SEFAC PRIVACY POLICY

1. INTRODUCTION

SEFAC (“SEFAC, we, us, our”) is sensitive to the personal nature of the information you provide to us.

This privacy policy (“this Policy”) explains how we protect and use your Personal Information.

By providing us with your Personal Information, you –
Agree to this Policy and authorise us to process such information as set out herein; and
Authorise SEFAC, its Associates, our Service Providers and other third parties to Process your Personal Information for the purposes stated in this Policy.

We will not use your Personal Information for any other purpose than that set out in this Policy and will endeavour to protect your Personal Information that is in our possession from unauthorised alteration, loss, disclosure or access.

Please note that we may review and update this Policy from time to time. The latest version of this Policy is available on request.

This Policy applies to all external parties with whom we interact, including but not limited to individual customers, representatives of customer organisations, visitors to our offices, and other users of our services.

Defined terms used in this Policy are explained in Annexure “A”.

2. COLLECTION OF PERSONAL INFORMATION

We may collect or obtain Personal Information about you –

Directly from you;

In the course of our relationship with you;

In the course of providing services to you or your organisation;

When you make your Personal Information public;

When you visit and/or interact with our Website or our various social media platforms;

When you register to use any of our services;

When you interact with any third-party content or advertising on our Website; or

When you visit our offices.

We may also receive Personal Information about you from third parties.

In addition to the above, we may create Personal Information about you such as records of your communications and interactions with us, including, but not limited to, our attendance at events or at interviews in the course of applying for a job with us, subscription to our newsletters and other mailings.

3. CATEGORIES OF PERSONAL INFORMATION WE MAY PROCESS

We may process the following categories of Personal Information about you –

Personal details: name; and photograph;

Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences;

Identifier information: passport or national identity number;

Contact details: correspondence address; telephone number; email address; and details of your public social media profile(s);

Attendance records: details of meetings and other events organised by or on behalf of SEFAC that you have attended;

Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information;

Payment details: billing address; payment method; bank account number or credit card number; invoice records; payment records; SWIFT details; IBAN details; payment amount; payment date; and records of cheques;

Data relating to your visits to our Website: your device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Website; and other technical communications information; and

Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (including, but not limited to, mouse hover, mouse clicks and any forms you complete).

4. SENSITIVE PERSONAL INFORMATION

Where we need to Process your Sensitive Personal Information, we will do so in the ordinary course of our business, for a legitimate purpose, and in accordance with applicable law.

5. PURPOSES OF PROCESSING AND LEGAL BASES FOR PROCESSING

We will Process your Personal Information in the ordinary course of the business of providing services.

We will primarily use your Personal Information only for the purpose for which it was originally or primarily collected.

We will use your Personal Information for a secondary purpose only if such purpose constitutes a legitimate interest and is closely related to the original or primary purpose for which the Personal Information was collected.

We may subject your Personal Information to Processing during the course of various activities, including, without limitation, the following –

Operating our business;
Compliance with applicable law and fraud prevention;
Transfer of information to our Service Providers and other third parties or Recruitment.

We may process your Personal Information –

  • To provide and maintain our Website, including monitoring the usage of our Website.
  • To manage your Account: to manage your registration as a user of our Website. The Personal Information you provide can give you access to different functionalities of the Website that are available to you as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Website.
  • To contact you: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information.
  • To manage your requests: to attend and manage your requests to us.
  • For business transfers: we may use your Personal Information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred.
  • For other purposes: we may use your Personal Information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, services, marketing and your experience.

We may Process your Personal Information for safety and security purposes.

6. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

We may disclose your Personal Information for legitimate business purposes, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality.

  • To Service Providers: we may share your Personal Information with Service Providers to monitor and analyse the use of our Website, for payment processing or to contact you.
  • For business transfers: we may share or transfer your Personal Information in connection with, or during negotiations of, any merger, sale of SEFAC assets, financing, or acquisition of all or a portion of our business to another company.
  • With affiliates: we may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • With business partners: we may share your Personal Information with our business partners to offer you certain products, services or promotions.
  • With other users: when you share Personal Information or otherwise interact in public with other users, such information may be viewed by all users and may be publicly distributed. If you interact with other users or register through a third-party social media service, your contacts on the third-party social media service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
  • With Your consent: we may disclose your Personal Information for any other purpose with Your consent.

In addition, we may disclose your Personal Information –
If required by law;

Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or
suspected breach of applicable law or regulation;

Third party Operators (including, but not limited to data processors such as providers of data hosting services), located anywhere in the world, subject to what is stated below in terms of third party Operators;

To any relevant party for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including, but not limited to safeguarding against, and the prevention of threats to public security;

To any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including, but not limited to, in the event of a reorganization, dissolution or liquidation); and

To any relevant third-party provider, where our Website uses third party advertising, plug-ins or content.

If we engage a third-party Operator to Process any of your Personal Information, we recognise that any Operator who is in a foreign country must be subject to a law, binding corporate rules or binding agreements which provide an adequate level of protection similar to POPIA. We will review our relationships with Operators we engage and, to the extent required by any applicable law if force, we will require such Operators to be bound by contractual obligations to –

Only Process such Personal Information in accordance with our prior written instructions; and

Use appropriate measures to protect the confidentiality and security of such Personal Information.

7. TRANSFER OF YOUR PERSONAL INFORMATION

Your Personal Information is Processed at SEFAC’ s operating offices and any other places where third-party Operators involved in the Processing are located. This means that your Personal Information may be transferred to and maintained on computers located outside of your province. The third-party Operator will use appropriate measures to protect the confidentiality and security of your Personal Information.

8. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

We may transfer your Personal Information to recipients outside of the Republic of South Africa.

Subject to what is stated above in terms of third party Operators, Personal Information may be transferred outside of the Republic of South Africa provided that the country to which the data is transferred has adopted a law that provides for an adequate level of protection substantially similar to POPIA, the Operator/third party undertakes to protect the Personal Information in line with applicable data protection legislation and the transfer is necessary in order to provide the services that are required by SEFAC’ s members.

9. DATA SECURITY

We implement appropriate technical and organisational security measures to protect your Personal Information that is in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, in accordance with applicable law.

Where there are reasonable grounds to believe that your Personal Information that is in our possession has been accessed or acquired by any unauthorised person, we will notify the relevant regulator and you, unless a public body responsible for detection, prevention or investigation of
offences or the relevant regulator informs us that notifying you will impede a criminal investigation.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Information that is in our possession, we cannot guarantee the security of any information transmitted using the internet and we cannot be held liable for any loss of privacy occurring during the course of such transmission.

10. DATA ACCURACY

The Personal Information provided to SEFAC should be accurate, complete and up-to-date. Should Personal Information change, the onus is on the provider of such data to notify SEFAC of the change and provide SEFAC with the accurate data.

11. DATA MINIMISATION

SEFAC will restrict its processing of Personal Information to data which is sufficient for the fulfilment of the primary purpose and applicable legitimate purpose for which it was collected.

12. DATA RETENTION

SEFAC shall only retain and store Personal Information for the period for which the data is required to serve its primary purpose or a legitimate interest or for the period required to comply with an applicable legal requirement, whichever is longer.

13. LINKS TO OTHER WEBSITES

Our Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s Website. We strongly advise you to review the privacy policy of every Website you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

14. OUR LEGAL RIGHTS

You may have rights under the South African and other laws to have access to your Personal Information and to ask us to rectify, erase and restrict use of, your Personal Information. You may also have rights to object to your Personal Information being used, to ask for the transfer of Personal Information you have made available to us and to withdraw consent to the use of your Personal Information.

15. COOKIES AND SIMILAR TECHNOLOGIES

We may Process your Personal Information by our use of Cookies and similar technologies.

When you visit our Website we may place Cookies and similar tracking technologies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies and other tracking technologies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Information through Cookies and similar technologies, in accordance with our Cookie Policy. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our Website. Cookies and tracking technologies may include:

  • Cookies or Browser Cookies. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Website. Unless you have adjusted your browser setting so that it will refuse Cookies, our Website may use Cookies.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Website. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how you can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
  • Web Beacons. Certain sections of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit SEFAC, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of a certain section and verifying system and server integrity)

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser. Learn more about cookies: Cookies: What Do They Do?.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

Type: Session Cookies

Administered by: SEFAC

Purpose: These Cookies are essential to provide you with services available through our Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services cannot be provided.

  • Functionality Cookies

Type: Persistent Cookies

Administered by: SEFAC
Purpose: These Cookies allow us to remember choices you make when you use our Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use our Website.

16. DIRECT MARKETING

We may Process your Personal Information for the purposes of providing you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.

If you currently receive marketing information from us which you would prefer not to receive in the future, please email us at admin@sefac.co.za.

17. CONTACT DETAILS

The Data Protection Officer:

Alison Strydom

Telephone: +27 11 483 0007

Email: admin@sefac..co.za

Website: https://sefac.co.za/contact/

Date: 17 March 2021

ANNEXURE “A” – DEFINITIONS

Account” means a unique account created for you to access our Website.

Cookie” means a small file that is placed on your device when you visit a Website. In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear Graphic Interchange Format files (“GIFs”).

Operator” means any person or entity that Processes Personal Information on behalf of the Responsible Party.

Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

POPIA” means the Protection of Personal Information Act 4 of 2013.

Process“, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Responsible Party” means the entity that decides how and why Personal Information is Processed.

SEFAC (“SEFAC, we, us, our”)” means SOUTHERN EQUITORIAL FERRARI AUTOMOBILI CLUB, PO Box 87099, Houghton, Johannesburg 2041.

Sensitive Personal Information” means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.

Service Provider” means third party providers of various services whom we engage, including, but not limited to, providers of information technology, communication, file storage, data storage, copying, printing, accounting or auditing services and our insurers and professional advisors.

Usage Data” means data collected automatically, either by the use the Website or from the Website infrastructure itself, for example the duration of a page visit.

Website” means any Website operated, or maintained, by us or on our behalf.