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nTer

Privacy Policy

Version 1.8 • effective 18 August 2026 • first published 3 August 2026

This policy explains what personal information nTer collects, how it is obtained, why it is used, where it is processed, how long it is kept, when it is disclosed and the rights and choices available to you. nTer is a daily Christian devotional service operated by Matt White International (Pty) Ltd. This policy is designed to meet the transparency requirements of the Protection of Personal Information Act, 2013 (South Africa) and other privacy laws that apply where nTer deliberately offers the service.

In brief

  • We collect only the information needed to operate, secure and support nTer.

  • Your Whisper Journal is encrypted before storage. We do not routinely inspect, analyse or use its content.

  • We do not sell personal information, disclose it for targeted advertising, or use journal content to train artificial-intelligence models.

  • We use a limited group of service providers to operate the platform, as described below.

  • You can access, export, correct or delete your information and withdraw optional consents.

  • You must be 18 or older to create an nTer account.

This summary helps you navigate. The full policy governs.

What this policy covers

1 Who we are and how to reach us

2 Scope and how we collect information

3 The information we hold, why we hold it and how long we keep it

4 Your use of nTer, the Whisper Journal and sensitive information

5 How we disclose personal information

6 How we protect personal information

7 Where personal information is processed

8 Retention, deletion and backups

9 Cookies, security technologies and on-device storage

10 Email and other messages

11 Your rights and choices

12 Children, automated decisions and profiling

13 Regional information

14 Changes, questions and complaints

1. Who we are and how to reach us

nTer is a service of Matt White International (Pty) Ltd, a private company incorporated in the Republic of South Africa under the Companies Act 71 of 2008, registration number 2017/378663/07. Physical business address and address for service: 34 2nd Avenue, Linden, Johannesburg, 2196, South Africa. Postal address: Suite 8, Private Bag X1, Greenside, Johannesburg, 2034, South Africa.

For matters relating to personal information, including requests and complaints, contact our registered Information Officer, Matthys Johannes Kruger-Nel, at info@mattwhiteinternational.com or +27 82 869 6163. For ordinary nTer service support, contact support@nter.life.

In this policy, “we”, “us”, “our” and “nTer” mean Matt White International (Pty) Ltd. Under POPIA, we are the responsible party for personal information used for nTer. nTer is offered from South Africa. At launch, we do not deliberately offer Account creation or Subscriptions to people ordinarily resident in the European Economic Area or the United Kingdom, and we also decline new Account creation when the sign-up request originates there or the request country cannot be reliably resolved. An eligible Account validly created outside those territories is not automatically suspended merely because the Account holder later travels there temporarily. We do not use continuous geolocation for this purpose. Where any data-protection law applies to a particular person or processing activity, we comply with it. “You” and “your” mean the person using or communicating with nTer.

The relevant Paddle group company identified at checkout or on your receipt is nTer’s authorised reseller and Merchant of Record. Depending on your location, this may be Paddle.com Inc., Paddle.com (Canada) Ltd. or Paddle.com Market Limited. Paddle independently determines how it handles checkout, payment, tax, invoicing, fraud prevention and related billing information. Paddle’s own privacy notice governs that processing. nTer receives only the limited subscription and transaction information needed to provide and support the service.

2. Scope and how we collect information

This policy applies to the nTer website and responsive web application, Account, Whisper Journal, LightDrops, the optional daily nTer Moment email, one-to-one devotional gifting where enabled, email delivery, support interactions and subscription administration. For clarity: a LightDrop is devotional content; the nTer Moment is the optional daily email communication; a Gifted Reading is temporary entitlement to one already-published LightDrop; and a Gifted Reading email is the one-to-one notice and claim mechanism used to deliver that gift journey. This policy does not govern a third party’s website or service merely because nTer links to it.

Territorial availability. At launch, nTer is available only to people ordinarily resident in an eligible territory. People ordinarily resident in the European Economic Area or the United Kingdom cannot create an Account or Subscription. During sign-up you provide and confirm your country of ordinary residence. At initial Account creation only, nTer also uses a coarse country-level location check supplied through our edge infrastructure. Account creation is declined where the request is detected as originating in the European Economic Area or the United Kingdom, or where the country cannot be reliably resolved. The location check supports the launch-territory control but does not determine ordinary residence, and nTer does not continuously geolocate established Account holders for this purpose. Temporary travel by an otherwise eligible Account holder does not, by itself, change eligibility. A Gifted Reading email may incidentally reach a recipient who is in the European Economic Area or the United Kingdom because an eligible member has chosen that person through an existing personal relationship or acquaintance. nTer does not use that incidental delivery to target, market to or deliberately offer Account creation or Subscriptions in those territories. Receiving or opening a Gifted Reading does not bypass the launch-territory rules. A recipient who already has a valid Account may sign into that Account under the ordinary rules; a recipient who needs a new Account must pass the territorial eligibility process before Account creation. The giver does not determine or warrant the recipient’s ordinary residence. The Terms of Service explain this restriction and what happens if ordinary residence later changes.

We collect information in four ways:

We do not purchase personal information from data brokers. For an ordinary nTer Account we collect your country of ordinary residence, but we do not ordinarily collect your legal name, street or residential address, proof-of-residence document or identity document unless a particular legal, billing, support or fraud-prevention need requires it and you are told at the time.

Where information is required, we explain the consequence of not providing it. Without an email address, adult-status confirmation, country of ordinary residence and the required eligibility confirmations, nTer cannot create an Account. Whisper Journal use and optional communications remain subject to the choices described in this policy.

3. The information we hold, why we hold it and how long we keep it

The table describes the principal categories of personal information processed by nTer. “Contract” means processing needed to provide the service requested by the person who is party to that relationship. “Legitimate interests” means a necessary and proportionate purpose that we assess against the rights and interests of the person whose information is processed. For recipient information supplied by a giver before the recipient has an Account relationship with nTer, we do not rely on a contract with that recipient merely because the giver requested the feature. Because nTer is expressly a Christian devotional service, creating an Account, subscribing or using the Service may reveal or permit an inference about religious beliefs. Where applicable law treats that information as special-category or sensitive information, we rely on explicit consent collected separately from acceptance of the Terms, in addition to the ordinary lawful basis shown in the table. We also request separate explicit consent for sensitive Whisper Journal content. Consent is not bundled with marketing consent.

Information Source and purpose Required and lawful basis Retention
Account identifiers and authentication data Your email address, an internal user identifier, sign-in records, magic-link events and related authentication information. We use these to create and secure your account and let you sign in. Email and adult-status confirmation are required. Contract; legitimate interests in account security and preventing misuse; legal obligations where applicable. Account identifiers remain while the account is active. Authentication and security logs are normally kept for a limited period under sections 6 and 8.
SoulName A display name you choose. It need not be your legal or real name. It is shown within your account and service experience. Required for the account experience, but you may use a pseudonym. Contract. While your account is active, then deleted under section 8.
Adult age confirmation You provide your date of birth once. nTer checks whether you are 18 or older, immediately discards the date itself and keeps only the result and date of verification. Required. Contract; legitimate interests in maintaining an adults-only service; legal obligations where applicable. The yes/no result and verification date remain while the account is active. The date of birth itself is not intentionally stored.
Territorial eligibility information The country of ordinary residence you provide and confirm at sign-up, together with a one-time coarse country-level sign-up location and the result and time of the territorial check. We use this to determine whether nTer is offered to you at launch and to document the Account-creation decision. We do not use this information for continuous location monitoring. Required to create an Account. Contract; legitimate interests in applying service-availability rules, legal compliance and preventing circumvention. Residence and the minimal Account-creation eligibility record are kept while the Account is active and, where necessary, for a limited period afterwards to demonstrate the decision or handle a dispute. Raw location history is not created for this purpose.
Giver and gift operational information When an eligible Account holder creates a Gifted Reading, nTer processes the giver Account reference, the selected LightDrop reference, a cryptographic hash of a random gift token, creation, expiry and claim state and, after a successful claim, the authenticated recipient Account reference and limited access-until time. The giver must make the required adult-recipient confirmation. Search terms used inside the gift flow are not intentionally persisted or logged. Required sending acknowledgements may be recorded as generic accountability events without retaining a permanent history of who gave which reading to whom. Rate-limit and abuse-prevention events may be processed where needed to enforce gifting controls. Optional feature data. Contract for the giver’s requested feature; legitimate interests in securely operating the one-to-one gift, enforcing reasonable gifting limits, preventing harassment and abuse, and protecting the Service; legal obligations where applicable. An unclaimed gift expires after 14 days. After claim, the operational gift record is kept only through the limited access period and is then purged. Generic accountability and justified abuse-prevention records may be retained under the separate accountability, security and complaint retention rules.
Recipient Gifted Reading delivery information The recipient email address is supplied by the giver. nTer uses it to send the one requested Gifted Reading email, including the short collection notice, claim route and related security information. The address is not written to the operational gift record and is not retained by nTer as a gifting, referral or marketing contact profile. It is transmitted to the email provider for delivery and may appear in that provider’s limited delivery, bounce, complaint or suppression records. A recipient may decline the gift and may ask nTer either to block future Gifted Reading emails from the same sender to that address or to block all future Gifted Reading emails from nTer to that address. nTer may retain minimal purpose-limited suppression values solely to honour the selected block. Recipient delivery data before an Account relationship exists. Legitimate interests: nTer’s legitimate interest in fulfilling a current user’s requested one-to-one personal gift. That interest arises in the context of the current user’s existing relationship or acquaintance with the recipient. The relationship provides the factual context and safeguard for the initial contact; it does not create an ongoing relationship between nTer and the recipient. The recipient alone decides whether any further interaction with nTer occurs. Legal obligations where applicable. nTer does not retain the clear address as a gifting, referral or relationship profile after the requested delivery. Provider-side operational records are retained only as described for email delivery. A sender-specific or nTer-wide Gifted Reading suppression value may be retained for as long as reasonably necessary to honour the recipient’s selected block and is not used for another purpose.
Whisper Journal entries The private reflections you choose to write. We use them only to store them securely and return them to your authenticated account. Optional. Contract for the journal function, plus explicit consent where entries reveal special-category or sensitive information. While your account remains active, subject to deletion, withdrawal and dormancy rules in section 8.
Candle Connection state The local calendar date on which you most recently chose to use Candle Connection, nTer’s virtual candle feature. nTer uses only that current-day state so Candle Connection can remain active when you return on the same day. We do not keep a history of Candle Connection activity or a reading-completion record. Optional feature data. Contract. While your Account is active; the single date is overwritten when you next use Candle Connection and is deleted with the Account, subject to lawful retention.
Timezone and nTer Moment preference Your timezone may be detected from your browser during onboarding and can be changed by you. We use it with your nTer Moment email preference to deliver the requested daily message at the intended local time. Timezone is required for date-sensitive service behaviour after Account creation. The daily email preference is optional; contract for requested functionality and consent where required for the communication. While your Account is active, or until you change or withdraw the email preference.
Consent, acknowledgement and policy records Records of consents, withdrawals, required acknowledgements and policy or terms versions associated with your Account. We use these to honour your choices and demonstrate compliance. A gifting territorial acknowledgement is retained, where needed, as a generic event and does not identify the recipient, gifted devotional or gift token. Generated automatically. Legal obligations and legitimate interests in accountability. While the Account is active and normally for five years after Account deletion or the relevant consent/withdrawal/acknowledgement event, whichever is later, unless longer retention is required for an actual legal claim, investigation, regulatory matter or statutory obligation.
Subscription and transaction information Information received from Paddle, such as subscription status, plan, customer or transaction reference, purchase date, currency, country, tax status and limited billing or contact details Paddle makes available to us. nTer does not receive your complete card number. Required for paid access. Contract and financial, tax, accounting and fraud-prevention obligations. Subscription status while relevant to the account. Transaction and accounting records for the period required by applicable law, generally at least five years.
Email-delivery information Message type, recipient address, delivery status, bounce, complaint and suppression information generated by Resend or another mail provider. This includes Account messages, nTer Moment emails and personal Gifted Reading emails. We use this to deliver requested messages, protect sender reputation and stop sending where required. Generated when email is sent. Contract for communications requested by an Account holder; legitimate interests in reliable delivery, security and member-requested Gifted Reading delivery; consent or another lawful permission for marketing where required. Operational delivery records are kept only as long as needed. A minimal opt-out, complaint or suppression record may be retained for as long as reasonably necessary to honour the choice and prevent contact contrary to it. nTer does not use a Gifted Reading recipient address as a referral or marketing profile.
Support correspondence Messages, attachments and account information you provide when contacting support. We use these to answer the request, investigate faults and maintain an appropriate service record. Optional unless needed to resolve a request. Contract; legitimate interests in support, service quality and dispute management; legal obligations where applicable. Normally for up to 24 months after the matter is closed, unless a longer period is needed for legal, security or dispute reasons.
Technical, device and security data IP address, dates and times, browser or user-agent information, device and operating-system information, requested pages or functions, error records, rate-limit events and security signals generated when nTer is used. Generated automatically and necessary to operate the service safely. Legitimate interests in security, reliability, fraud prevention and fault diagnosis. nTer-controlled operational logs are normally retained for no longer than 90 days. Records connected to a security incident, legal claim or abuse investigation may be kept longer.
Privacy-rights, complaint and incident records Requests to access, correct, export, restrict or delete information, identity-verification evidence, complaint correspondence and breach-assessment records. Generated when needed. Legal obligations and legitimate interests in accountability and legal defence. For the period required by applicable law and normally up to five years after the matter closes, unless a longer period is justified.

We may keep a smaller amount of information for longer where necessary to comply with law, enforce rights, investigate a security incident, maintain an opt-out or establish, exercise or defend a legal claim. We do not retain information merely because storage is available.

4. Your use of nTer, the Whisper Journal and sensitive information

nTer is a Christian devotional service. Creating an Account, subscribing, receiving the optional nTer Moment email or using devotional features may reveal or permit an inference about religious or philosophical beliefs. What you choose to write in the Whisper Journal may reveal those beliefs and may also reveal other sensitive or special-category information, such as information about health, political opinions, racial or ethnic origin, relationships or sex life. nTer does not require you to include any of these details in the journal.

We process account and service information to provide nTer under our contract with you and, where required, on the basis of explicit consent for information revealing religious or other special-category information. We process journal content to provide the optional journal function under our contract with you and rely on the separate explicit journal consent requested during account setup where the content is sensitive. These consents are not bundled with acceptance of the Terms or with marketing consent.

You may withdraw an applicable sensitive-information consent at any time. Withdrawal does not make earlier lawful processing unlawful. Where the separate Whisper Journal consent is required for us to process journal content, nTer gives you an authenticated opportunity to export or delete your writing before the final withdrawal takes effect. Once that withdrawal takes effect, new journal writing and ordinary read/decrypt access stop and live Whisper Journal content is deleted, subject only to the backup cycle and any limited retention required by law. Withdrawal of a broader consent that is necessary to provide the Account or devotional service may require us to stop the affected processing or close the Account, subject to the same export, deletion and retention principles.

Journal entries are encrypted in transit and encrypted by an application-level server function before they reach the Supabase database. Supabase stores the journal body as ciphertext only. The encryption key is held in Cloudflare's secret store, separately from the database, and each entry carries a key-version tag so keys can be rotated. nTer does not routinely inspect, analyse, classify or use journal content. Journal content is not used for advertising, profiling or training artificial-intelligence models.

This is server-managed encryption, not end-to-end or zero-knowledge encryption, because nTer holds the encryption key. Decryption occurs inside the server function when an authenticated and authorised Account holder requests the relevant entry. There is no ordinary administrative journal-reading function. Journal content is not written to application logs. An in-session export is delivered to the authenticated Account holder and does not create a journal-content or journal-count log.

Please avoid recording identifiable personal information about another person unless you have a proper and lawful reason to do so. The journal is not an emergency, medical, counselling or crisis-response service, and nTer does not monitor journal entries for requests for help.

Gifting a reading

Where gifting is enabled, an eligible Account holder may ask nTer to make one already-published LightDrop temporarily available to another adult as a Gifted Reading. The giver supplies the recipient email address so nTer can send the Gifted Reading email. That email is the notice and claim mechanism; it does not create a permanent emailed copy of the devotional. Before sending, the giver must confirm: “I confirm that this person is 18 or older and is someone I know or with whom I have an existing relationship or acquaintance.” The giver must not send a Gifted Reading if they know or reasonably believe the recipient is under 18. The first Gifted Reading email includes a short collection notice explaining that the address was supplied by an nTer member, identifying nTer and the purpose of the use, confirming that the address is not added to a promotional list, and providing a route to this full policy and to the available Gifted Reading refusal and blocking choices.

The operational gift record contains only what is needed to operate the Gifted Reading securely: the giver Account reference, LightDrop reference, a hash of a cryptographically random gift token, timestamps and claim state and, after claim, the authenticated recipient Account reference and access-until time. The raw token is not written to the operational gift record and must not be intentionally written to nTer application logs. Opening or automated scanning of the email link must not itself redeem the gift: the link opens a landing experience and the recipient completes a deliberate claim action. The recipient may use the authentication or onboarding route made available for the claim; nTer does not require the eventual Account email to match the delivery address and does not represent that it verifies the giver’s off-platform relationship or the recipient’s legal identity. Unclaimed gifts expire after 14 days. Claimed gifts provide access only for the displayed limited gift period, ordinarily until the recipient’s next local-day boundary, and the operational record is then purged. Search terms used to find a reading to give are not intentionally persisted or logged. We do not create share counts, referral rewards, conversion records, “most shared” rankings or a permanent history of who gave which reading to whom.

Being sent a Christian devotional does not mean that the recipient has told nTer anything about their beliefs. We do not treat receipt, opening or claiming of a Gifted Reading as evidence of the recipient’s religion or use it to profile or market to them. nTer processes the recipient email address on the basis of its legitimate interest in fulfilling a current user’s requested one-to-one personal gift. That legitimate interest arises in the context of the current user’s existing relationship or acquaintance with the recipient. The relationship provides the factual context and safeguard for the initial contact. It does not create an ongoing relationship between nTer and the recipient. The recipient alone decides whether any further interaction with nTer occurs. The giver is not shown whether the recipient opened the email, claimed the gift, created an Account, subscribed, requested a Gifted Reading block or failed an eligibility check. The Whisper Journal is structurally separate from gifting and is never shared through this feature.

5. How we disclose personal information

We do not sell personal information. We do not disclose personal information for cross-context behavioural or targeted advertising. We disclose only what is reasonably necessary in the following circumstances:

We require processors and operators to act on documented instructions, maintain confidentiality and security, assist with rights and breach obligations, and delete or return information when the relationship ends, subject to lawful retention.

6. How we protect personal information

We use technical and organisational safeguards proportionate to the sensitivity of the information and the risks presented by the service. These include:

No internet transmission, device or storage system is completely secure. If a personal-information breach occurs, we investigate and assess it under each applicable law. We notify the relevant regulator and affected people when, in the manner and within the period required by that law.

7. Where personal information is processed

nTer is operated from South Africa and uses a limited group of providers. Some providers process information outside South Africa and outside the country where a user is located. The principal providers at the date of this policy are listed below.

Provider Role and data involved Principal processing locations and role
Supabase Database and authentication. Stores account information, authentication records and encrypted journal entries. Processes technical and security logs. Primary database region: Frankfurt, Germany. Other support, security and operational processing may occur internationally. Processor/operator.
Cloudflare Website delivery, edge security, performance, rate limiting, the one-time country-level sign-up check, and the secret-management infrastructure used by nTer. Global edge network, including the United States and other countries where Cloudflare operates. Processor/operator for customer data; may act independently for limited service and security data under its own notice.
Resend / Plus Five Five, Inc. Sends account, service, daily-reading and one-to-one Gifted Reading emails. Processes recipient address, message content and delivery, bounce, complaint and suppression information. United States and locations used by its subprocessors. Processor/operator for email customer data; independent controller for its own account and usage information.
Relevant Paddle group company Authorised reseller and Merchant of Record. Handles checkout, payment, tax, invoicing, fraud prevention, refunds and billing support. nTer receives limited transaction and subscription information. The contracting entity depends on the buyer’s location and may be in the United States, Canada or the United Kingdom. Processing may also occur in the European Union and other locations described in Paddle’s privacy information. Independent controller for payment and billing information.
Tristar Technologies CC Hosts the support@nter.life mailbox and processes sender and recipient details, message content, attachments, delivery information and mailbox administration records. South Africa. Operator/processor for hosted email services, subject to its contractual terms.

We maintain a current provider and subprocessor list on nTer’s legal page. A provider may change its infrastructure or subprocessors. We review material changes and update the list or this policy where appropriate.

For transfers from South Africa, we use a mechanism permitted by section 72 of POPIA, including contractual protections, an adequate legal framework, consent where appropriate or another permitted ground.

You may ask which safeguard applies to a particular transfer and request information about it by contacting info@mattwhiteinternational.com. We may provide a summary or a redacted copy where confidentiality or security requires it.

8. Retention, deletion and backups

We retain personal information for the shortest period reasonably needed for the purpose described in this policy, including legal, accounting, security and dispute-management requirements.

When you delete your Account, nTer deletes the live service data that is no longer required to operate or lawfully close the relationship, including the profile, SoulName and Whisper Journal ciphertext. nTer-side subscription state is removed or disconnected as appropriate. A minimal consent/accountability record may be retained while the Account is active and normally for five years after Account deletion or the relevant consent, withdrawal or required acknowledgement event, whichever is later, unless a longer period is required for an actual legal claim, investigation, regulatory matter or statutory obligation. Paddle acts independently for payment and billing data: where appropriate nTer uses or supports Paddle’s buyer-privacy process, but Paddle may retain transaction or accounting records it is independently required to keep. Ordinary email-contact data is removed when no longer needed, while the minimum suppression state necessary to honour an unsubscribe may be retained so that the person is not contacted contrary to that choice. Gift operational records are governed by the shorter expiry and purge rules above and are not kept as a permanent sharing history. Privacy-request, security, transaction or legal records may likewise be retained only for their remaining lawful purpose. At launch, Supabase Pro daily backups are retained for approximately seven days and point-in-time recovery is not enabled. Deleted information may remain only as residual data in those backups until the backup cycle expires. nTer maintains no separate journal export archive. Backups are used only for disaster recovery or service continuity.

Deletion may not remove records that nTer or an independent controller must retain by law, or information necessary to maintain an unsubscribe, defend a legal claim, prevent fraud or document that a request was completed. Such information is restricted to the remaining purpose.

9. Cookies, security technologies and on-device storage

At the date of this policy, nTer does not use advertising cookies, third-party behavioural tracking or product analytics that measure devotional engagement. The service uses only limited technologies needed to authenticate, secure, operate and diagnose the service:

If nTer introduces a non-essential cookie, advertising technology or materially different analytics tool, we will update this policy and request consent where applicable law requires it.

10. Email and other messages

nTer sends different kinds of communications for different purposes:

nTer does not intentionally use open pixels or click tracking to create profiles of recipients. We do not expose Gifted Reading redemption, Account creation, subscription, eligibility or block outcomes to the giver. Our mail provider still processes technical delivery, bounce, complaint, abuse-prevention and suppression information needed to operate email safely and reliably.

Gifted Reading choices and blocks. A recipient, including a person who does not have an Account, may decline a Gifted Reading and may choose either: (a) not to receive further Gifted Reading emails from the same sender to that email address; or (b) not to receive any further Gifted Reading emails from nTer to that email address. nTer may retain only the minimal purpose-limited suppression values needed to honour the selected choice. Sender-specific suppression may associate a protected recipient-address match value with the giver Account reference solely to prevent another Gifted Reading from that giver to that address. An nTer-wide suppression value prevents Gifted Reading sends to the address regardless of which member initiates them. These values are not used to build marketing, referral or relationship profiles. Suppression checks occur before a proposed Gifted Reading is passed to the email provider, and the giver is told only that the Gifted Reading could not be sent, not why.

11. Your rights and choices

Depending on the law that applies, you may have some or all of the following rights. nTer makes the core choices available to every account holder where reasonably possible:

You can carry out common actions such as changing preferences, exporting writing and deleting the account through the service where those controls are available. For any other privacy or PAIA request, email info@mattwhiteinternational.com. We use proportionate verification and do not ask for more identity information than reasonably necessary.

We respond without undue delay and within the period required by applicable law. Requests are usually free. We may charge a reasonable or prescribed fee, request clarification, extend a response period or refuse a request only where applicable law permits it, and we will explain the decision and complaint route.

Some rights are subject to exemptions. A request may also affect information concerning another person. In that case, we balance the applicable rights and may redact or withhold information where the law requires or permits it.

12. Children, automated decisions and profiling

Children

nTer is intended only for people aged 18 or older. The Service is not designed for or directed to children. We check adult status during Account creation and intentionally retain only the result, not the date of birth. A member must not initiate a Gifted Reading for a person whom the member knows or reasonably believes is under 18, and the gifting flow requires the member to confirm the adult-recipient condition before sending. The Gifted Reading itself is not made available through the claim journey until the recipient completes the applicable adult-status and eligibility steps. If we reasonably determine that an Account or Gifted Reading recipient is under 18, we stop the affected processing and delete or restrict the associated personal information as applicable, subject to any limited record required by law or necessary to document the action.

Automated decisions and profiling

nTer does not use personal information to make solely automated decisions that produce legal or similarly significant effects. The adult-status check is a simple rule used to enforce eligibility. We do not profile journal content, infer characteristics for advertising, use gifting/search behaviour to infer religious beliefs, or carry out targeted advertising.

13. Regional information

The general protections above apply to everyone. The following provisions add information required or appropriate for particular regions. Where a regional provision conflicts with the general policy, the regional provision governs for the person and processing covered by that law.

South Africa - POPIA and PAIA

Matt White International (Pty) Ltd is the responsible party. Our registered Information Officer is Matthys Johannes Kruger-Nel, Information Regulator registration number 2026-063369, at info@mattwhiteinternational.com or +27 82 869 6163. MWI's PAIA Manual and prescribed access information are made available through https://mattwhiteinternational.com, the nTer legal page where relevant, and on request.

You may request access to or correction of personal information, object to qualifying processing, request deletion or destruction where the legal requirements are met, withdraw consent and complain to the Information Regulator. Cross-border transfers are managed under section 72 of POPIA. Direct marketing is managed under POPIA and other applicable electronic-communications and consumer law.

European Economic Area and United Kingdom

At launch, nTer is not deliberately offered to people ordinarily resident in the European Economic Area or the United Kingdom. A person creating an Account must state and confirm their country of ordinary residence. nTer also declines initial Account creation where the sign-up request is detected as originating in the European Economic Area or the United Kingdom, or where the country cannot be reliably resolved. This one-time country-level check supports the launch-territory control but does not determine ordinary residence. nTer does not continuously geolocate established Account holders for this purpose, and an otherwise eligible Account holder does not lose access merely because they temporarily travel to or spend time in those territories. A Gifted Reading email may incidentally reach a person who is in the European Economic Area or the United Kingdom because an eligible existing member has chosen that recipient through their personal relationship or acquaintance. nTer does not use that incidental contact to target or deliberately offer Account creation or Subscriptions in those regions, and a new recipient remains subject to the territorial eligibility controls before any Account can be created. If we later choose to deliberately serve ordinary residents of these regions, we will update the Service and this policy before doing so. Where the EU or UK GDPR nevertheless applies to a particular processing activity, we comply with it.

United States

Where a United States state privacy law applies to nTer, a resident has the rights provided by that law. Depending on the state, those rights may include access, correction, deletion, portability, appeal and freedom from discriminatory treatment for exercising privacy rights. Regardless of whether a particular state law applies, nTer voluntarily provides the core account rights described in section 11 where reasonably possible.

nTer does not sell personal information, use journal content to infer characteristics for advertising, or process personal information for targeted advertising. The one-to-one Gifted Reading feature described in this policy is not used for cross-context behavioural advertising. If a future practice creates a legally defined sale, sharing for cross-context behavioural advertising, or targeted-advertising activity, nTer will provide the required notice and opt-out mechanism before that practice begins.

Australia

Where the Privacy Act 1988 and Australian Privacy Principles apply to nTer, we handle personal information consistently with the APPs, including transparency, access, correction, security, complaint handling and cross-border-disclosure requirements. SoulName allows a pseudonym within the service, although an email address and adult-status confirmation remain necessary for an account.

Personal information may be disclosed to recipients in Germany, the United States, the United Kingdom and other countries used by the providers identified in section 7. We take reasonable steps appropriate to the relationship and risks to require overseas recipients to protect the information. Eligible data breaches are notified as required by the Notifiable Data Breaches scheme. You may complain to the Office of the Australian Information Commissioner after raising the concern with us.

Other countries

Additional national or regional privacy laws may apply depending on where you are located and whether nTer deliberately offers the Service there. We provide additional collection notices, consent choices, grievance details and rights processes where required. Naming a law in this policy does not limit rights you have under another law that applies to you.

14. Changes, questions and complaints

Changes to this policy

We update this policy when nTer, our providers, our processing or applicable law changes. We change the version number and effective date and retain earlier versions as required or on request. We notify you before a material change takes effect where appropriate. If a new use requires consent, we obtain that consent before the new use begins. Continued use is not treated as consent where the law requires an affirmative choice.

Questions and complaints

Contact info@mattwhiteinternational.com with a privacy or PAIA question, request or complaint. Contact support@nter.life for ordinary product support. We assess privacy concerns, gather the relevant facts and respond without undue delay. You are not required to complain to us before approaching a regulator where the law allows direct contact.

South Africa: Information Regulator, Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg; PO Box 31533, Braamfontein, Johannesburg, 2017; enquiries@inforegulator.org.za; Information Regulator eServices portal.

Australia: Office of the Australian Information Commissioner.

Elsewhere: Your applicable national or regional privacy authority.

Privacy Policy v1.8