Multitrack POPI-Act

DATA PROTECTION POLICY THE PROTECTION OF PERSONAL INFORMATION ACT 4 OF 2013 CUSTOMER.

1. Persons accessing the Multitrack website, and making use of our product and
service offering, subject themselves to and agree to Multitrack (Proprietary)
Limited’s terms conditions and privacy policy, as set out below.

2. INTRODUCTION

2.1.We respect your privacy and take it very seriously. We are Multitrack (Pty)
Ltd, and this is our plan of action for the protection of your personal
information. It describes how we collect, use, disclose, and store your
personal information.

3. APPLICATION

3.1.This policy applies to you when you visit our website and use our products or
services as a customer.

4. PERSONAL INFORMATION

4.1.We collect the following personal information: –
4.1.1.Your full name;
4.1.2.Identity number;
4.1.3.Address;
4.1.4.Contact information;
4.1.5.Location information;
4.1.6.Vehicle information.

4.2.We obtain such personal information by the following means: –
4.2.1.When you log into our website or use our GPS tracking platform;
4.2.2.Upon acceptance, on registration or submission;
4.2.3.through an order; or
4.2.4.provided by you voluntarily.

4.3.Please note, that in terms of the Protection of Information Act, you may only
send us your own personal information or someone else’s personal
information if you have their permission to do so.

5. ACCEPTANCE AND CHANGES

5.1.You may not order any of our products or services if you do not accept this
policy or any changes to it.

5.2.We may change this policy at any time and will notify you of the changes on
our website, through our platform, or by email. The changed policy applies to
you if you continue using our website, or our products or services following
the notification.

6. COLLECTION

6.1.When you visit our website, we automatically collect your Internet usage
information (including your IP address, browser details, and usage
information) through your browser, which we may use to display our website
correctly, track your activities on it, or for other necessary purposes.

6.2.When you use our products and services, we automatically collect your
application usage information (including your operating system version and
other relevant system information) through analytics software and other
technologies, which we may use to optimise our offering to you.

6.3.We may ask you to provide us with certain identifying information (including
your first name, surname, and email address) when you register on or
otherwise submit information through our website or platform for the first
time.

6.4.We ask you to provide us certain personal information (including your first
name, surname, contact information, email address, and banking details)
when you order our products or services.

6.5.We may ask you to provide us certain optional information on a voluntary
basis.

6.6.Consent to collection
6.6.1. You consent to us using, collecting, processing, and storing your
personal information in accordance with applicable law.

6.7.Lawful Purposes
6.7.1. We may use, collect, and process your personal information that you
provide to us for the purposes for which it was collected and agreed
with you, such as: –
6.7.1.1.Legitimate business purposes, in order to provide you with the
products and services we offer.

6.7.2. In addition, where necessary your information may be retained for legal
or research purposes, such as: –
6.7.2.1. To gather contact information;
6.7.2.2. To confirm and verify your identity or to verify that you are an

authorised user for security purposes;
6.7.2.3. For audit and record keeping purposes;
6.7.2.4. In connection with legal proceedings.

6.7.3. Processing includes gathering your personal information, disclosing it,
and combining it with other personal information.

6.7.4. All personal information processed by a responsible party must be
done on one of the following bases: –
6.7.4.1.Consent;
6.7.4.2.Contract;
6.7.4.3.Legal obligation;
6.7.4.4.Vital interests;
6.7.4.5.Legitimate interests.

7. USE

7.1.Processing
7.1.1.We may process your personal information to fulfil our obligations to you
i.e. for legitimate business purposes.

7.2.Cookies
7.2.1. We may place small text files on your device when you visit our website
that allow us to provide you with a personalised experience by
associating your personal information with your device. They let us
remember your preferences, allow third parties to provide services to
you, and otherwise serve useful purposes for you. Your internet
browser generally accepts them automatically, but you can often
change this setting or delete them manually. However, we won’t be able
to provide you with access to certain aspects of our website where
cookies are necessary if you do so. We have no access to or control
over any cookies that our business partners use on our website and
they have their own privacy policies that govern them.

7.3.Messages
7.3.1. We may use your identifying information to send you administrative and
update messages about our website or platform.

7.4.Promotional messages

7.4.1. We will not send you promotional messages unless you have chosen to
opt into them. But, we may send you one message asking you to opt
into promotional messages without you having opted into promotional
messages.

7.5.Recording calls
7.5.1. We may monitor and record any telephone calls that you make to us,
unless you specifically request us not to.

8. DISCLOSURE OF INFORMATION

8.1.We may share your personal information with third parties with whom we
contract for the purposes of fulfilling our obligations to you, including with:
8.1.1. other companies or divisions within our group;
8.1.2. our contractors who help us meet our obligations to you, including
those that help us understand your personal information; or
8.1.3. to provide our ongoing service to you; or
8.1.4. third parties as required by applicable law.

8.2.We will require anyone that we share your personal information with to
honour this policy whenever possible in terms of applicable law to ensure that
personal information that we remain responsible for, is kept secure.

8.3.We may also disclose your information, where we: –
8.3.1.have a duty or right to disclose in terms of law or industry codes;
8.3.2.belive it is necessary to protect our rights.

8.4.Marketing purposes
8.4.1. We may disclose aggregate statistical information that we derive from
your and other people’s personal information to our advertisers or
business partners.

8.5.We may need to disclose personal information to our personnel to do their
jobs but will not do so unnecessarily.

8.6.We may assign our rights to the personal information we process to our new
owners if our ownership changes for any reason.

9. SECURITY

9.1.We take the security of personal information very seriously and always do our
best to comply with applicable data protection laws. Our website and cloud
service are housed in a secure server environment that uses a firewall and
other advanced security measures to prevent interference or access from
outside intruders. We implement disaster recovery procedures where
appropriate.

10.STORAGE

10.1. You may ask us to provide you with a description of the personal
information that we hold on you, correct or update it or delete it (provided
that we do not need it to fulfil our obligations to you or applicable law does
not require us to keep it). We will take all reasonable steps to verify your
identity before doing so. We may charge a fee to recoup our costs
associated with this request if there is a cost to us associated with it and
provided that applicable law allows us to do so. Please contact us with your
name, and a copy of your identity document in order to identify you
correctly if you want access to information or want us to correct, update or
delete it.

10.2. We will do our best to keep your personal information that we collect
accurate, complete, and up to date.

10.3. We may ask you to update your personal information from time to time but
will take steps to verify your identity to prevent unauthorised access when
doing so.

10.4. We will only keep your personal information for as long as is necessary to
fulfil our obligations to you, unless you have given us permission to keep it
longer or we are otherwise legally allowed to do so.

10.5. Transfer. We may transfer your personal information outside of the country
in which it was collected to a foreign country. You consent to us processing
your personal information in a foreign country with less stringent data
protection laws than the country in which it was collected.

11. GENERAL

11.1. You may update or remove your personal information:
11.1.1. through our website or application; or
11.1.2. by contacting us.

12.LIMITATION

12.1. We are not responsible for anyone else’s privacy policies or practices.

13.BREACH

13.1. In the event of a breach of security leading to the accidental or unlawful
destruction, loss, alteration, unauthorised disclose of, or access to,
personal information we shall promptly access the risk of the data
subjects’ rights and freedoms and if appropriate report the breach to the
Information Regulator as soon as possible.

14.HOW TO CONTACT US

14.1. If you have any queries about this policy; you need further information
about our privacy practices; wish to withdraw consent; exercise

preferences or access or correct your personal information, please
contact us at the numbers/addresses listed on our website.