1. The purpose of this privacy policy is to set out the basis upon which weprocess personal information when making use of our products and/or ourservices (“Products/Services”) or any of our platforms (herein aftercollectively referred to as our “Site/s”)
   
2. By utilising our Products/Services or any of our Sites, you are accepting andconsenting to the practice described in this privacy policy.
   

2. Interpretation and definitions:

1. Words that are defined in the Protection of Personal Information Act No. 4 of2013 (“POPIA”) and used in this privacy policy will bear the same meaning asin POPIA unless the context requires otherwise;
   
2. Reference to “consent” shall include any electronic means by which youconvey your acceptance and acknowledgement that you agree to usprocessing your personal information, whether it be by the clicking of abutton, or through biometric means, subscribing, submitting or sending of amessage, updating your profile or clicking “I Agree” button or pressing the“enter” button, or by any other means, to submit/convey any information tous; or signing of any documentation;
   
3. Any reference to singular shall include plural, and any reference to a certaingender shall include the opposite gender.
   

3. Introduction:

We recognise the importance of protecting your privacy in respect of your personalinformation collected by us.

1. In adopting this privacy policy, we wish to balance our legitimate businessinterests and your reasonable expectation of privacy. Accordingly, we willtake appropriate and reasonable technical and organisational steps toprevent unauthorised access to, or disclosure of your personal information.However, we do not guarantee that your personal information shall be 100%secure.
   
2. Where there are reasonable grounds to believe that your personalinformation has been accessed or acquired by any unauthorised person, wewill notify you and the Information Regulator which is appointed in terms ofPOPIA.
   
3. We will delay notifying you of the unauthorised access or acquisition of yourpersonal information if a public body responsible for detection, preventionor investigation of offences or the Information Regulator informs us thatnotifying you will impede a criminal investigation.
   
4. When we notify you of the compromise to the security of your personalinformation, we will provide you with sufficient information to allow you totake protective measures against the potential consequences of thecompromise.
   

4. Consent:

By continuing to use our Products/Services and/or our Site:

1. You agree to the terms set out in this privacy policy. If you do notagree with this privacy policy, please do not continue to use ourProducts/Services and/or our Site and/or the Products/Servicesprovided by any of our partners; and
   
2. You agree that we may process your personal information for,amongst other things, (i) the purposes of providing you with access toour Products/Services, our Site; and (ii) for any other purposes set outin this privacy policy.
   

5. Variation of privacy policy:

1. We reserve the right to vary the terms of this privacy policy. We will notify you of anysuch change and give you an opportunity to review the revised policy before you chooseto continue to make use of our Products/Services and/or our Site. It is your responsibilityto familiarise yourself with the most recent version of this privacy policy each time youaccess our Products/Services and/or our Site and before you elect to continue to makeuse of our Products/Services and/or our Site.
   

6. What type of personal information do we process:

The personal information that we may process includes information necessary for us toprovide you with the Sale/Products/Services and to protect and ensure our legitimatebusiness interests. This may include all of the categories of personal information listed inPOPIA, and amongst other, include at least all of the following information: –

1. Information and content you provide. We collect the consent, communicationsand other information you provide when you use our Products/Services, includingwhen you sign up for an account, create or share content, and message orcommunicate with us via our Site or via any other means.
2. Our systems automatically process content and communications you and othersprovide to analyse context and what’s in them for the purposes described below.We specifically process your name and identity number, e-mail and physicaladdresses, postal address, contact information, information relating to your race,gender, and age, and such other information regarding yourself and/or your viewsif you choose to share same via our Site;
   
3. Your usage. We collect information about how you use our Products/Servicesand/or our Site, such as the types of content you view or engage with; the featuresyou use; the actions you take; the accounts you interact with; and the time,frequency and duration of your activities. For example, we log when you’re usingand have last used our Products/Services and/or our Site, and what posts, pagesand other content you view on our Site. We also collect information about how youuse certain features of our Products/Services and/or our Site;
   
4. Vehicle Information. As described below, we collect information from and aboutthe vehicles through our DMS system as well as financial platforms and OEMprovided information every time a customer visits our site or makes use of ourservices.

Information we may obtain from these sources include:

1. Vehicle attributes: information such as the specification of the vehicle,VIN/Engine and Registration numbers, service intervals, repairs done andaccessories and parts specifically manufactured for the vehicle, battery testsand any other campaigns or information relating to your vehicle or partpurchased.
   

7. When will we process your personal information:

Personal information may be processed by us when:

1. You visit, browse, register, subscribe and/or apply for and use ourProducts/Services and/or our Site;
   
2. You register to receive any notifications from us in respect of ouremail authentication service and/or our text message authenticationservice;
   
3. We carry out research; and
   
4. When or if required by law; and
   
5. When and if it is in your best interest.
   
6. You acknowledge that all personal information processed by us may bestored by us and used, inter alia, for any of the purposes, but not exclusively,listed in clause 8 below.
   

8. How do we use your personal information:

We may use your personal information:

1. to deliver our Products/Services, including to personalise features andcontent (such as services, products and advertisements) and makesuggestions for you (such as pages, services and information you may4be interested in or topics you may want to follow) on or about ourProducts/Services or on our Site. To create personalised content thatare unique and relevant to you, we use your connections, preferences,interests and activities based on the data we collect and learn fromyou and others (including any data with special protections youchoose to provide); how you use and interact with our Site; and thepeople, places, or things you’re connected to and interested in, on andoff our Site.
   
2. to develop, test and improve our Products/Services and/or our Site,including by conducting surveys and research, and testing andtroubleshooting new products and services and features.
   
3. to select and personalise advertisements, offers and other sponsoredcontent that we show you;
   
4. we are not in the business of selling personal information andtherefore we will not disclose your personal information to anyoneexcept as provided in this policy. We may for marketing purposesdisclose aggregate statistics (information about the user population ingeneral terms) about your personal information to our advertisers orbusiness partners. It may be necessary for us to disclose personalinformation to suppliers, affiliates or agents (for example in order todeliver products to you which you have bought) in order to provideyou with our services. We will obviously need to disclose personalinformation to employees of ours who require such information to dotheir jobs. There may be situations where the law requires us todisclose your personal information. In all other situations we will notdisclose your personal information without giving you notice thereofand an opportunity to indicate that your personal information shouldnot be disclosed. to promote safety, integrity and security. We use theinformation we have to verify accounts and activity, combat harmfulconduct, detect and prevent spam and other bad experiences,maintain the integrity of our Products/Services, and promote safetyand security on and off of our Products/Services. For example, we usedata we have to investigate suspicious activity or violations of ourterms or policies;
   
5. to communicate with you. We use the information we have to sendyou marketing communications, communicate with you about ourProducts/Services, and let you know about our policies and terms. Wealso use your information to respond to you when you contact us;
   
6. For helping us in any future dealings with you; and
   
7. For any other purpose as legally authorised to do and as is allowed bylaw.
   

9. Where we store your personal information

1. All of the information you provide to us is stored manually, and/or on oursecure cloud based platform and/or servers operated, maintained andprotected in the Republic of South Africa (RSA);
   
2. Records of the personal information will not be retained for no longer than isnecessary for operational or archiving purposes, unless retention of record isrequired or authorised by law. Records of the information may be retainedfor periods in excess of those contemplated for historical, statistical orresearch purposes. This will be subject to us establishing appropriatesafeguards (which can include de-identifying the records) against the recordsbeing used for any other purpose;
3. Unfortunately, the transmission of information via the internet is notcompletely secure. We will use appropriate and reasonable technical andorganisational measurements to protect the information, we cannothowever guarantee the security of your data transmitted to our Site or toany other location by electronic means. Any transmission is at your own risk.However, once we have received the information, we will use appropriateand reasonable technical organisational measurements to try and preventunauthorised access.
   

10. Sharing of your personal information:

We will not disclose any of your personal information to any person, exceptwhen we have your consent and/or permission to do so or where we arerequired to do so in terms of law or if same is in your best interest;

You agree that your personal information may be shared: –

1. to our holding companies, subsidiary companies, agents, advisers,partners, service providers and suppliers, or in the event of a changecontrol if the ownership or control of all or a part of ourProducts/Services changes, we may transfer your information to suchnew owner.
   
2. where the law requires that we disclose your personal information toa party, and where we have reason to believe that a disclosure ofpersonal information is necessary to identify, contact or bring legalaction against a party who may be in breach of the terms or may becausing injury to or interference with (either intentionally orunintentionally) our rights or property, other users, or anyone elsethat could be harmed by such activities, or where the disclosure ofyour personal information would be in your best interest.
   

11. Your rights:

1. You have the right to, in accordance with these terms, request that wecorrect, destroy or delete any of your personal information that we have6processed on our Products/Services and/or our Site. The personalinformation that you may request us to correct, destroy or delete is personalinformation that has been processed in accordance with these terms that isinaccurate, irrelevant, excessive, out of date, incomplete, misleading,obtained unlawfully or that we are no longer authorised to retain.
   
2. You have the right to withdraw your consent for us to process your personalinformation at any time. The withdrawal of your consent can only be madeby you on the condition that the withdrawal of your consent does not affectthe processing of your personal information before the withdrawal of yourconsent; or that the withdrawal of your consent does not affect theprocessing of your personal information if the processing is in compliancewith an obligation imposed by law on us; or that the withdrawal of yourconsent does not affect the processing of your personal information wheresuch processing is necessary for the proper performance of a public law dutyby a public body; or that the withdrawal of your consent does not affect theprocessing of your personal information as required by law; or that thewithdrawal of your consent does not affect the processing of your personalinformation as required to finalise the performance of a contract in whichyou are a party; or that the withdrawal of your consent does not affect theprocessing of your personal information as required to protect yourlegitimate interests or our own legitimate interests or the legitimateinterests of a third party to whom the information is supplied.
   
3. You have the right to object to the processing of your personal informationat any time, on reasonable grounds relating to your particular situation,unless the processing is required by law. You can make the objection if theprocessing of your personal information is not necessary for the properperformance of a public law duty by a public body; or if the processing ofyour personal information is not necessary to pursue your legitimateinterests, our legitimate interests or the legitimate interests of a third partythe information is supplied to.
   
4. You have the right to object to the processing of your personal information,at any time, if the processing is for purposes of direct marketing other thandirect marketing by means of unsolicited electronic communications and youhave not given your consent for that processing.
   
5. You have the right to not have your personal information processed forpurposes of direct marketing by means of unsolicited electroniccommunications from third parties unknown to you.
   
6. You have the right to submit a complaint to the Information Regulatorregarding an alleged interference with the protection of personalinformation processed in accordance with these terms. The InformationRegulator’s contact details are published by the government from time totime in terms of POPIA. When they are published POPIA places a duty on usto inform you what those contact details are and we will do so via ourProducts/Services and/or our Site.
   
7. You have the right to institute civil proceedings regarding an allegedinterference with the protection of your personal information processed inaccordance with these terms.
   

12. Use of cookies:

1. We sometimes use "cookies". "Cookies" are programs that we transfer toyour computer's hard drive. The purpose of "cookies" is to enhance yourfuture visits to our website. You can set your browser to notify you if"cookies" are to be transferred or to reject "cookies" but this may preventyour use of some of our web pages.
   

13. Links to other Sites:

When you use our Products/Services and/or our Site, you could be directed to other site/sthat are beyond our control. These other site/s may send their own cookies to you, collectdata or solicit personal information. We do not control the privacy policies of those thirdparty and we cannot be held liable for the use thereof by you for any reason whatsoever.

14. Direct Marketing:

1. We may process your personal information for the purposes of providing youwith information regarding services that may be of interest to you. You mayunsubscribe for free at any time.
   
2. If you currently receive marketing information from us which you wouldprefer not to receive in the future please email us or alternatively,unsubscribe using the unsubscribe function when receiving marketingcommunication from us.
   

16. Contact Details:

You may contact us at –

1. The POPIA Information Officer:
   
2. Attention: Mr. Mark Jonathan White
   
3. Contact Number: 011 840 1960
   
4. Email address: [email protected]
   

Last updated: 30th June 2021