Privacy Policy: Data Protection and POPIA Compliance

Our Website: www.fleximobility.com
Last Updated: October 2024

Vehicle Care Group (Pty) Ltd, t/a Flexi, including all its subsidiaries and associated entities (“the Company”), is committed to safeguarding the privacy of personal information collected, processed, and stored in compliance with the Protection of Personal Information Act 4 of 2013 (POPIA). This policy outlines how we collect, use, store, and share personal data, ensuring compliance with Section 18 (Notification of Collection), Chapter 3 (Conditions for Lawful Processing), and other relevant provisions under POPIA.

By using our website, you agree to the terms outlined below. If you do not agree, please refrain from using the website or services.

Interpretation and Definitions

The following definitions are consistent with the POPIA framework:

• Account: A unique profile created for you, where your personal information is stored and processed by the Company.
• Company: Refers to Vehicle Care Group (Pty) Ltd, duly registered under the Companies Act 71 of 2008.
• Cookies: Defined as small text files placed on your browser or device for tracking and analytics purposes. (Regulation: Section 18 of POPIA, requiring notification of the collection).
• Country: Republic of South Africa.
• Device: Any digital device used to access our services, such as a mobile phone or computer.
• Personal Information: As defined in Section 1 of POPIA, it includes any information that can identify a person (natural or juristic), such as:
  • Contact details (email, phone number, physical address).
  • Demographics (age, race, gender, marital status).
  • Financial, educational, and medical history.
  • Biometric data (fingerprints, facial recognition).
• Service Provider (Operator): Third parties that process data on our behalf, regulated under Section 21 (Processing by Operator) of POPIA.
• Usage Data: Data automatically collected by our website, including IP addresses, browsing behavior, and device information.

Collecting and Using Your Personal Information

Types of Data Collected

In compliance with Section 13 (Collection for Specific Purpose) of POPIA, we only collect personal information necessary for the purpose for which it is intended. This includes:

• Personal Data: Name, email address, phone number.
• Usage Data: Collected automatically, including IP addresses, browser information, pages visited, and time spent on the website.

Lawful Processing of Personal Information

We ensure that personal information is processed lawfully in accordance with Section 11 (Consent, Justification, and Objection) of POPIA. Our lawful basis for processing includes:

1. Consent: Provided explicitly by you.
2. Performance of a Contract: Necessary to provide services requested.
3. Legal Obligation: Complying with regulatory requirements.
4. Legitimate Interests: For fraud prevention or to improve our services.

Cookies and Tracking Technologies

We use Persistent and Session Cookies for the following purposes, in accordance with Section 18 (Notification):

• Essential Cookies: Authenticate users and prevent fraudulent activity.
• Functionality Cookies: Store user preferences for a more personalized experience.
• Analytics Cookies: Used to analyze usage patterns and improve website performance.

You can manage cookies through your browser settings. Disabling cookies may limit some functionality on our website.

Sharing of Personal Information

In line with Chapter 3 (Conditions for Lawful Processing) and Section 20 (Processing by Third Parties) of POPIA:

1. With Service Providers: For hosting, analytics, or customer support.
2. With Affiliates: For internal business purposes.
3. Business Transfers: If the Company is involved in mergers or acquisitions.
4. Legal Obligations: We may share personal data if required by law or to protect our rights and users.

All third-party service providers are required to comply with Section 21 (Operator Responsibilities) of POPIA.

Retention of Personal Information

We retain personal information only as long as required to fulfill its purpose, in compliance with Section 14 (Retention and Restriction of Records). Usage Data may be retained for internal analysis and security purposes.

Security Measures

We implement appropriate security measures to protect personal data, including encryption and secure storage, as outlined under Section 19 (Security Safeguards) of POPIA. However, we cannot guarantee absolute security for data transferred over the internet.

Financial Information

In compliance with Section 12 (Minimality) of POPIA, financial information is collected only when necessary and is treated with strict confidentiality.

Children’s Personal Information

We do not knowingly collect personal data from children. In cases where children’s information is provided, we ensure that it is processed with prior consent from a parent or legal guardian, in compliance with Section 35 (Special Personal Information of Children).

Your Data Protection Rights under POPIA

1. Right to Access and Correction (Sections 23 and 24):
   • You may request access to personal data held about you.
   • You can also request corrections or updates to inaccurate information.
2. Right to Object (Section 11(3)):
   • You may object to the processing of your personal data.
3. Right to Lodge a Complaint (Section 74):
   • You can file a complaint with the Information Regulator at complaints.IR@justice.gov.za or directly with us at info@fleximobility.com.

Data Breach Notification

In the event of a data breach, we will notify the Information Regulator and affected data subjects as required by Section 22 (Notification of Security Compromises).

Changes to This Privacy Policy

We reserve the right to update this policy in accordance with Section 18 of POPIA. It is your responsibility to review the policy periodically.

Our Contact Information

• Company Name: Vehicle Care Group (Pty) Ltd
• Information Officer: Dewaldt Scholtz
• Email: info@fleximobility.com
• Phone: 087 898 3685
• Address: Unit 2A Quantico House, Loerie Park, Durbanville, Western Cape, 7550