Ctrack Africa (Pty) Ltd with registration number 2021 / 327542 / 07 having its registered Head Office at 9 Regency Drive, Route 21 Corporate Park, Irene Ext 30, Centurion 0046, together with any Group companies (“we”,”us”,”our”) commit to protect and respect your privacy.
2. Website Visitors
By using the Ctrack South Africa website, you consent to the data practices described in this statement.
2.1 We may a) collect and b) process your personal data under the following circumstances:
2.1.1 when you complete any forms on our website (“Site”), including but not limited to your names, telephone numbers, email address and city, either when you enquire about our goods and services, subscribe to a mailing list or when you subscribe to, or request and services and/or goods.
2.1.2 when any information is provided to us when lodging a request, complaint or reporting any problem, or contacting us for any other reason. When this contact is made, we may keep a record of this interaction.
2.1.3 when you visit our Site, details of your visits including but not limited to, traffic data, location data, web browser type, operating system, and any other communication data, whether required for our billing purposes or not, including the resources you access – see Çookie statement at point 2.2.2.
2.1.4 whenever you disclose your personal information to us, or it is collected from you in any other way, via our Site.
2.2 We may also collect data in the following ways:
2.2.1 We may collect information about your device, including
Internet Protocol address (for fraud detection). This includes the device’s operating system and web browser for system administration, website performance, website analytics and to report aggregate information to our advertisers. (This is statistical data about user browsing interactions and patterns, and does not identify any individual).
Our Site uses ‘cookies’ to help you personalize your online experience when visiting us. It cannot be used to execute any software or deliver a malicious payload and can only be read by a web server in the domain that issued it to you in the first place.
The purpose of the cookie is to inform the web server you have returned to a specific web page and saves you time by storing your personal information such as billing address, shipping address, email address and so on. The next time you return to the same web page, the information is already stored in the cookie in the event you would like to place an order or request further information.
2.3 We may use your personal data for legitimate business interests to do the following:
2.3.1 deliver the services and information you have requested from us, as well as inform you of any other products and services available from Ctrack South Africa and its affiliates.
2.3.2 share data with vetted, trusted partners to assist with statistical analysis, send email or postal mail, provide customer support, or to arrange deliveries and/or collections. These trusted partners will have to have signed our POPIA agreement where they agree to be bound by the requirements of the above document.
2.3.3 keep records of which web pages and sites our customers visit within the Ctrack SA website so we can establish what services are the most popular. Based on this, we can deliver customized content and advertising to Ctrack SA clients whose behaviour indicate what they are interested in.
2.3.4 improve our Site, services, and content
2.3.5 remediate any complaints or respond to any enquiries.
Ctrack South Africa encourages you as our client to carefully review the privacy statements of any web sites you choose to connect to, from the Ctrack SA web site, so that you understand how those 3rd party web sites collect, use and share your information. Ctrack SA is not responsible for any content, or privacy statements on web sites beyond their jurisdiction.
3. What Ctrack SA will not do with your data:
3.1 will not sell, rent, or lease customer lists to third parties
3.2 will not use or disclose sensitive personal information including but not limited to, race, religion, political affiliations if any, without explicit consent.
3.3 will not disclose your personal information without notice, except when required to do so by Law or in the good faith belief that the action is necessary to a) conform to the edicts of the Law or comply with due legal process served on Ctrack SA or the Site; b) protect and defend the rights or property of Ctrack SA; and c) under exigent circumstances to protect the personal safety of users of Ctrack SA, or the public.
4.1 When you order goods or services from us, personal details including name, address, telephone number, email address and bank account details may be collected. This enables us to process any orders and comply with our contractual obligations.
4.2 To establish contact with you, it may be required that we share personal data with a third party including but not limited to I.T. service providers, payment providers and postal services. These third parties will need to have signed and agreed to our POPIA compliance agreement.
4.3 We may advertise your feedback on our Site and marketing materials, subject to obtaining explicit permission to so beforehand.
4.4 Your information will be retained while we’re still providing you with services or goods ordered from us, and for a further 5 years to adhere to legislation, accounting and tax requirements applicable to our business.
5. Telematics and Customer Staff
We will collect telemetry data by way of a telematics unit that enables our clients to establish who is driving a vehicle, how they are doing it, when and where. We provide software to our clients that allows them to access this data via our Online Portals. Personal information pertaining to the staff employed by our customers is input into our software by our clients for above-mentioned reasons.
We will also collect details including but not limited to, name, address, telephone number, email address and banking details so that we can contact you about services and goods ordered from you, to place additional orders and to pay you for the goods and services provided. This information will be kept for a period of 5 years after services have been cancelled to comply with legislation, accounting and tax requirements applicable to our business.
7. Failure to Provide Personal Data
In any situation where the law requires us to collect personal data or where the terms of a contract dictate it, and the requested data is not provided, we may not be able to conclude the contract we are attempting to enter or execute on it (where we are trying to provide goods or render a service to you). In the event this occurs, we may have to cancel said product or service you have with us, after notifying you.
8.1 Over and above the uses described in the previous sections where you, our client indicate that you would like to receive any marketing correspondence from us, subscribe to any type of mailing list or newsletters, in digital or natural form, or enter into any competitions or events, or when you provide us with your details at any events, we may use your personal information for our legitimate interests to provide you with information about our goods, services, business updates or events which we think will be of interest to you.
8.2 You have the right to ‘opt-out’ of receiving the information detailed in point 8.1 at any time and may do this by:
8.2.1 selecting a form field denoting “No, I do not wish to receive any further marketing material” on the prescribed form to indicate that you do not wish to receive any more notifications from us, in any format.
8.2.2 clicking the Unsubscribe button in any communications received from us.
8.2.3 email us at CtrackMarketing@ctrack.com providing us with your name and details and request to cease receiving notifications.
8.2.4 any personal data that was provided to us in between the time your consent was provided until the time it was retracted will be kept for the data retention period stipulated in our Data Retention policy, after which it will be pseudonymised.
9. Monitoring and Recording
We may monitor and record communications with you, including telephone communications, online communications and emails for quality assurance, training requirements, fraud prevention and compliance. CCTV cameras are also installed on our premises for crime prevention and Safety and Health reasons. This data is retained for as long as it is required by us, according to the retention period in our Data Retention policy.
10. Automated Processing
10.1 Your data may only be used for any automated processing for targeted marketing campaigns after having received your consent in writing.
10.2 We may perform credit checks on our customers so that we can a) make informed credit decisions about you and b) prevent fraud and money laundering activities
10.3 Our searches will be recorded on the credit agency’s files.
Pursuant to undertaking a credit check and you receive a low score, we reserve the right to not supply services or goods to you on credit and/or require an upfront payment for any services or goods you wish to purchase.
10.4 If any inaccurate or blatantly false information is provided by you and we suspect fraud, this will be recorded. If you wish to review your credit rating, please contact Experian, the credit agency we use for credit verification.
11. Legal Grounds for Processing Personal Data
11.1 Your personal data will only be used where the South African law permits it. To define this usage, it will be used in the following circumstances:
11.1.1 for entering into a contract/agreement with you
11.1.2 where necessary for compliance with legal or regulatory obligations we are subject to
11.1.3 for our legitimate interests as describe previously in this document, and where your interests and fundamental rights do not override these interests.
12. Disclosure of Personal Data to Third Parties
12.1 In addition to the previously referenced third parties, we may disclose your information to certain third parties for our legitimate interests in the following circumstances, subject to them having agreed to our POPIA compliance agreement in writing:
12.1.2 to our staff so they may execute the provision of services and goods to you.
12.1.3 to vetted affiliated entities who support our internal administrative functions
12.1.4 professional advisors including but not restricted to lawyers, bankers, consultants, and insurers who render legal, banking, consulting, and insurance services to us.
12.2 Where we are bound by legal obligation, or in order to enforce or apply our website terms and conditions and agreements, or to protect our rights, property or the safety of our customers or others, we may disclose personal data to the police, regulatory bodies, legal advisors or similar third parties.
12.3 We will not distribute or sell personal data to any organization without your express permission.
13. Cross-Border Data Transfers
Any data transfer within the Group is permitted provided a Data Sharing agreement is in place between Group entities.
14. Data Security
14.1 Where you have been provided with a password or have selected a password that enables you access to portions of our Site, the onus is on you to ensure the password is kept secret, is sufficiently strong/complex and is not shared.
14.2 Due to inherent security risks attached to using the Internet, the security of any information transmission cannot be absolutely guaranteed when transmitting data to our Site. Any transmission of data is performed at your own risk. We do employ encryption via the use of SSL certificates that ensure any traffic between our Site and your person is encrypted, especially when inputting data like credit card detail or other personal information.
14.3 The information you provide to us is stored on secured server infrastructure within secured environments. Physical, technical, and organizational security measures have been implemented to secure your information against a) accidental loss, and b) unauthorised access, use, alteration, or disclosure. All access is also minimized to only those employees, vetted contractors, agents and any third parties that have a legitimate business reason for said access.
15. Personal Data Access, Updating, Deletion and Restricted Use
15.1 The personal data we hold about you must be kept current and accurate. That said, please inform us of any changes to the above detail.
15.2 Data protection legislation provides you with the right to object to the processing of your data in certain circumstances, as well as withdraw any consent to the processing of your personal information where it has been provided to us. You also have the right to access any information held about you and have it provided to you in an easy-to-read format/medium. To request a copy of all, or a subset of the information held about you, kindly send an email to DPO@ctrack.com with your request.
15.3 You may also request the following:
15.3.1 that your personal information be updated if you state it is inaccurate
15.3.2 that we remove all your personal data from any database or repository completely
15.3.3 that we send you all, or a subset of your personal data in a commonly used medium/format and transfer your data to another entity after you have provided the entity details to us. This may be processed electronically with your consent or where necessary for the execution of a contract.
15.3.4 that we restrict the use of your personal data
15.4 To confirm your identity and right of access, we may request specific information from you, as well as to be able to provide you with the personal data we store about you, or to make requested changes to it.
In certain instances, data protection legislation may allow us or require us to refuse to provide you access to some, or all your personal data, or even to comply with any request made in accordance with your rights previously referred to.
In this situation, if we cannot provide you with the requested access to your personal data, or assist you with any other request, we will inform you as to the reasons why, subject to legal and/or regulatory restrictions.
15.5 Kindly address any requests relating to the above to Ctrack South Africa’s Data Protection Officer at DPO@ctrack.com or via registered postal mail to: Ctrack, P.O. Box 68270, Highveld Park, Centurion, 0169, specifying your name, as well as the actions you require us to take.
16. Right to Withdraw Consent
Where you have consented to the collection, processing, and transfer of your personal data, you also have the right to withdraw your consent under certain conditions. To action this, please contact us at CtrackMarketing@ctrack.com
We reserve the right to amend this policy at any time, and any changes will be posted on this page. You will be notified if there are any changes that materially affect the way your personal data is collected, stored or processed for reasons other than the ones originally specified. We will provide you with a notice and where required by law, seek your consent before using your personal data for a new, unrelated purpose.
For escalation on any matters you feel are not being addressed correctly, please email the Information Regulator at InfoReg@justice.gov.za