PRIVACY POLICY

PRIVACY POLICY

The Protection of Personal Information Act, 2013 (“POPI Act”) regulates the manner in which personal information may be processed, by establishing conditions, in harmony with international standards, that prescribes how organizations collect, use, store, protect, transfer and destroy personal information. For purposes of this Privacy Policy, “process” means collect, use, store, protect, transfer, destroy or otherwise act on personal information.

The POPI Act promotes a Privacy Policy to demonstrate the processing of personal information amongst other relevant factors.

Personal information is described in better detail under the heading: “Personal Information/Data We Collect”.

WHO WE ARE

Salvador Caetano South Africa (Proprietary) Limited trading as GAC South Africa (Company registration number: 2023/795686/07) (“Salvador Caetano SA” or “GAC SA” or “our” or “we” or “us”), is a group company of Grupo Salvador Caetano, SGPS, S.A. Salvador Caetano trading operations has its humble beginnings in 1946. Our Group has been in business for a long period of time, and we respect and value the privacy of our customers’, authorized dealers, vendors, suppliers, stakeholders, employees, and other data subjects (“your personal information”). We appreciate the importance of protecting your personal information, when making use of our website, call centers, mobile application, attendance at our dealership, attendance at our authorized dealerships, attendance at of head office, social media interactions or any other interaction that you may have with us.


PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to inform you about how we process any personal information/data.


PERSONAL INFORMATION/DATA WE PROCESS

We may process the following kinds of Personal Information:


1. Your identity which includes information such as your first and last name, date of birth, title, and other identifiable information that you may have provided at some time.


2. Your contact information which includes information such as email address, mobile/telephone numbers, street address, postal address, and any other information you have given to us for purposes of communication or dealing with you;


3. Your financial information which includes information such as your bank account details and credit card/debit card details;


4. Transaction information which includes details about payments or communications to and from you as well as information about the vehicles, products, and services you have purchased from us;


5. Personal data that you enter into an online inquiry, applications for finance and questions you ask via e-mail, through our call centre, chatbot or other form of communications;


6. Technical information which includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or our mobile application;


7. Your profile which includes information such as your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses;


8. Marketing information which includes your preferences in receiving marketing from us, communication preferences, responses, and actions in relation to your use of our vehicles, products and services.

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information includes information that does not identify you as an individual. Aggregated information may be derived from your Personal Information but is not considered Personal Information in law as it does not reveal your identity.

For example, we may aggregate profile information to assess interest in a vehicle, product or service.

However, if we combine or connect aggregated data with your Personal Information so that it can identify you in any way, we treat the combined data as Personal Information, and it will be used in accordance with this Privacy Policy.


SPECIAL CATEGORIES OF PERSONAL INFORMATION

Generally, we do not collect Special Personal Information, which includes data about your race or ethnicity, religious or philosophical beliefs, sexual identification, political opinions, trade union membership, information about your health and biometric data.

We may only collect Special Personal Information about you if there is a lawful basis on which to do so.


IF YOU DO NOT PROVIDE PERSONAL INFORMATION WE NEED

Where we need to collect Personal Information by law, or under the terms of a contract, we have with you, and you fail to provide that information when requested, we may not be able to perform and/or complete that contract or transaction. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.


WHAT WE DO WITH YOUR PERSONAL INFORMATION

We process your Personal Information for the purposes set out below. Please be informed that insofar as we already hold Personal Information about you, we may use that information for the same purposes.

1. For the performance of a contractual obligation with you

When you purchase vehicles, products and/or request services from us (in person and/or online), or otherwise, you are required to agree to our standard terms and conditions, at which point a contract is formed between yourself and us.

In order to properly manage and handle your purchases and/or to provide you with the services you request from us, we use your contact details, your account information provided, electronic identification data as well as information regarding your purchases.

Further and in order to carry out our obligations under that contract, we must process the information you give us. Some of this information may be considered Personal Information.


Accordingly, we may use the information in order to:

  • verify your identity for security purposes;

  • sell vehicles, products, and services to you;

  • provide you with our services; and

  • provide you with suggestions and advice on vehicles, products, and services;

  • provide you with information on how to obtain the most value from using our website.


2. To comply with applicable laws

Any Personal Information referred to in paragraph 1 above may be used to maintain appropriate business records, to comply with lawful information requested by public authorities and to comply with applicable laws and regulations or as otherwise required by law.

3. Information we process for the purposes of legitimate interests

We may process your Personal Information on the basis that there is a legitimate interest, either to you or to us.

Where we process your Personal Information on this basis, we do so after having given careful consideration to:

  • whether the same objective could be achieved through other means;

  • whether processing (or not processing) might cause you harm; and

  • whether you would expect us to process your personal information, and whether you would consider it reasonable to do so.


The Personal Information/data referred to in paragraph 1 above may also be used by us:

  • to generate aggregated statistics about the drivers of our vehicles and the users of our products and services;

  • to assist in security and fraud prevention;

  • for system integrity purposes (preventing data breaches, hacking, spamming, phishing etc.);

  • to facilitate our business operations, to operate company policies and procedures;

  • for other legitimate business purposes permitted by applicable law.


4. Information we process with your consent

Where there is no contractual relationship between you and us or legitimate purpose for us to process your Personal Information, you may through certain actions such as when you browse our website or ask that we provide you with more information about our business, including our vehicles, products and services, you provide your consent to us to process your information which may include Personal Information.

Wherever possible, we aim to obtain your consent to process this information, for example, by asking you to agree to our use of cookies.

We continue to process your Personal Information on this basis until you withdraw your consent or where it expires.

If you have given us consent to do so, we will use your contact details for you to receive the latest offers and vehicle, service and product updates, general marketing materials as well as surveys about our vehicles, our products and our services. At any time, you may opt out of / unsubscribe from receiving the previously mentioned materials by following the instructions in any communication you receive from us.

We will use your Personal Information referred to above in paragraph 1 above to improve our vehicles, products and services as well as to understand our customers both on an aggregated and on an individual basis.


5. Sharing Information

We will share your Personal Information with our group companies and selected associates to fulfil warranty and service obligations and recall obligations if and when the need arises.

We do not and will not sell or provide your Personal Information to third-parties for independent use.

We may, however, share Personal Information with selected associates whom we consider may provide services or products you would find useful if that information is required to provide the product or service you have requested.


6. Third Party Websites

When you use a third-party website or platform to provide us with your Personal Information, that information may also be processed by that third-party.

We encourage you to view and understand the privacy policy and data protection polices of that third-party. The privacy policy of the third-party applies to any Personal Information the third-party may collect. If our website contains any links to other websites, we are not accountable for their privacy and data protection practices as we do not control those websites.



COMMUNICATING WITH US

When you contact us, whether by telephone, through our website or by way of email, or in person, or any other method of communication (such as WhatsApp), we collect the Personal Information you provided to us in order to allow us to reply with the information that you need.

We record your request and our reply in order to increase the efficiency of our business operations.

We keep personally identifiable information associated with your messages, such as your name and email address to be able to track our communications with you to provide a high-quality service.


COOKIES

Cookies are generally described as small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalized experience and the website owner with statistics about how you use the website so that it can be improved.

For more about the cookies we use, please have a look at our Cookie Policy.


INFORMATION MAY BE PROCESSED OUTSIDE SOUTH AFRICA

We may transfer your Personal Information outside of South Africa depending on your relationship with us and what services you require.


We may also use outsourced services in countries outside South Africa from time to time in other aspects of our business.


Accordingly, information obtained within South Africa could be processed outside South Africa within jurisdictions which may not adhere to laws regarding protection of Personal Information or data. We will endeavour to conclude appropriate contracts to protect your Personal Information.

SECURITY

We take reasonable technical and organisational measures to secure the integrity of retained Personal Information, using accepted technological standards to prevent unauthorised access to or disclosure of your Personal Information, and protect your Personal Information from misuse, loss, alteration or destruction.

From time to time, we review our information collection, storage and processing practices, including physical security measures, to keep up to date with industry good practice.

Even by taking the above measures when processing Personal Information, we cannot guarantee that our security considerations are full proof.

In the event of a data breach which in any way compromises or might compromise your Personal Information, we will notify you in accordance with our data breach policy. If you have any reason to believe that your interaction with us is no longer secure, please immediately notify us on personaldatamanagement@salvadorcaetano.co.za



RETENTION PERIOD

Except as otherwise mentioned in this Privacy Policy, we keep your Personal Information only for as long as required by us:

  • to provide you with the vehicles, services and products you have requested;

  • by law or a contract for lawful purposes related to our functions and activities;

  • to support a claim or defence in court or other legal forum; and

  • for security and fraud prevention purposes.


UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website.


GENERAL

If any provision of this Privacy Policy is judged to be illegal, void or unenforceable due to applicable law or by order of a court of a competent jurisdiction the offending provision shall be deemed severable from the remaining terms of this Privacy Policy. The unaffected portions of this Privacy Policy will continue to be in full force and effect and the remainder of the provisions will not be prejudiced.

If we or you do not enforce any right in terms of this Privacy Policy it will not constitute a waiver of that right.

YOUR RIGHTS

Your duty to inform us of changes

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes.

Access to your Personal Information

At any time, you may review or update the Personal Information that we hold about you.

To obtain information about your Personal Information, please follow the PAIA Manual.

After receiving the request, we will respond in accordance with the PAIA Manuel.


Removal of your information

If you wish us to remove Personal Information, you should contact us to make your request.

If you remove your Personal Information or withdraw your consent to process your Personal Information, this may limit or terminate the service we can provide to you.



CONTACT US

If you have any questions regarding our Privacy Policy, would like to make specific requests regarding your Personal Information or exercise your rights in terms of your Personal Information, please contact us using the following: