LegalPrivacy & POPIA

Your data is our responsibility.

xverified is a beneficiary tracing and verification platform of Lebon Consulting (Pty) Ltd. We respect your privacy and are committed to protecting your personal information. This policy explains how we collect, use, disclose and safeguard your information in line with the Protection of Personal Information Act (POPIA).

FSP No. 52013
POPIA-compliant
Reg: K2021570343

Registered Office

5th Floor, Bloukrans Building, 4 Daventry Street, Lynnwood Manor, Pretoria, 0081

Email

info@lebonconsulting.co.za

Telephone

012 745 8100

Last updated: 26 August 2026

01

Introduction

xverified (“the platform”) is a beneficiary tracing and verification platform of Lebon Consulting (Pty) Ltd (“we”, “us”, “our”). We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you interact with the xverified platform, our websites, and our business operations — whether as an institutional client, a platform user, or a person we trace or verify on behalf of a client.

02

Who we are

xverified is operated by Lebon Consulting (Pty) Ltd, a South African company (Reg: K2021570343) and authorised Financial Services Provider (FSP 52013). The platform helps pension funds, fund administrators, insurers, banks, estate administrators and law firms resolve identities, trace beneficiaries, and reconnect rightful claimants with unclaimed benefits.

Because of the nature of tracing, we often process personal information about people who are not yet our users — members, beneficiaries, dependants and heirs whose details are given to us by the institutions that owe them benefits. This policy covers that processing too.

03

Information we collect

We collect and process the following types of personal information:

Identity

  • Names & previous names
  • ID / passport numbers
  • Date of birth & life status

Contact

  • Email addresses
  • Telephone numbers
  • Physical & postal addresses

Family & beneficiary

  • Relationships & dependants
  • Marital status
  • Estate & next-of-kin details

Financial

  • Banking details for benefit payment
  • Unclaimed benefit records
  • Fund membership data

Employment

  • Employment history
  • Employer & fund records
  • Directorships (CIPC)

Technical & usage

  • Device information & IP addresses
  • Platform interaction patterns
04

How we collect information

We collect information through:

  • From institutional clients (funds, administrators, insurers, estate practitioners) who mandate a trace
  • Directly from you when you interact with us, verify your identity, or submit a claim
  • From registered credit bureaus and identity-verification services, where lawfully authorised
  • From public and official sources — CIPC, deeds, courts, published unclaimed-benefit registers
  • From automated technologies when you use the xverified platform
05

Our role under POPIA

As an operator

When an institutional client instructs a trace or verification, that client is the responsible party for its members’ and beneficiaries’ information, and we act as its operator. We process the case data only on the client’s documented instructions, under a written operator agreement, and with the security safeguards described in this policy.

As a responsible party

We are the responsible party for information we collect for our own purposes — platform accounts, enrichment of trace results from lawful sources, billing, security, audit records, and improving the platform. This policy governs that processing directly.

06

How we use your information

We use personal information for the following purposes:

Beneficiary tracing

Locating members, beneficiaries and heirs entitled to unclaimed benefits.

Identity verification

Verifying that a claimant is the rightful beneficiary before benefits are paid.

Legal compliance

Meeting obligations under POPIA, FICA, the Pension Funds Act and FSCA conduct standards.

Audit & evidence

Producing auditable trace and verification records for our institutional clients.

Relationship management

Managing our ongoing relationship with clients and platform users.

Improvement

Improving our platform, matching accuracy and client experience.

08

Information sharing

We may share information with:

We are transparent about who has access to your data. We do not sell your personal information, and trace results are never made public.

  • The institutional client that mandated the trace

    Pension funds, fund administrators, insurers, banks, estate administrators and law firms receive trace and verification outcomes for the cases they instruct — and only those cases.

  • Verification & data partners

    Registered credit bureaus, identity-verification services and screening providers engaged under written contracts, used strictly to resolve and verify identities.

  • Regulatory authorities & government bodies

    The FSCA, Information Regulator, SARS, and other bodies where required by law.

  • Professional advisers

    Auditors, legal counsel, and compliance consultants engaged under confidentiality.

  • Third parties involved in corporate transactions with Lebon Consulting

    Only in the context of mergers, acquisitions, or restructuring — and only with appropriate safeguards.

09

Your rights under POPIA

POPIA · Your rights

Under the Protection of Personal Information Act, you have the following rights regarding your personal information — whether you are a platform user or a person we have traced:

Access your personal information

Correct your personal information

Request deletion of your personal information

Object to processing of your personal information

Lodge a complaint with the Information Regulator

Withdraw consent for processing

Where we process your information as an operator for an institutional client, we will refer your request to that client and assist it in responding.

10

Information security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, accidental loss, or damage.

AES-256 encryption at rest, TLS 1.3 in transit
Access controls & authentication
Immutable audit journal
Regular security assessments
Staff training on data protection
Data residency: Microsoft South Africa North
11

Retention period

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including legal, regulatory, and reporting requirements. Trace and verification records are kept as an auditable evidence trail for the periods required by FICA, the Pension Funds Act, and our institutional clients’ record-keeping obligations — typically five years after case closure — after which they are deleted or de-identified.

12

International transfers

Platform data is hosted in the Microsoft South Africa North region. Where personal information is transferred outside South Africa — for example to a specialised verification provider — we ensure adequate safeguards are in place in compliance with section 72 of POPIA.

13

Contact our Information Officer

Isaiah Mphaloane

Managing Director & Information Officer — Lebon Consulting (Pty) Ltd

14

Changes to this policy

We reserve the right to update this Privacy Policy at any time. Any changes will be posted on this page with an updated revision date. Your continued use of the xverified platform after such modifications constitutes your acknowledgment of the modified Privacy Policy.

15

Complaints

If you believe your privacy rights have been violated, you may file a complaint with us or with the Information Regulator:

This Privacy Policy was last updated on 26 August 2026. xverified is a platform of Lebon Consulting (Pty) Ltd, an authorised Financial Services Provider (FSP 52013).