Privacy Policy — ICDA (Intelligent Community Dialogue Agent)
Effective date: 2026-05-08 Version: 1.0
This Privacy Policy explains how the Intelligent Community Dialogue Agent (ICDA) collects, uses, shares, and protects personal data of people who use the mobile app, web portal, or AI chat. ICDA is built and operated by Wits Mining Institute, Faculty of Engineering and the Built Environment, University of the Witwatersrand, implementing the platform on behalf of the MASTERMINE Project (the EU-funded consortium that owns the initiative).
We comply with the EU General Data Protection Regulation (GDPR), the South African Protection of Personal Information Act (POPIA), and equivalent national laws of the countries where ICDA operates.
Plain-language summary — ICDA exists so communities living near mining sites can raise issues, get information, and stay in dialogue with operators. We collect only what is needed to make that dialogue work, we never sell your data, and you can ask to see, correct, export, or delete your data at any time.
1. Who we are
| Role | Entity |
|---|---|
| Project owner | MASTERMINE Project (EU consortium) |
| Platform implementer / joint controller | Wits Mining Institute, Faculty of Engineering and the Built Environment, University of the Witwatersrand |
| Independent controllers | Participating mining-company partners (e.g. Sibanye-Stillwater, TAPOJARVI, JSW) — for personal data they receive about issues, events, or community engagement at their own sites |
Contact: Wits Mining Institute Chamber of Mines Building (West Campus), CM6 1 Jan Smuts Avenue, Braamfontein, Johannesburg 2000, South Africa Tel: +27 11 717 7428 Email: wmi@wits.ac.za or info.wmi@wits.ac.za
For data-protection requests (access, deletion, complaints), email the addresses above with the subject line "ICDA — Data Protection Request".
2. Who can use ICDA
ICDA is intended for adults and young people aged 16 or older. If you are under 16, do not create an account or submit information. If we discover that we hold data of a child under 16 without verifiable parental consent, we will delete it.
3. What personal data we collect
We collect only what is necessary for the service. Categories include:
3.1 Data you provide
- Account data — name, email, phone (optional), preferred language, the site/community you are associated with, role.
- Profile data — avatar photo, display name.
- Issues and reports you submit — title, description, category, status, and optionally photos, videos, or audio attachments.
- Event RSVPs and questions you post.
- Chat messages you send to the AI assistant or to platform staff.
- Survey and feedback responses.
3.2 Data collected automatically
- Device data — device model, OS version, app version, language, time zone, push-notification token.
- Usage data — screens viewed, actions taken, error logs.
- Approximate location — derived from IP address for security and analytics.
- Precise location (camera/GPS) — only when you explicitly attach location to an issue or photo. You control this in your device settings; we never read your location in the background.
- Camera, microphone, photo library — only when you choose to attach media to a report.
- Cookies / equivalent identifiers — strictly necessary cookies for sign-in. Our authentication cookies (
icda_session,icda_refresh_token) are HttpOnly, Secure and SameSite-restricted, so they cannot be read by scripts running in your browser. We also store your cookie-banner choices in a non-HttpOnly cookie (icda_cookie_consent) that must be readable by the page. Plus an anonymous device ID for crash reporting.
3.3 Data from third parties
- Identity provider (Keycloak) — when you sign in, we receive the claims in your access token (your user ID, email, role, site memberships).
- Mining-company partners — when an issue you raise concerns a specific operator, that operator receives the issue and any contact details you chose to share.
We do not intentionally collect special-category data (health, religion, political opinions, etc.). Do not include such data in your reports unless strictly relevant.
4. Why we use your data and the legal basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Create and operate your account, authenticate sign-in | Contract (Art. 6(1)(b)) |
| Receive, route, and resolve issues you report | Contract; legitimate interests of operators in addressing community concerns (Art. 6(1)(b)/(f)) |
| Send push, email, or in-app notifications you opted into | Consent (Art. 6(1)(a)); contract for transactional messages |
| Provide AI chat answers about your community, mining operations, or how to use ICDA | Contract |
| Improve ICDA — debugging, analytics, performance | Legitimate interests (Art. 6(1)(f)) |
| Comply with legal obligations (audit logs, lawful requests) | Legal obligation (Art. 6(1)(c)) |
| Research and reporting under the MASTERMINE Project | Public interest / legitimate interests, using aggregated and de-identified data only (Art. 6(1)(e)/(f)) |
You can withdraw consent at any time in Profile → Settings → Notifications, or by contacting us.
5. AI chat and third-party AI processing
ICDA's AI assistant is powered by a third-party AI service provider's large-language-model API. When you send a message to the AI:
- Your message and any retrieved knowledge-base context are sent to that provider's servers (within the EU/US, depending on routing) to generate a response.
- The provider acts as our sub-processor under a Data Processing Agreement.
- The provider does not use your conversations to train its models.
- We retain chat transcripts to maintain conversation continuity and for safety/audit purposes. You can delete your chat history from Profile → Privacy.
If you do not wish to use the AI assistant, simply do not open it — every other ICDA feature works without it.
6. Who we share data with
We share personal data only with:
- Mining-company partners at the site you belong to — for issues, events, and engagement they need to act on. They are independent controllers for that data.
- MASTERMINE consortium partners — only aggregated, anonymous statistics for research and reporting.
- Sub-processors that operate the platform on our behalf:
- AI service provider — AI chat (see §5).
- Hosting — cloud or on-premises infrastructure providers in the EU and South Africa.
- Push-notification provider — delivers notifications via Google's and Apple's native push services (device token only, no message content).
- Map-tile provider — renders map tiles and geocodes issue locations (approximate coordinates only, no user identifiers).
- Email provider — transactional email.
- App monitoring / crash reporting — receives anonymous error, crash and performance reports from the mobile app (device model, OS and app version, an anonymous device ID; no name, email or message content).
- Authorities — when required by law (court order, regulator request).
We never sell personal data and we do not run advertising.
The current, named list of our sub-processors — including which company fills each role above — is available on request from privacy@icda.app. We keep names out of this policy so we can change a named provider (e.g. for cost, performance, or compliance reasons) without triggering a re-publication of this document; the role each provider plays does not change when we swap it.
7. International transfers
Data is primarily stored in South Africa and/or the European Union. Where transfers cross borders (e.g. when calling our AI service provider's API), we rely on:
- EU Standard Contractual Clauses (SCCs), and/or
- Adequacy decisions where they exist, and/or
- POPIA s.72 lawful-transfer mechanisms.
8. How long we keep data
| Data | Retention |
|---|---|
| Account data | While your account is active, plus 12 months after closure for audit |
| Issues, events, RSVPs | 5 years for operational and historical reporting |
| AI chat transcripts | 12 months, or until you delete them |
| Server and security logs | 12 months |
| Backups | Up to 35 days, rolling |
| Aggregated, anonymous research data | Indefinitely |
Soft-deleted records are purged from active systems on a rolling schedule and removed from backups within 35 days.
9. Your rights
Under GDPR and POPIA you have the right to:
- Access the personal data we hold about you.
- Correct inaccurate or incomplete data.
- Delete your data ("right to be forgotten"), subject to legal retention obligations.
- Export your data in a portable, machine-readable format.
- Restrict or object to certain processing.
- Withdraw consent at any time, without affecting prior lawful processing.
- Lodge a complaint with a supervisory authority — the South African Information Regulator (https://inforegulator.org.za) or your national EU data-protection authority.
You can exercise the first four rights directly in Profile → Privacy → Export my data / Delete my account, or by emailing privacy@icda.app. We respond within 30 days.
10. Security
We use, among other measures: TLS 1.2/1.3 in transit, encryption at rest, role-based access control, multi-tenant database isolation (PostgreSQL row-level security), audit logging, regular security reviews, and least-privilege access for staff. No system is perfectly secure — if you suspect your account is compromised, contact us immediately.
11. Changes to this policy
We will post material changes in the app and on https://icda.app/legal/privacy and, where required, ask you to re-consent. The "Effective date" at the top reflects the latest version.
12. Contact
Questions? Email privacy@icda.app with the subject line "ICDA Privacy".