1. Application and purpose of this notice
TiAuto Investments (Pty) Ltd (hereinafter referred to as “TiAuto”, “we” or “us”) wishes to be transparent with its customers, prospective customers, job applicants, employees, policyholders and website users, suppliers and visitors to TiAuto’s premises (collectively referred to as “data subjects” or “you”) in respect of its processing of your Personal Information.
This Privacy Notice aims, amongst other things, to inform you about important information regarding:
- the Personal Information we process about you;
- the purposes for such processing;
- how TiAuto undertakes to keep your Personal Information secure;
- what rights you have in respect of your Personal Information in terms of the Protection of Personal Information Act (“POPIA”) and how to exercise those rights.
This privacy notice represents the “processing” (including the collection, use, storage, updating, distribution, alteration and destruction) of Personal Information by TiAuto including all the brands within the group including Tiger Wheel & Tyre, TYRES & MORE®, Treads Unlimited, Treads for Africa, Used Tyres SA, Wheel Collision and Mobile Mag Medic.
2. What is Personal Information?
Personal Information has a wide definition in terms of POPIA and includes any information which can be used to identify you. We have included the definition of POPIA below for your information, however, TiAuto does not collect all categories of Personal Information described below. We only collect the Personal Information we need for our specific business purposes as described in this privacy notice.
Personal Information as defined in POPIA includes:
- information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, wellbeing, disability, religion, conscience, belief, culture, language and birth of the person;
- information relating to the education or the medical, financial, criminal or employment history of the person;
- any identifying number, symbol, email address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
- the biometric information of the person;
- the personal opinions, views or preferences of the person;
- correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
- the views or opinions of another individual about the person; and
- the name of the person if it appears with other Personal Information relating to the person or if the disclosure of the name itself would reveal information about the person;
3. What Personal Information is collected and from where?
TiAuto collects Personal Information directly from you, the data subject, unless stated otherwise in this privacy notice.
- Customer: We collect your Personal Information directly from you when you contact us (whether by phone, email, social media or in person in one of our stores) in relation to our products or services; general queries or complaints or when you respond to any marketing campaigns including competitions. Personal Information collected includes your name, surname and contact details (email address and telephone number). We may also collect / update incomplete Personal Information from Baker Street Data Sciences and Analytics (Pty) Ltd in order to enrich and improve the quality of Personal Information we have about you on an ongoing basis.
- Driver and car owner: We collect Personal Information about the driver and car owner of a vehicle that is brought to a TiAuto company to perform an inspection or assessment of a vehicle. The Personal Information processed includes the driver and/or car owner’s name, contact details (email address and telephone number), identity number, insurance details, vehicle details (including car photographs, car registration number, car licence number, VIN number of the vehicle which can be linked to the vehicle owner).
- Credit applicant: We collect your Personal Information when you complete a credit application form including your name, trading name (if you are company), identifying numbers (such as your company registration number or ID number; VAT number), postal, delivery and physical address details, contact details (including your telephone numbers, fax numbers, and email address), and banking details. In the case where you are a company, we also request you to provide the Personal Information of third parties such as your landlord, your shareholder(s), your auditor/accounting officer, your directors/trustees/partners/members/owners details and the surety’s details, where applicable. We will also collect Personal Information from third parties (including credit bureaus).
- Policyholder: We collect various Personal Information for and on behalf of:
Hollard Insurance Company Limited (“Hollards”) in relation to the XSure/MoreSure guarantee you have taken out including your name, contact number (email address and telephone number), vehicle registration number. This Personal Information is collected from you when you apply for a Hollard insurance product or when you make a claim in respect of a Hollard insurance product at one of our branches. Please review Hollard’s Privacy Notice for further information regarding such processing.
Infrasonic in relation to the Tiger Advantage Plus policy you have taken out including your name, contact number (email address and telephone number), vehicle registration number. This Personal Information is collected from you when you apply for an Infrasonic insurance product or when you make a claim in respect of an Infrasonic insurance product at one of our branches. Please review Infrasonic’ s Privacy Notice for further information regarding such processing.
- Supplier: Your Personal Information is collected when you apply to the organization as an approved supplier through the completion of the required supplier forms. The Personal Information collected includes account number, address, points of shipment, telephone number and details of contact persons within your business.
- Job applicant: We collect Personal Information directly from you, from third parties (such as verification agencies and recruitment agencies) and from public records (such as LinkedIn). This Personal Information includes any Personal Information you have supplied on a job application form, in your CV, during your interview with us, your academic history and records. Criminal record verification will only be conducted with your prior written consent.
- Employee: We collect and process your Personal Information when you are on-boarded as an employee. This includes your name, tax details, contact details (including email address and telephone numbers), physical address, trade union membership details (with your prior written consent), employee number and banking details.
In certain instances we may request you to provide the Personal Information of your friends or family (e.g. your next of kin) who can be contacted in the case of a medical emergency, this Personal Information is voluntary. We also collect the Personal Information required by the provident fund administrator and medical aid scheme administrator in terms of their respective requirements. Please refer to the relevant Privacy Notices of the provident fund administrator and medical aid scheme administrator for further information regarding the processing activities of these third parties.
- Visitors: We collect the Personal Information of visitors in order to maintain the security of our premises this Personal Information includes your name, contact details, car registration number, and, where required, health information for purposes of COVID-19 symptom checking.
- Website users: We collect the Personal Information when you visit our website. Please refer to our cookies policy described below.
- Biometric: We collect video footage when you make use of our premises for security and monitoring purposes.
4. What Personal Information is mandatory?
We use our best endeavours to indicate whether the Personal Information requested is mandatory or voluntary at the time of collection. In this regard our forms have been updated to indicate mandatory Personal Information with an Asterix on relevant forms and online applications. However, you may also ask a manager whether or not the Personal Information is mandatory if this is unclear. Failing to provide mandatory Personal Information may impact our ability to, amongst other things:
- provide your products or services to you;
- extend credit to you;
- provide you access to all webpages and websites.
- on-board you as supplier.
- assess you in respect of a job opportunity.
- assist you in taking our insurance policy products or services (i.e. XSure/MoreSure, Tiger Advantage Plus etc.) and to assist you in processing any of your related claims.
- perform in terms of a contract (such as an employment contract) with you; or
- access our premises.
5. For what purposes is your Personal Information used?
- Provision of products and services
- In order to provide you with products and services you have requested.
- To verify your instructions to us,
- To analyse, assess and improve our services to you,
- For training and quality purposes.
- Invoicing and payment collections
To invoice you in respect of products and services purchased by you and for the collection of amounts due to us for the provision of such products and services.
- Queries and complaints
To respond to any questions, requests, concerns or complaints you may have regarding our products, service offerings or processing activities.
- We may contact you to market our products and services and to communicate with you regarding competitions, events, and other promotions we are involved in.
- We may use email, post, telephone and text to communicate with you for marketing purposes. you may change any communication preferences by:
- Lodging a formal request to: email@example.com for instructions and or relevant forms on how you can update your preferences.
- Clicking on the relevant links included in any communication that is sent. This will take you to our communication partner Everlytic who manage our client communications on our behalf
- You have the right to opt-out of direct marketing at any stage by following the “opt out” instructions or selecting the “unsubscribe” link available in the direct marketing or other communication you receive from us. Please note that it may take up to 5 days for your opt-out to be given effect to. Should you continue to receive direct marketing from TiAuto beyond this period please inform our Information Officer.
- With your prior consent, we may provide your Personal Information to entities within the TiAuto group for them to market their goods and services to you.
- Online advertising
- TiAuto currently does not perform any online behavioural advertising, however this may be revisited in the future at which point this specific clause would be revisited.
- Credit check and verification
- We will use the services of a credit bureaux to perform credit checks if you have sent us a credit application for the purchase of our products and services. The credit check assists us in determining whether or not we would like to extend credit to you.
- Your Personal Information will be used to verify your identity when we are in contact with you, this would further be used to gain access to your account in order to efficiently provide you with our products and services.
- Compliance with laws
TiAuto will process Personal Information in order to comply with an obligation imposed on it by law. These laws include but not limited to:
- the Basic Conditions of Employment Act 75 of 1997;
- the Labour Relations Act 66 of 1995; the Employment Equity Act 55 of 1998;
- the Occupational Health and Safety Act 85 of 1993,
- the Income Tax Act 58 of 1962 and the VAT Act 89 of 1991;
- Insurance products administration
We will process your Personal Information to administer your Xsure insurance contract underwritten by Hollard Insurance (Pty) Ltd (“Hollard”). This includes collection of Personal Information required by Hollard to issue you with an insurance policy, provide Hollard with details of your claim and provide any other Personal Information which Hollard requires related to your policy with Hollard. Please review Hollard’s Privacy Notice for further information regarding its processing activities.
- Supplier assessment and on-boarding
Personal Information is processed to determine whether we require your goods or services, to register you as a supplier on our procurement system and in order to perform any actions agreed with you in terms of our contract (i.e. including processing payment).
- Recruitment and employment
We process your Personal Information in order to:
- evaluate you in respect of a job you have directly or indirectly applied for;
- on-board you as an employee,
- administer benefits as agreed in your employment contract;
- comply with employment, health and safety and tax laws which apply to you;
- assess your performance
- take disciplinary action, where necessary.
We process Personal Information to secure our premises, our assets and our employees.
6. With whom is your Personal Information shared?
We may share your Personal Information with:
- Related companies within the TiAuto Investments Group provided we have obtained your prior consent to do so.
- Business partners, suppliers or agents who are tasked with delivering our products and services to you. These include:
- Baker Street Data Sciences and Analytics (Pty) Ltd in order to enrich the Personal Information records of our customers or potential customers.
- Hollard Insurance (Pty) Ltd in relation to any Xsure/MoreSure insurance products you have taken up with us.
- Infrasonic (PTY) Ltd in relation to Tiger Advantage Plus products you have taken up with us.
- Everlytic (PTY) Ltd in relation to the management of our email and SMS contacts with you.
- CustomApp (PTY) Ltd in relation to collection and management of our vehicle assessment information when you visit our stores.
- CarScan (PTY) Ltd in relation to management of our vehicle assessments when you visit our stores.
- Canvas Intelligence (PTY) Ltd. in relation to the analysis of and provision of data analytics development services.
- Credit bureaus and verification agencies in order to assess the credit worthiness of credit applicants, to verify your criminal record or to authenticate your qualifications. These include:
- Credit Guarantee (PTY) Ltd in relation to credit vetting when you request credit with us.
- Debt collectors, where you default on the payment of fees due to us in connection with the products and services provided to you.
- Law enforcement agencies such as, but not limited to, the South Africa Police Service, local, provincial and national government entities, regulators and courts, where we are compelled by law to do so.
- Mergers and acquisitions Should TiAuto be reorganised or sold to another company or entity, your Personal Information may be provided to such company or entity.
7. Is there any international sharing of Personal Information?
TiAuto is a multinational organisation with presence outside South Africa including, Mozambique, Tanzania, Zambia and Zimbabwe. Accordingly, personal Information will only be transferred to recipients outside of South Africa if one of the following conditions have been satisfied:
- you have consented, in writing, to the transfer of Personal Information to the recipient;
- we have entered into a binding agreement or binding corporate rules with the recipient which effectively upholds the principles of reasonable processing as defined in POPIA and which prohibits the further transfer of Personal Information to other third parties without TiAuto’s written consent; or
- we have performed an assessment of the foreign law and have reasonably satisfied ourselves that those laws provide an adequate level of protection and effectively upholds the principles of reasonable processing as defined in POPIA
8. What information do we collect automatically
Each time you interact with our websites, we may automatically collect the following Personal Information and/or Anonymous Information:
- Technical information including, but not limited to, browser type, operating system, device information, IP address, domain name, referral URL, time zone setting, and/or a time-stamp for your visit.
- Usage information including, but not limited to, geographic location information (such as your country or province), the numbers and frequency of visitors to our site, page views, unique page views, video views, form conversions, and your clickstream behaviour (e.g. clicking links to, through and from our Website).
We may use various technologies such as cookies, web beacons (also referred to as clear gifs), and e-tags to collect Personal Information and/or Anonymous Information, to analyse trends, and to provide you with a more personalized customer experience.
Cookies are small pieces of information that are placed on your computer to enable our system to recognize your computer when you return to our Website and to collect various technical and usage information about your visits. Cookies may be used by us and our third-party suppliers who help us provide our Website. We may link information stored in cookies to Personal Information we have in our systems.
For more information on how to do so, please refer to the documentation accompanying your browser. If you choose to disable cookies, some areas of our website may not function properly.
To learn more about third party cookies and other advertising networks and their opt out instructions, please visit http://www.aboutads.info/choices or http://preferences-mgr.truste.com.
9. How do we secure Personal Information records?
We are committed to ensuring that your Personal Information is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information we collect.
- Hosting of our systems in secure data centre locations.
- Limiting of access to information and personal information via clear segregation of roles in our systems.
- Ongoing education of our staff on the secure handling of personal information in our operations.
- Encryption of data where applicable.
- Securely storing of physical records in controlled filing locations where appropriate.
- Securely destroying operational records and data when they are no longer required in terms of relevant operational or legislative retention requirements.
10. How long do we retain Personal Information?
We will retain your Personal Information only for as long as we need it having regard to our retention policy and schedule (extracts of this document is available on request). We will take all reasonable steps to destroy, delete or de-identify Personal Information records as soon as reasonably possible the retention period has been reached. In determining the retention periods we have had regard to:
- the purpose for which the Personal Information was collected or subsequently processed;
- whether the retention of the Personal Information record is required or authorised by law;
- whether we reasonably require the Personal Information record for lawful purposes related to our functions or activities;
- whether the Personal Information record is required by a contract between TiAuto and you;
- whether you have consented to the retention of the Personal Information record for a longer period than would ordinarily apply;
- whether Personal Information records are required for historical, statistical or research purposes (provided that we have established appropriate safeguards against these records being used for any other purposes).
11. What are your privacy rights?
We set out what your rights in terms of your Personal Information below. Should you wish to exercise any of these rights please contact TiAuto’s Information Officer using the details provided below.
- Right to access Personal Information
You have the right to request whether or not TiAuto holds any of your Personal Information without incurring any fees or charges.You may also request us to provide a description of Personal Information we hold about you and/or to request access to such Personal Information records. In order to respond to such requests there may be a fee or charge payable by you. However, we will provide you with a written estimate of such fee before providing you with services associated with your request for access.
- Right to correct or delete Personal Information
You have the right to request the correction or deletion of your Personal Information if it inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully; or if TiAuto is no longer authorised to retain such Personal Information having regard to the requirements of POPIA.
- Right to object to the use of Personal Information
You have the right to object to direct marketing at any time.
You also have the right to object to the processing of your Personal Information by TiAuto on reasonable grounds relating to your particular situation, unless legislation provides for such processing. The right to objection can only be exercised by you in limited circumstances where:
- TiAuto considers it necessary to process such Personal Information to protect a legitimate interest of you ; or
- TiAuto considers it necessary to process your Personal Information for pursuing its legitimate interests or the legitimate interests of a third party to whom the Personal Information is supplied.
- Right to withdraw consent
You have the right to withdraw your consent in instances where TiAuto relies on consent as a justification to process your Personal Information and you have previously given such consent.
- Right to lodge a complaint
You have the right to lodge a complaint with TiAuto’s Information Officer/Deputy Information Officer or with the Information Regulator regarding any perceived interference with your rights in terms of POPIA and/or where your Personal Information has not been processed as required in terms of POPIA.
|TiAuto Information Officer||Information Regulator|
Information Officer: Alex Taplin
Deputy Information Officer: Brendan Clark
Physical Address: TiAuto Investments (Pty) Ltd, Corner K101 and Old Pretoria road, Halfway House Estate, Midrand,1685.
Email address: firstname.lastname@example.org
Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Postal Address: P.O. Box 31533, Braamfontein, Johannesburg, 2017
12. How to contact us and our Information Officer
Should you require any further information regarding the Personal Information processed by TiAuto, wish to exercise any rights as set out in this Privacy Notice or otherwise wish to lodge a complaint regarding the manner in which your Personal Information is being processed by TiAuto you may contact the Information Officer via post or email per the details below.
Information Officer: Alex Taplin
TiAuto Investments (Pty) Ltd
Corner K101 and Old Pretoria road
Halfway House Estate
Email address: email@example.com