NAVIGATING ARTIFICIAL INTELLIGENCE PERSONALISATION AND CONSUMER PRIVACY IN DIGITAL MARKETING ACROSS SOUTH AFRICA AND GLOBAL CONTEXTS

Abstract

Artificial Intelligence (AI)-driven hyper-personalisation has reconfigured digital marketing by embedding predictive analytics and automated decision-making into everyday consumer interactions. While these systems enhance marketing efficiency and engagement, they simultaneously intensify concerns regarding surveillance, behavioural manipulation, and erosion of consumer autonomy. Existing global scholarship recognises these risks; however, limited context-specific analysis interrogates how such dynamics unfold within emerging regulatory environments. This study addresses that gap by critically examining how AI-driven hyper-personalisation reshapes consumer privacy in South Africa and evaluating the adequacy of its regulatory framework in comparison with international standards such as the European Union’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). A desktop-based systematic literature review was conducted using the Preferred Reporting Items for Systematic Reviews and Meta-Analyses (PRISMA) framework to synthesise peer-reviewed studies published between 2019 and 2025. The findings reveal that AI-driven personalisation systems operate through opaque algorithmic profiling mechanisms that weaken informed consent and shift control away from consumers. Although South Africa’s Protection of Personal Information Act (POPIA) establishes foundational data protection principles, it lacks AI-specific provisions addressing explainability, automated decision-making, and effective consumer redress. In contrast, while the GDPR and CCPA provide more explicit safeguards, enforcement and technical interpretability challenges persist even within these jurisdictions. The study argues that the regulatory disparity between South Africa and more mature digital economies exposes local consumers to heightened risks within transnational digital marketing ecosystems. It concludes that strengthening AI-specific governance, enhancing institutional audit capacity, and embedding ethical design principles are necessary to reconcile technological innovation with consumer rights in both South African and global contexts.