, how long.

9. Cookies and page statistics

The public site sets no cookies. Signed-in users receive one session cookie, which is essential and is not used for tracking. Staff who choose to remember a browser after two-factor verification receive a second, essential cookie for thirty days. There are no analytics, advertising or social-media cookies.

We count visits to the public pages with Umami, open-source analytics software that runs on our own server (section 6). It sets no cookies and stores nothing on your device. For each visit it records the page, the referring website, the browser, operating system and device type, and an approximate location (country, region and city) derived from the IP address; the IP address itself is not stored. Visits on the same day are grouped under an anonymous identifier that changes daily, so a visitor cannot be followed from one day to the next. We also count when a referral or partner application is submitted, without any of its contents. The portal and every sign-in and secure-link page are not counted, and browsers that send a Do Not Track signal are not counted at all. The statistics are used only in aggregate and are not shared.

10. Your rights

You may ask what personal information we hold about you, ask for it to be corrected or, where the law allows, deleted, object to processing based on legitimate interest, and withdraw consent where consent is the basis. Some records must be kept even after an objection, for example a signed instruction or a chain-of-custody receipt, and we will tell you when that applies and what is kept and why. Information we are no longer allowed to keep is removed when you ask, without waiting for the end of the period (section 8). Write to the Information Officer at support@firearmdesk.co.za; we respond within the time POPIA allows and usually much sooner. A request for access to a record under the Promotion of Access to Information Act follows our PAIA manual.

You may also complain to the Information Regulator (South Africa): Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191; P.O. Box 31533, Braamfontein, 2017; telephone 010 023 5200 or 0800 017 160; complaints through eservices.inforegulator.org.za or POPIAComplaints@inforegulator.org.za; inforegulator.org.za.

11. Changes

We will change this notice when the service or the law changes. Each revision is shown on this page with its date, and account holders are told of a material change by email.