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COOKIE POLICY

“We” or “us” means Auto Investments – 2015/106789/07.

What is a cookie?

A cookie is a small piece of data that a website asks your browser to store on your computer, mobile device and/or other web-enabled device whenever you visit a website.  The cookie, once stored, allows the website to “remember” your device and your actions or preferences over time.

A cookie is downloaded by your internet browser the first time your visit a website.  The next time you visit that website with the same device, the cookie and the information in it are sent back to either the website visited (i.e. first-party cookie) or another website (i.e. third-party cookie).  By that a website can detect that it has already been opened using your browser, and in some cases it will then vary the content it shows and/or limit or enable functionality.  

Most internet browsers support cookies. You can however set your browser to decline certain types of cookies or specific cookies. Further, you can delete cookies at any time.

Where we use cookies to collect personal information, this will be carried out in accordance with our Privacy Statement available on website.  Please ensure that you read our Privacy Statement to understand our practices regarding your personal information and how we will treat such personal information.

Why do we use cookies?

We use cookies for a lot of different functions, including to learn how you interact with our content and to generally improve your experience when visiting our website. For example, some cookies remember your language and other preferences so that you do not have to repeatedly make these choices and/or input these details when you visit our website.

Cookies can also help to ensure that the advertisements you see online are more relevant to you and your interests. In addition, cookies can help us to analyze the use of our website and online content and they can also facilitate/track the interaction on our website and online content with social media (e.g. links to social media sites, like buttons, etc.).  

We may employ the learnings of your behaviour on our website to serve you with targeted advertisement on third-party website(s) in an effort to “re-market” our products and services to you.

First Party and/or Third Party cookies?

We use both first-party and third-party cookies on our website. First-party cookies are cookies issued from our autoigroup.co.za domain that are generally used to identify language and location preferences or render basic site functionality. 

Third-party cookies belong to and are managed by other parties, such as our business partners or service providers. These cookies may be required to render certain forms, such as the submission of a job application, or to allow for some advertising outside of the Shell website.

For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to third party content providers (for example YouTube, Twitter, etc.). These videos or links (and any other content from third party suppliers) may contain third party cookies, and we encourage you to consult the privacy policies of these third party suppliers on their websites for information regarding their use of cookies.

Session Cookies and/or Persistent Cookies?

We use both session cookies and persistent cookies on our website. Session cookies are temporary cookies that are used to remember you during the course of your visit to our website, and they expire when you close your web browser.

Persistent cookies are used to remember your preferences within our website and remain on your desktop, mobile device and/or other web-enabled device even after you close your browser or restart your device. We use these cookies to analyse user behaviour to establish visit patterns so that we can improve our website functionality for you and others who visit our website. These cookies also allow us to serve you with targeted advertising and measure the effectiveness of our site functionality and advertising.

Categories of cookies?

We use the following categories of cookies on our website:

- Strictly necessary cookies

These cookies are essential in order to enable you to move around our website and use its features (such as accessing secure areas of our website). Without these cookies certain functionalities of our website cannot be offered.  Strictly necessary cookies are always active and will be placed without your consent.

- Analytics cookies

These cookies allow us to employ data analytics so we can measure and improve the performance of our website and provide more relevant content to you. The information collected is aggregated, and therefore made anonymous. These cookies do not collect information that would allow you to be identified, and only serve the purpose of evaluating and enhancing your experience of our website. These cookies enable us to improve the way our website works, for example by ensuring that you are finding what you are looking for easily.

- Performance cookies

These cookies collect information about your visit and use of our website, for instance which pages you visit the most often and if you get error messages from web pages. They are generally third-party cookies from vendors we work with or who work on our behalf. These cookies don't collect information that identifies you. All information these cookies collect is anonymous and is only used to improve how our website works. Third party vendors may have access to this data and may use it to improve their overall services and offerings.

- Functionality cookies

These cookies allow our website to store information you have already previously entered (such as your username) and remember options you have already previously selected (such as your language), in order to offer you improved personalised functions and remember your preferences. These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for advertising or remembering where you’ve been on the internet outside our website.

- Targeting, advertising and social media cookies

These cookies are used to: (i) deliver advertisements more relevant to you and your interests; (ii) limit the number of times you see an advertisement; (iii) help measure the effectiveness of the advertising campaign; (iv) re-target to our website/information and (v) understand your behaviour after you view an advertisement. They are usually placed on behalf of advertising networks with our website operator’s permission. They remember that you have visited a website and quite often they will be linked to website functionality provided by the other organization. This may impact the content and messages you see on other websites you visit. 

How are cookies used for advertising purposes?

We may use information collected from our cookies to identify user behaviour and to serve content and offers based on your profile to the extent legally permissible. In other cases, we can associate cookie information with you. For example:

- If we send you a targeted email which includes web beacons, cookies or similar technologies we will know whether you open, read, or delete the message;

- When you click a link in a marketing e-mail you receive from us, we may also use a cookie to log what pages you view and what content you download from our website, even if you are not registered at or signed into our website.

Cookies and ad technology such as web beacons, pixels, and anonymous ad network tags help us serve relevant ads to you more effectively. They also help us collect aggregated audit data, research, and performance reporting for advertisers. Pixels enable us to understand and improve the delivery of ads to you, and know when certain ads have been shown to you. Since your web browser may request advertisements and web beacons directly from ad network servers, these networks can view, edit, or set their own cookies, just as if you had requested a web page from their site.

Although we do not use cookies to create a profile of your browsing behaviour on third-party sites, we do use aggregate data from third parties to show you relevant, interest-based advertising. We do not provide any personal information that we collect to advertisers. You can opt out of off-site and third-party-informed advertising by adjusting your cookie settings. Opting out will not remove advertising from the pages you visit, but, instead, opting out will result in the ads you see not being matched to your interests. This implies that the ad(s) you see will not be matched to your interests by those specific cookies.

Combining and analysing personal data

We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected when you sign-up or log on to our website or connect to our website using your social media credentials). We combine this data to better assess your experience with us and to perform the other activities described throughout our Privacy Statement.

Do we use any other tracking technologies similar to cookies?

We may use web beacons (including conversion pixels) or other technologies for similar purposes as above and we may include these on our website, in marketing e-mail messages or our newsletter, affiliated websites, to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but they may work in conjunction with cookies to monitor website activity. The information provided herein about cookies also applies to web beacons and similar technologies. Conversion pixels are small codes located on our website which are triggered when someone visits a page resulting in an increase in the conversion count.

How can you manage your cookies?

You can adjust your cookie settings through our cookie consent manager available on website. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies being placed on your device you can use our cookie consent manager available on website.

Using our cookie consent manager available on website will set a cookie on your device to remember our preferences.

Most browsers automatically accept cookies. Therefore, if you do not wish cookies to be used, you may need to actively delete or block the cookies.

If you reject the use of cookies, you will still be able to visit our website but some of the functions may not work correctly.

You may also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies generally. By using our website without deleting or rejecting some or all cookies, you agree that we can place those cookies that you have not deleted or rejected on your device. 

Changes to this cookie policy

We may update this cookie policy at any time by publishing an updated version here.  To ensure that you know when we make changes to this cookie policy, we will amend the revision date.  The new modified or amended cookie policy will apply from the revision date.  Therefore, we encourage you to review this cookie policy periodically to be informed about how we are using your information.

STATEMENT

“We” or “us” means Auto Investments – 2015/106789/07.

We are strongly committed to protecting personal information and we attach great importance to your right to privacy. We want you to feel secure that when you deal with us, your personal information is in good hands.

We protect your personal information in accordance with applicable laws and our information privacy policies. In addition, we maintain the appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.

The use of our website is also subject to our Website Disclaimer available on website, and our Cookie Policy available at on website.  Your relationship with us is further subject to and governed by the separate contractual terms and conditions that may exist between us.

When used in this Privacy Statement, the term “personal information” has the meaning given to it in the Protection of Personal Information Act, Act 4 of 2013 (“POPIA”), applicable in the Republic of South Africa.  Generally, personal information is any information that can be used to personally identify you.  If any information that we collect personally identifies you, or you are reasonably identifiable from it, we will treat it as confidential.

LAWFUL PROCESSING

The following conditions of lawful processing of personal information are the principles in terms of which we will be processing the collected personal information. They are:

- Accountability – we will make sure that your personal information is processed in a lawful and responsible manner;

- Processing limitation– we shall lawfully collect your personal information for a defined purpose and where applicable, with your consent;

- Purpose specification – we will only use your personal information for the purposes that you expect us to use it for.

- Further processing limitation – where a processing activity is seen as further processing (means a new purpose for processing your personal information) and this new purpose is inconsistent with the original purpose (original reason we collected your personal information), we will make sure that our processing activities meet the requirements of the applicable information protection laws;

- Information quality – we will take reasonable steps to ensure your personal information is accurate, complete and updated and not misleading;

- Openness – from the start, we will be open, clear and honest with you on how and why we use your personal information and how we protect your personal information

- Security safeguards – we will apply and follow appropriate and reasonable technical and organisational measures to make sure that the confidentiality, integrity and availability of your personal information are secured. These measures will also be applied to protect your personal information against loss, damage, unauthorised destruction or unlawful access

- Information subject participation – we have processes in place for you to access, correct and delete personal information and exercise your rights in terms of applicable information protection laws.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?    

We will collect your personal information in the following ways:

- directly from you; and

- where lawful and reasonable, from third parties and public sources.

If we do not obtain your personal information directly from you, we may obtain it from the following sources:

- publicly available sources (registers or the internet);

- our employees, contractors, (prospective) members of board of directors and/or shareholders;

- our affiliates, subsidiaries and newly acquired businesses;

- employers of our contractors;

- public authorities, public websites and social media;

- previous employers, educational institutions, suppliers and vendors (including third party information providers).

Specifically we may collect your personal information via our website in the following ways:

- directly if you provide the information in response to a request (for example, when you provide personal information  to sign up for a newsletter) or if you otherwise provide same (for example via any postings, comments other content that you upload of post on our website); and/or

- indirectly through the use of technologies such as cookies. Please refer our Cookie Policy available at on website.

WHICH CATEGORIES OF PERSONAL INFORMATION DO WE COLLECT? 

The personal information we collect includes the categories of personal information referred to in this Privacy Statement or in other statements you have received.

Below is a chart describing certain categories of personal information that we may collect:

We also may derive inferences about you based on the information described above and also collect other information about you as described in this privacy statement. If you provide us with personal information of another person, you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with us.

The above-mentioned categories of personal information have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors. Except where certain information is required by law or by our policies, your decision to provide any personal information to us is voluntary. Please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this Privacy Statement, and you may not be able to use certain tools and systems which require the use of such personal information.

We will not intentionally or knowingly collect personal information directly from minors (anyone under the age of 18). The personal information of minors will be collected through their legal guardian or parent only where products or services are obtained for the minors.

WHEN CAN WE PROCESS OR SHARE YOUR PERSONAL INFORMATION?

We will process your personal information if you give us your consent willingly or according to the grounds of lawful processing highlighted below. If we need your consent, we will notify you through our product and services agreements or application processes. To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal information.

FOR WHICH PURPOSES AND ON WHICH LEGAL BASIS DO WE USE YOUR PERSONAL INFORMATION?

We will only use and share your personal information where it is necessary for us to carry out our lawful business activities. To enable you to fully understand the way in which we process your personal information, we have described the different lawful grounds for such processing in detail below:

- Consent – We may process your personal information for a specific and explicitly defined purpose where you, or a competent person in the case of personal information relating to a minor, provide us with your express consent for such processing or where law requires;

- Contractual need – We may process your personal information where it is necessary to enter into a contract with you in order for us to provide our products or services to you or to perform our obligations under that contract. Please note that if you do not agree to provide us with the requested personal information, it may not be possible for us to continue to provide products or services to you;

- Compliance with an obligation imposed by law – When you apply for a product or service, we are required by law to collect and process certain personal information about you. Please note that if you do not agree to provide us with the requested personal information, it may not be possible for us to continue to provide products or services to you;

- Legitimate interests – We may process your personal information where it is in our legal interests to do so as an organisation and without harming your interests or fundamental rights and freedoms (for example, for marketing purposes, site maintenance, etc.).

Please view the table below for: (i) a non-exhaustive list of specific purposes for which we may use your personal information and (ii) an overview of the legal basis for each such purpose:

Legitimate interest means that we have reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy reviews and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact our information officer or deputy information officer (s).

WILL WE SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?

We will only share your personal information if:

- the law requires it;

- we have a public duty to share the personal information;

- our or your legitimate interests require us to share the personal information;

- it is necessary to conclude or perform due to an agreement between you and us; or

- you agreed that we may share your personal information.

As specified by the above purposes, we may share your personal information with any of the parties mentioned below:

- Any member of our group;

- Professional advisers like auditors, third-party vendors, or independent contractors who process personal information on our behalf to support our business;

- Our business partners who provide their products and services to you;

- Service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, information hosting, auditing, and information processing;

- Any individual who needs your personal information due to foreign or local law or regulation;

- Any court of justice, regulatory body, taxation authority (including any authority investigating an offence) or their agents;

- Any debt collection agency, credit bureau, insurer or broker, direct or indirect provider of credit protection and fraud prevention agencies;

- Any financial institution to conduct credit checks, anti-money laundering related checks, for fraud prevention and detection of crime purposes for our group.

We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

We will not share your personal information to organisations outside the borders of South Africa that are not our service providers, unless business operations require the processing of your personal information in other countries, either to carry out processing based on your instructions or for ordinary business purposes. Any third party, who is located outside of South Africa and receives your personal information, will need to comply to either a law, or binding corporate rules or a binding agreement which states that they will provide an adequate level of protection to your personal information. This means that they have to agree to lawfully process your personal information and protect your personal information in the same manner as we do.

WHAT ABOUT SPECIAL PERSONAL INFORMATION?

We do not generally seek to collect special personal information as defined in POPIA through our website or otherwise. In the limited cases where we do seek to collect such information, we will do this in accordance with legal requirements and/or ask for your consent.

STORAGE

We will store and keep your personal information according to the retention periods defined by law for legitimate business purposes and will take reasonably practicable steps to make sure that it is kept up to date and deleted and archived as appropriate.

We maintain specific records management and retention policies and procedures, so that personal information are deleted after a reasonable time. Refer our POLICY ON RETENTION AND DESTRUCTION OF RECORDS – [ITEM 2.3 OF OUR POPIA COMPLIANCE FRAMEWORK – MANDATORY ITEMS] for further details.

INFORMATION SECURITY

The security of your personal information is important to us. We have implemented appropriate and reasonable technical and organisational measures to prevent loss, unauthorised destruction, damage or access to your personal information by unauthorised third parties. The security of your personal information is important to us. We make sure that we implement organisational and technical procedures to keep your personal information safe. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal information and the processing we undertake.

Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet (including by e-mail) is never completely secure.  We endeavour to protect personal information, but we cannot guarantee the security of information transmitted to or by us.

MARKETING BY ELECTRONIC MEANS

We would like to share information about our own products, services and special offers that are similar to the products or services used by you, via your preferred method of communication (as indicated to us), such as email, text message, social media platforms or notification on your mobile application. We may also share information with you about similar products, services and special offers of our partner companies.

If you have opted-in to receive marketing communications, you may always opt out at a later stage using the link shared below or clicking on the “Unsubscribe” option included in every marketing communication sent to you. You have the right at any time to stop us from contacting you for marketing purposes or giving your information to other members of our group.

If you no longer wish to be contacted for marketing purposes, please request for us to mark you as ‘No’ to Marketing by calling us on +27 (0) 12 8801 777  or emailing us on ops@autoigroup.co.za.

USE OF COOKIES

Please refer our Cookie Policy available at on website.

YOUR RIGHTS

You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

- Right to access – You have a right to get access to the personal information that we hold about you. If you would like a record or description of the personal information that we hold about you, please request this from our information officer or deputy information officer(s) at ops@autoigroup.co.za. We may, if allowed by law, charge a fee for this.

- Right to rectify/correct/ update – You have a right to correct inaccurate personal information and to update incomplete personal information. Please request this through our information officer or deputy information officer(s) at ops@autoigroup.co.za.

- Right to be notified – You have the right to be notified that your personal information is being collected by us or has been accessed or acquired by an unauthorised person.

- Right to withdraw – You have the right to withdraw your consent to us processing your personal information. Please note that if you withdraw your consent to us processing your personal information, we may have to stop or suspend the provision of the products and services we provide to you. Please note that where the law requires us to process your personal information, we will have a legal obligation to do so. Please note that where the law permits us to process your personal information, we may continue to do so. Please request this through our information officer or deputy information officer(s) at ops@autoigroup.co.za.

- Right to object – You have a right to object to us processing your personal information where we have relied on one of the lawful grounds above for legitimate interest or where we perform a public law duty (and to request us to restrict processing). Please note that if you request us to restrict processing your personal information, we may have to stop or suspend the provision of the products and services we provide to you. Please note that where the law requires us to process your personal information, we will have a legal obligation to do so. Please note that where the law permits us to process your personal information, we may continue to do so. Please request this through our information officer or deputy information officer(s) at ops@autoigroup.co.za.

- Right to deletion - You have a right to request that we delete your personal information. Despite your request, may still have a legal right or obligation to retain your personal information. Please note that if you request us to delete your personal information, we may have to stop or suspend the provision of the products and services we provide to you Please request this through our information officer or deputy information officer(s) at ops@autoigroup.co.za.

- Right to object to the processing of personal information for the purposes of direct marketing – You have a right to object at any time to the processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing. Please request this through our information officer or deputy information officer(s) at ops@autoigroup.co.za.

- Right to lodge a complaint with the Regulator. If you wish to raise a complaint on how we have handled your personal information, you can contact our information officer or deputy information officer(s) at ops@autoigroup.co.za who will investigate the matter. We hope that we can address any concerns you may have.

THIRD PARTY WEBSITES

Our website may include:

- Links to and from the sites of our partner networks, advertisers and affiliates

- Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal information collected through such programs for their own purposes.

This privacy statement does not apply to any third party websites which may be accessible through links on our website.  

We do not make any representation and/or warranties about the privacy of any third party websites and do not accept any responsibility or liability for them.  Third party website provides are responsible for informing users about their own privacy practises and we suggest that you review the privacy policies of any third party provides whose sites you access.

CHANGES TO THIS PRIVACY STATEMENT

We may update this Privacy Statement at any time by publishing an updated version here.  To ensure that you know when we make changes to this Privacy Statement, we will amend the revision date.  The new modified or amended Privacy Statement will apply from the revision date. Therefore, we encourage you to review this Privacy Statement periodically to be informed about how we are using your information.

DISCLAIMER

1. “We” or “us” means Auto Investments – 2015/106789/07.

2. Your use of our website is dependent on factors beyond our control, such as the network coverage or availability of your Internet Service Provider.  We are not liable for any loss or damages you may suffer if a factor beyond our control arises, and you cannot access this website.

3. You use our website and the online services entirely at your own risk. You are fully responsible for any loss or damage that may result from you using or not being able to use our website or any of its content, information or any online service.

4. We (including our owners, agents, consultants, employees and any affiliated person) are not responsible for any loss or damages related to your use of our website. This includes, without limitation, any direct, indirect, special, incidental, consequential or punitive damages in terms of any contract, delict (breach of a duty of care) or law, and even if we were expressly told that any loss or damage was possible.

5. We are not responsible for any loss that results from:

5.1 any technical or other problem (including interruption, malfunction, downtime or other failure) that affects our website, system or any online service or any database for any reason;

5.2 any problem affecting any other goods or services provided by any other party, for example any telecommunication or Internet service provider, electricity supplier, or local or other authority;

5.3 any loss of or damage to any personal information or other data caused directly or indirectly by technical problems, power failures, unlawful acts (such as data theft), any harmful computer program or virus, or because of your own negligence;

5.4 any order, investment decision or purchase or disposal of goods or services (including any financial instrument or currency) from any other party based on any information on our website; or

5.5 any event over which we have no direct control.

6. Our website may include links to external websites. When you follow such links the external website may appear as a full screen (in which case you will need to use the back button on your browser to return to our website) or in some cases it may appear within the frame of this website (in which case you will be able to return to this website by using the navigation buttons within the frame). Where an external website appears within the frame of our website, this is purely for ease of navigation back to our website and does not indicate any responsibility on our part for the external website concerned, even if it is a website owned and operated by another of our group companies. These links are provided in order to help you find relevant websites, services and/or products which may be of interest to you quickly and easily. It is your responsibility to decide whether any services and/or products available through any of these websites are suitable for your purposes. We are not responsible for the owners or operators of these websites or for any goods or services they supply or for the content of their websites and do not give or enter into any conditions, warranties or other terms or representations in relation to any of these or accept any liability in relation to any of these (including any liability arising out of any claim that the content of any external website to which this website includes a link infringes the intellectual property rights of any third party).

7. All information or advice provided as part of our website is intended to be general in nature and you should not rely on it in connection with the making of any decision. We try to ensure that all information provided as part of our website is correct at the time of inclusion on the website but do not guarantee the accuracy of such information. We are not liable for any action you may take as a result of relying on such information or advice or for any loss or damage suffered by you as a result of you taking this action.

8. We reserve the right to monitor any information transmitted or received through any forum provided. We, at our sole discretion and without prior notice, may at any time review, remove or otherwise block any material posted.

9. Should any part of our website offer you the opportunity to join in or read from a forum, please be aware that any communications posted on the forum represent the views of the individual who posted such communication and are not to be taken as our views. We accept no responsibility or liability for anything posted on the forum by any user of the forum and you must not use the forum to post, upload, or otherwise transmit information or pictures that are defamatory, a breach of privacy or otherwise unlawful.