Safety
Age verification.
How we keep SPOTR restricted to adults, and what we do with the data that requires.
1. Purpose and legal basis
This Age Verification Policy describes how Spotr Technologies (Pty) Ltd (registration number 2026/618421/07) keeps the SPOTR Platform restricted to people aged 18 and older, in line with:
- the Protection of Personal Information Act 4 of 2013 (POPIA) — sections 34–35 (children’s personal information), section 11(1)(a) (consent) and section 26 (special personal information, including biometric data);
- the Children’s Act 38 of 2005 — a child is any person under 18;
- the Cybercrimes Act 19 of 2020 — identity fraud and computer-related misrepresentation;
- the Consumer Protection Act 68 of 2008 — fair dealing and the protection of vulnerable people;
- the Films and Publications Act 65 of 1996 (as amended) — age-gating obligations for adult content;
- Apple App Store and Google Play age-rating obligations for dating applications.
SPOTR is an adult-only platform. We do not knowingly permit anyone under 18 to register or use it. Where we discover that a member is under 18 we terminate the account and delete their personal information.
2. Scope
This Policy applies to every registration on the SPOTR mobile application and any associated web interface, and to any account flagged for suspected age misrepresentation.
3. How we verify age
We apply two checks. The first applies to everyone. The second applies where identity verification is enabled and where a specific concern arises.
| Check | How it works | What we process |
|---|---|---|
| 1. Date of birth | You enter your date of birth when you register. The app calculates your age and blocks registration if you are under 18. This is also enforced by a constraint in our database, so an under-18 account cannot be created even if the app is bypassed. | Date of birth, retained for the life of the account so that we can evidence the check and so that you can correct it. |
| 2. Identity document and liveness check | You photograph a South African Smart ID card, passport or driver’s licence. The date of birth is read from the document, and a liveness prompt confirms you are present and match the photograph. This is carried out by Smile ID, a third-party identity verification provider, under a data processing agreement. This check will be enabled at public launch. It does not operate during our closed testing period. | The document image and selfie are processed by the provider and are not retained by SPOTR. Only the outcome of the check — verified or not verified — is stored. |
We may require the second check where an account is reported for age misrepresentation, or where our review of an account raises a concern.
4. Identity document data — special protections
An identity document and liveness selfie are biometric data and special personal information under POPIA section 26. Where this check is in use:
- the data is processed only to verify age and identity, and for no other purpose;
- it is handled by our contracted verification provider under a POPIA data processing agreement, and deleted on completion of the check;
- SPOTR does not retain any biometric data — only the pass or fail outcome;
- explicit, informed consent is obtained before any biometric data is collected, in accordance with POPIA section 27;
- you may withdraw that consent at any time, but we will not be able to complete verification, and access to age-restricted features will be withdrawn.
5. Prohibited conduct
Age misrepresentation puts every member at risk. The following are prohibited:
| Conduct | Consequence |
|---|---|
| Giving a false date of birth | Account terminated and a permanent ban on re-registration. Evidence retained for 3 years. |
| Using another person’s identity document | Account terminated, and referral to the SAPS for identity fraud under the Cybercrimes Act where the evidence warrants it. |
| Helping a minor to register, including lending them a document | Permanent ban. Where the minor comes to harm, civil and criminal liability may follow. We will cooperate fully with law enforcement. |
| Creating a new account after an age-related ban | The new account is removed. Repeated attempts may be reported to the SAPS. |
6. If we find an underage member
If we become aware — through a report, our own review, or a request from law enforcement — that a member is under 18, we will:
- suspend the account immediately, pending review;
- preserve the account data as the law requires;
- permanently delete the account and all associated personal information within 72 hours of confirming it, unless it must be retained for an investigation;
- where there is evidence of grooming, exploitation or child sexual abuse material, refer the matter immediately to the SAPS and the Film and Publication Board, in accordance with our Reporting & Enforcement Policy;
- record the incident in our audit trail, retained for 3 years.
7. If you cannot complete verification
Some people face genuine barriers — no government-issued document, a disability affecting the photograph step, or a technical failure. A manual route is available:
- email support@spotr.co.za with the subject line “Age Verification Assistance”;
- we will assess each case individually and may ask for alternative documentation;
- we aim to decide within 5 business days;
- this route is for adults who cannot use the standard checks. It is not a way around the age limit.
8. What we keep, and for how long
| Data | Retained for | Why |
|---|---|---|
| Date of birth | The life of the account | To evidence the 18+ check under POPIA s.34 and to allow you to correct it |
| Verification outcome (that a check was done, when, and by what method) | 3 years | Audit trail; cooperation with law enforcement |
| Identity document image and liveness selfie | Not retained by SPOTR; deleted by the provider on completion | Data minimisation; POPIA s.26 |
| Evidence of age misrepresentation | 3 years from the incident | Cooperation with law enforcement; Cybercrimes Act |
All of this is processed in line with our Privacy Policy. You may ask for access to, correction of, or deletion of your personal information, subject to the legal obligations above.
9. Our verification provider
Identity verification is carried out by a contracted third-party provider. Any provider we use must:
- be bound by a POPIA data processing agreement, and process data only on our documented instructions;
- delete document and biometric data on completion of each check;
- hold ISO 27001 certification or an equivalent information security standard;
- operate within South Africa, or under an approved POPIA section 72 cross-border transfer mechanism;
- notify us of any security compromise within 24 hours.
10. How this meets POPIA
- Purpose limitation (s.13) — verification data is used only to confirm age and identity.
- Data minimisation (s.14) — we collect only what the check requires, and retain no biometric data.
- Security safeguards (s.19) — encryption in transit and at rest, and restricted access.
- Consent (s.11(1)(a) and s.27) — explicit consent before any biometric processing.
- Special personal information (s.26) — handled only by a contracted operator under a binding agreement.
- Children’s information (ss.34–35) — the purpose of this Policy is to prevent it being processed at all.
- Accountability (s.8) — verification records retained for 3 years to demonstrate compliance.
Our Information Officer, Kyle Crawford, is registered with the Information Regulator under reference 2026-064109, in accordance with POPIA section 55.
11. App store age rating
SPOTR will be rated 18+ on both the Apple App Store and Google Play. That rating restricts downloads on devices managed by Apple Screen Time or Google Family Link where the account holder has set restrictions, and is enforced by the app stores independently of the checks described above.
As at September 2026 there is no South African statute mandating a specific age verification technology for dating applications; a proposed Online Safety Bill is under development. We will update this Policy as that develops.
12. Changes to this Policy
We may update this Policy as the technology, the law and our own practice develop. We will give notice in the app 30 days before a material change takes effect, and where a change introduces a new biometric processing activity we will ask for fresh consent first.
13. Contact
For anything about age verification, or to report a member you believe is under 18:
- Email: support@spotr.co.za
- Telephone: +27 64 967 1289
- Information Officer: Kyle Crawford
- Information Regulator: enquiries@inforegulator.org.za | 010 023 5200
Spotr Technologies (Pty) Ltd (registration number 2026/618421/07), 5 Gowrie Avenue, Gowrie Village, Nottingham Road, KwaZulu-Natal, 3280.