Refund policy

Last updated: 4 September 2026

Provara Group (Pty) Ltd (“Provara Group”, “we”, “us” or “our”) provides digital compliance products and implementation resources, including the Provara Group POPIA Compliance Programme, browser-based implementation workspaces, editable templates, implementation frameworks, policies, procedures, registers, checklists, guidance materials and related digital documentation. We also provide programme-related and separately scoped consulting services.

Unless expressly stated otherwise, our products are supplied digitally. No physical goods are shipped.

This Refund & Cancellation Policy must be read together with our Terms of Service. Nothing in this Policy excludes, limits or restricts a statutory right or remedy that cannot lawfully be excluded under applicable South African law.

1. Digital products and change-of-mind requests

Digital products may be made available automatically after successful payment or, where manual fulfilment, licence activation, an access code or an emailed delivery step is required, within the delivery period stated in our Terms of Service or on the applicable product page.

Because digital products can ordinarily be accessed, downloaded, copied, activated or used once access has been provided, Provara Group does not generally offer discretionary change-of-mind refunds after digital access has been granted.

This does not remove or limit any statutory cooling-off right, cancellation right, quality right or refund remedy that applies to the particular transaction.

2. When Provara Group may provide a refund or other remedy

Depending on the circumstances and any applicable statutory rights, Provara Group may provide a refund, replacement access, corrected delivery, repair, replacement or another appropriate remedy where:

• a duplicate purchase was made in error;
• the incorrect product was supplied by Provara Group;
• you experience a material technical access or delivery issue that we are unable to resolve within a reasonable period;
• the product supplied materially differs from the product expressly described at the time of purchase;
• a digital product is defective, unsafe, not reasonably suitable for its intended purpose, or otherwise does not meet an applicable statutory standard where the Consumer Protection Act 68 of 2008 (“CPA”) applies;
• Provara Group is unable to supply the purchased product or service within the agreed or legally applicable period; or
• a refund, cancellation or other remedy is otherwise required under applicable South African law.

3. Technical access and delivery issues

If you do not receive access to your digital product, cannot access the programme or workspace, cannot open the supplied files, or experience another technical delivery problem, please contact us promptly at support@provaragroup.com.

We will make reasonable efforts to resolve the issue. Depending on the circumstances, this may include re-issuing access, resending a download link, supplying a corrected file, reactivating access or providing another reasonable delivery method.

Where Provara Group is unable to perform because a product or service is unavailable, any refund required by the Electronic Communications and Transactions Act 25 of 2002 (“ECTA”) or another applicable law will be processed within the applicable statutory period.

4. ECTA cooling-off rights for qualifying electronic transactions

Chapter VII of ECTA applies to electronic transactions with an ECTA “consumer”, meaning a natural person who enters or intends to enter into an electronic transaction with a supplier as the end user of the goods or services.

Where section 44 of ECTA applies, the consumer may cancel the qualifying electronic transaction without reason and without penalty:

• for goods, within seven days after receipt of the goods; or
• for services, within seven days after conclusion of the agreement.

If payment has already been made and a valid section 44 cancellation is exercised, the consumer is entitled to the refund required by ECTA, which must be made within 30 days from the date of cancellation.

Section 44 does not apply to the transactions excluded by section 42(2) of ECTA. Relevant exclusions depend on the nature of the transaction and may include, for example, services that began with the consumer’s consent before the end of the seven-day cooling-off period.

Provara Group does not treat the mere fact that a transaction involves a digital product as an automatic waiver of a statutory ECTA cooling-off right. The application of sections 42 and 44 will be assessed according to the particular transaction and the law.

5. Consulting and services commenced during an ECTA cooling-off period

Where an ECTA consumer expressly requests that consulting or another service begin before the end of the seven-day period contemplated in section 44, the section 44 cooling-off right may cease to apply where the statutory exclusion in section 42(2)(d) is satisfied.

This does not affect any other cancellation, refund or consumer right that may apply under the CPA, the agreed scope of work or another applicable law.

6. CPA direct-marketing cooling-off rights

Where the CPA applies and a transaction results from direct marketing, section 16 of the CPA may give the consumer a separate right to rescind the transaction without reason or penalty within five business days after the later of:

• the date on which the transaction or agreement was concluded; or
• the date on which the goods were delivered.

The CPA provides that section 16 does not apply where section 44 of ECTA applies to the transaction. Where a valid CPA section 16 rescission applies, Provara Group will process any required refund within the statutory period.

7. Statutory quality and performance rights

Where the CPA applies, nothing in this Policy limits statutory rights relating to the quality, suitability, performance or characteristics of goods or services.

Where a Provara Group digital product constitutes “goods” for purposes of the CPA and the applicable statutory requirements are met, a consumer may have rights to repair, replacement, refund or another remedy under the CPA. The remedy available will be determined in accordance with the applicable statutory provisions and the circumstances of the transaction.

Where consulting or another service is supplied, Provara Group will perform the service in accordance with the agreed scope and any mandatory service-quality standards that apply under South African law.

8. Circumstances where a discretionary refund will generally not be provided

Subject always to statutory rights and remedies, Provara Group will generally not provide a discretionary refund merely because:

• you changed your mind after purchasing the product and no applicable statutory cooling-off or cancellation right applies;
• you no longer require the product;
• you purchased the wrong product and no applicable statutory cancellation or refund right applies;
• digital access has already been provided and the product has been accessed, downloaded, copied, activated or used, where no statutory right to cancel or obtain a refund applies;
• you expected the product to constitute legal advice, regulatory certification, audit approval or a guarantee of compliance;
• you do not have sufficient internal capacity to complete or implement the programme;
• you are unable or unwilling to adapt, approve, implement or maintain the supplied materials for your organisation;
• you do not complete the implementation steps required by the programme;
• the product does not meet an internal, client-specific, industry-specific or business-specific expectation that was not expressly represented or guaranteed by Provara Group in writing; or
• your organisation subsequently decides to use a different compliance methodology, consultant, platform or legal adviser.

9. Programme packages and consulting support

Certain Provara Group programme packages include a defined amount of consulting support. The consulting entitlement is governed by the relevant package description and our Terms of Service.

Programme Plus includes up to 6 consulting hours and the Fully Guided Programme includes up to 24 consulting hours. Programme Essentials does not include consulting hours.

Unless otherwise agreed in writing, included consulting support must be used within the applicable programme support period, which is ordinarily 120 days from programme activation.

Included consulting hours do not create an unlimited advisory engagement and do not automatically include material bespoke work such as complex privacy impact assessments, breach investigations, legal opinions, extensive contract negotiations, large-scale data-mapping projects or multi-jurisdiction legal assessments unless expressly agreed in writing.

Additional consulting or bespoke work outside the purchased programme scope will be separately scoped and quoted before the additional work proceeds.

10. Cancellation of separately scoped consulting services

Cancellation of a separately scoped consulting engagement is governed primarily by the applicable proposal, scope of work, statement of work or other engagement terms agreed for that service.

Any cancellation charge or amount retained must remain subject to applicable South African consumer law. Where the CPA applies to an advance booking, reservation or order, any cancellation charge must be reasonable in the circumstances as required by applicable law.

Where no specific consulting cancellation terms have been agreed, please contact Provara Group as soon as possible so that the cancellation can be assessed having regard to work already performed, committed time, unavoidable costs and any statutory rights that apply.

11. Product nature and implementation responsibility

Provara Group products are practical compliance implementation tools, governance resources and advisory-support materials. They are designed to assist organisations in implementing and maintaining privacy governance in a structured and evidence-based manner.

Unless expressly agreed otherwise in writing, our products and services do not constitute:

• legal advice or a professional legal opinion;
• regulatory certification or approval;
• an audit opinion or assurance conclusion;
• a representation that any regulator, client, auditor or other third party will accept the organisation’s compliance position; or
• a guarantee that an organisation complies, or will continue to comply, with POPIA or any other applicable law.

The purchasing organisation remains responsible for the accuracy of the information it provides, assessing the suitability of the materials for its circumstances, making appropriate governance and risk decisions, adapting and approving documents where required, implementing appropriate controls, maintaining evidence and obtaining independent legal or other specialist advice where necessary.

12. How to request support, cancellation or a refund review

To request technical support, exercise an applicable cancellation right, or ask Provara Group to review a refund request, email support@provaragroup.com and provide:

• your order number, where available;
• the email address used for the purchase;
• the product, programme package or service purchased;
• the date of purchase or agreement;
• if you are relying on a statutory cancellation right, sufficient information to identify that request; and
• a clear description of the issue and the remedy you are requesting.

We may request further information that is reasonably necessary to verify the purchase, confirm authority to act, investigate the issue and determine the appropriate remedy.

13. Processing of approved refunds

Where a refund is approved or legally required, Provara Group will generally process it using the original payment method where reasonably possible.

The time taken for the refunded amount to reflect after processing may depend on Shopify, the applicable payment provider, your bank or card issuer. Any statutory refund deadline that applies will take precedence over our ordinary administrative process.

For a valid ECTA section 44 cancellation, the statutory refund period is 30 days from the date of cancellation. Other statutory refund periods will be applied where relevant.

14. South African consumer rights

Nothing in this Refund & Cancellation Policy is intended to exclude, limit, waive or restrict any statutory right, cooling-off right, cancellation right, quality guarantee, refund remedy or other protection that cannot lawfully be excluded under the CPA, ECTA or any other applicable South African law.

Different statutory consumer protections may apply depending on whether the purchaser is a natural person or juristic person, the nature and value of the transaction, whether the transaction resulted from direct marketing, and whether the particular provisions of the CPA or ECTA apply.

Where an applicable statutory right or remedy conflicts with any provision of this Policy, the applicable law will prevail.

15. Contact details

Questions regarding this Refund & Cancellation Policy may be directed to:

Provara Group (Pty) Ltd
Registration Number: 2026/029775/07
16 Roos Bolton Crescent, Knysna Heights, Knysna, Western Cape, 6571, South Africa
Email: info@provaragroup.com
Support: support@provaragroup.com
Telephone: +27 82 294 2473