Tulpie Privacy Policy

This policy explains how Working Theory (Pty) Ltd, trading as Tulpie, collects, uses, shares and protects personal information when you use Tulpie. Tulpie includes the market admin dashboard, the vendor dashboard, the point-of-sale app and terminals, the website at www.tulpie.app, our quote and invoice pages, and the Tulpie AI connector.

We follow the Protection of Personal Information Act, 2013 (POPIA). In this policy, "we", "us" and "Tulpie" mean Working Theory (Pty) Ltd. "You" means anyone whose information we process: market organisers and admins, vendors, till operators and website visitors.

1. Who we are

Company: Working Theory (Pty) Ltd, trading as Tulpie
Registration number: 2026/554123/07
Address: 818 31st Avenue, Villieria, Pretoria, 0186, South Africa
Email: hello@tulpie.app
Information Officer: Lourens Ros, hello@tulpie.app

2. Tulpie and the market

Tulpie is bookkeeping software for markets with many vendors and a central point of sale. The market organiser decides which vendors, products and sales are recorded in Tulpie. For that market data, the market is the responsible party and Tulpie is its operator. We process the data on the market's behalf, to provide the service.

If you are a vendor and want to see, correct or delete what a market has recorded about you, please contact that market first. We will help the market respond. You can also contact us directly.

For accounts, billing, devices, the website and the AI connector, Tulpie is the responsible party.

3. What we collect

Accounts

Your email address and your password, which Firebase Authentication stores in scrambled form.
If you sign in with Google: the name, email address and profile picture that Google shares with us.
Which markets you belong to, and your role at each one: admin, vendor or point-of-sale account.

Market organisers and admins

Market details: name, dates, contact email, and the payment methods the market accepts (for example "cash" or "card").
The email addresses of the market's admins and point-of-sale accounts.

Vendors

Your stall or business name. Many vendors trade under their own name.
The email addresses linked to your stall.
The percentage of your sales that goes to the market.
Your products and prices.

Sales

For each sale at a market's point of sale we record:

the date and time
the items, their prices and the vendor of each
the payment method
the email address of the account that operated the till
an identifier of the device used

Quotes, invoices and payments

When an organiser buys Tulpie we collect:

the contact person's name, email address and phone number
the billing address and ID or company registration number
the market dates and pricing

When you pay online, PayFast sends us a payment notification. It includes your email address, the amount and fee, and PayFast's payment reference.

Devices and usage

Point-of-sale devices: the device name and model, and a Firebase installation identifier. For terminals that Tulpie rents out, we also record the serial number and hostname.
Connection status: whether a device is online, its platform, which app it's running and the account that's signed in.
Application logs: a record of actions taken in our apps and of any errors. Examples include recording a sale, adding or changing a vendor, and adding or removing an admin or point-of-sale account. Each entry records:
- the email address of the account that did it
- the time and platform
- the details of the change, which can include the names and email addresses of the vendors or accounts involved
We keep these as an audit trail of who did what, and use them for support and troubleshooting.
Crash and performance reports: technical details when an app crashes or runs slowly. These can include your user ID and, on point-of-sale devices, the market.
App and website analytics: how our apps and website are used, for example the pages you visit, your device and browser type, and your approximate location based on your IP address.
Server logs: your IP address, browser identifier and the time of each request.

AI connector

If you use the Tulpie AI connector, we record:

your email address and user ID
which AI apps you connected
which markets you asked about
when you used it

Feedback and forms

Your answers and, if you give it, your email address.

Device permissions

Our apps ask for these permissions, and use each one only for its feature:

Camera: to scan product QR codes.
NFC: to pair a point-of-sale device with a market.

4. What we don't collect

Shoppers: Tulpie does not record any personal information about people who buy at a market.
Card numbers: card payments at a stall are only labelled "card" in Tulpie. When you pay a Tulpie invoice online, PayFast handles your card or bank details, not us.
Precise location: we don't use your device's GPS.

5. How and why we use it

To provide Tulpie: running accounts, recording sales, working out what each vendor is owed, and showing dashboards, reports and exports. Basis: performing our contract with you or your market.
To pair and manage devices and keep Tulpie secure: verifying devices and apps, and blocking abuse and fraud. Basis: our legitimate interest in a secure service.
To keep an audit trail: application logs show who recorded or changed what, so markets and vendors can check and trust their records. Basis: our legitimate interest, and the market's, in accurate and accountable bookkeeping.
To fix problems and improve Tulpie: using crash reports, logs and analytics. Basis: our legitimate interest.
To send service emails: vendor welcome emails, product QR codes, password resets, quotes and invoices. Basis: performing our contract.
For billing, accounting and tax: Basis: contract and legal obligation.
To tell existing customers about Tulpie: we may occasionally email you about similar Tulpie products and services. Every message has an easy opt-out, or you can email us at any time. Basis: POPIA section 69(3), for existing customers.
To answer your questions and requests: Basis: our legitimate interest.
To comply with the law and protect our rights: including responding to valid requests from courts and authorities. Basis: legal obligation and legitimate interest.

We don't sell personal information. We don't use it for advertising or for automated decisions about you.

7. The Tulpie AI connector

Market admins and vendors can connect an AI assistant of their choice, such as ChatGPT or Claude, to their Tulpie account. The assistant can then answer questions about their sales. The connector is optional. It is currently available only to invited accounts.

Read-only. The AI cannot change anything in Tulpie.
Your role sets what the AI sees. Admins share figures for their whole market. Vendors share only their own sales.
What it shares:
- sales totals over a period
- vendor names and the market's percentage
- products and prices
- point-of-sale device names
What it never shares:
- email addresses or user IDs
- individual sales or who operated the till
- billing records
- logs
The AI provider's terms apply. What the connector returns goes to the AI provider you chose. That provider processes and keeps it under its own terms and privacy policy, which we don't control.
What we store: we keep a record of your use of the connector, described in section 3. We store only scrambled (hashed) versions of sign-in tokens.

To disconnect, remove the connector in your AI app or email us.

8. Transfers outside South Africa

Tulpie's database, files and server functions run on Google Cloud in the europe-west1 region in Belgium. Google, Porkbun, Zoho, Cloudflare and imgix may process information in other countries, including the United States.

Under POPIA section 72, we only use providers that meet one of two conditions. Either laws or binding agreements give your information protection comparable to POPIA, such as the EU's GDPR or the provider's data processing terms. Or the transfer is necessary to provide the service you asked for.

PayFast processes payments in South Africa.

9. How long we keep it

Market data (vendors, products and sales): while the market's Tulpie account is active. We delete it when the market asks, except where the law requires us to keep it.
Application logs: indefinitely, because they are an audit trail. You can ask us to delete or redact your information in them.
Connection status and AI connector records: while the related account is active. We delete them on request.
Quotes, invoices and payment records: for as long as South African tax and company law requires. This is generally five to seven years.
Server logs: about 30 days.
Analytics and crash reports: under the retention settings of the Google products we use.

10. Cookies and browser storage

Staying signed in (essential): Firebase Authentication saves your sign-in session in your browser or app.
Remembering your market: our apps remember which market you last chose.
Website analytics: Google Analytics sets cookies on www.tulpie.app to count visits. You can block them in your browser settings or with Google's opt-out add-on.
Bot protection: Cloudflare Turnstile may use browser storage on our feedback form.

We don't use advertising cookies. If you block essential storage, you won't be able to stay signed in.

11. Security

We protect your information with these measures:

encrypted connections (HTTPS)
role-based access rules, so admins, vendors and devices see only what their role allows
app and device verification
scrambled (hashed) storage of passwords and tokens
card details that never reach our systems

No system is completely secure. If we believe someone has accessed personal information without permission, we will tell the Information Regulator and the people affected as soon as reasonably possible, as POPIA section 22 requires.

12. Your rights

Under POPIA you can:

ask whether we hold personal information about you, and get a copy of it
ask us to correct information that is wrong, incomplete or out of date
ask us to delete information we no longer need, or no longer have a right to keep
object to us processing your information, including for direct marketing at any time
withdraw consent you gave us
complain to the Information Regulator

To use these rights, email hello@tulpie.app. We may need to confirm who you are first. We aim to respond within 30 days. Tulpie has no in-app account deletion yet, so please email us to have your account deleted.

Information Regulator (South Africa)

Website: inforegulator.org.za
Email: enquiries@inforegulator.org.za

13. Children

Tulpie is a tool for businesses and is not meant for anyone under 18. We don't knowingly collect information about children. If you think a child has given us personal information, please contact us and we will delete it.

14. Other websites

Tulpie links to other services, such as PayFast's payment pages and the AI assistants you connect. Their own privacy policies apply, and we are not responsible for how they handle your information.

15. Changes to this policy

When we update this policy, we change the "Last updated" date at the top. For important changes, we will tell you by email or with a notice in our apps before they take effect.

16. Contact us

Questions about this policy or your information:

Email: hello@tulpie.app
Post: Working Theory (Pty) Ltd, 818 31st Avenue, Villieria, Pretoria, 0186
This policy: privacy.tulpie.app