Data Protection Policy

Personal data is playing an increasingly important role in our economies, societies and everyday lives. New and innovative technologies are generating significant volumes of personal data, and modern communications networks and processing systems are enabling organisations to collect, analyse, use, share and store data on a global scale.

It is against this context that data protection legislation has been developed and implemented in various regions across the world.

Cartrack recognises the Data Subjects’ rights to privacy and is committed to protecting and controlling the use of the personal data that it collects, in accordance with the regulatory requirements of the jurisdictions in which it operates.

Executive management is continuously assessing the need to develop and implement or amend further policies, procedures and terms and conditions, including those with regard to data protection; consent policies and forms; data access; security breaches and employee privacy requirements.

This policy governs the collection, use and disclosure of personal data provided to Cartrack. It directs how we gather, store and handle personal data of Data Subjects, customers and other stakeholders, in accordance with relevant data protection legislation.

This policy applies to all legal entities within the Cartrack Group, including all employees, as well as third parties who provide services to the Group and covers personal data collected and managed by the Cartrack Group.

“Personal data” means any information or pieces of information relating to an individual, that could identify that individual, either directly (e.g. by name) or indirectly (e.g. through pseudonymised data). Personal data therefore includes things like email/home addresses, usernames, profile pictures, user generated content, financial information, and geolocation.

1. Collection/processing

   Cartrack will only collect personal data when it is necessary to comply with legal obligations that apply, or when such processing operation is necessary for the performance of a contract or pre- contractual procedures.

   Cartrack may also process information if it has a legitimate interest, provided that in each case our interest is in accordance with applicable law and the rights of the Data Subject.

   When none of the other lawful processing conditions support the data processing operation, Cartrack will only process personal information if it has obtained the consent of the Data Subject to process said personal data for specific, explicit and legitimate purposes.

2. Purpose

   Cartrack will only disclose or use personal data for the fulfilment of the specific purposes for which it was obtained, or for other lawful processing.

3. Accuracy

   Cartrack will take all reasonable steps to ensure that personal data that it processes is accurate, complete and up to date.

4. Openness

   Cartrack is committed to openness regarding its policies and practices of handling of personal data.

5. Security

   Cartrack will ensure that appropriate security safeguards are in place to protect personal data from loss, unauthorised access, destruction, use, modification or disclosure.

6. Transfers

   Cartrack may transfer personal data outside the European Union to be processed by some of its service providers, companies associated with and/or belonging to the Cartrack Group. In this case, Cartrack ensures that this transfer takes place in accordance with the legislation in force and that an adequate level of protection of personal data is guaranteed based on standard data protection clauses adopted, in accordance with Article 46 of the European Union General Data Protection Regulation (“GDPR”).

   Under no circumstances does Cartrack transfer personal data, outside the conditions described above, or sell personal data to third parties.

7. Retention

   Cartrack will retain personal data for as long as is necessary for the purposes for which it was collected. In some cases, data retention may occur for longer periods, especially when applicable law so requires.

8. Access

   The Data Subject may request a copy of their personal data from Cartrack and, where required, instruct Cartrack to effect changes to correct the data or to permanently delete their personal data, in accordance with local regulations.

Withdrawing consent or choosing to delete some types of personal data may prevent Cartrack from supplying certain services to a Data Subject, or responding to queries as a prospective employee or supplier. In order to better protect and safeguard personal data, Cartrack takes steps to verify the identity of a Data Subject before granting access or making changes to personal data.

Data Subjects that have any queries or concerns regarding Cartrack’s data protection policies or procedures may contact the Data Protection Officers at:

South Africa, Kenya, Tanzania, Namibia, Nigeria, Singapore, Mozambique:  dataprotection@cartrack.com

Poland, Portugal and Spain: dpo@cartrack.com

USA: dataprotection@cartrack.com

Hong-Kong, Indonesia, Philippines, Malaysia, Thailand, UAE: dataprotection@cartrack.com

Data Subjects also have the right to submit a complaint to the local Supervisory Authorities.

This policy framework falls within the scope and responsibility of the Risk Committee which reports to Cartrack’s Board of Directors.

Compliance is verified by Internal Audit which reports independently to the Board of Directors