INTRODUCTION

• This document explains how the SMH Car Hire including all its subsidiaries, hereinafter referred to as “SMH Car Hire ” collects, uses and processes Personal Information, in accordance with the requirements of Article 18 of the Protection of Personal Information Act (“POPIA”).
• According to the Act “personal information” means information relating to an identifiable, living and natural person, and where it is applicable, an identifiable and existing juristic person. A more comprehensive definition of ‘personal information’ can be found in the DEFINITIONS section of this document.
• SMH Car Hire is committed to protecting and respecting privacy. SMH Car Hire  strives to ensure that our use of Personal Information is lawful, reasonable, and relevant to our business activities.

CONSENT

• SMH Car Hire may collect, get, receive, record, organise, collate, store, update, change, retrieve, read, process, use and share Personal Information in the manner as set out in this Privacy Policy. Any natural or juristic person concerned about any aspect of this Privacy Policy, as it relates to their Personal Information, is encouraged to contact our Information Officer.
• This Privacy Policy applies to the processing by SMH Car Hire or on our behalf, and our successors-in-title, of the Personal Information relating to users who accesses and/or uses our website or our products and services, or are a provider of products and services to us. Parties may include business partners, clients, suppliers, former employees, prospective
  employees and any other data subject that engages with SMH Car Hire via any internet-connected device or mobile device.
• Users agree and accept that there is certain compulsory Personal Information they must provide SMH Car Hire with to engage with us fully, for us to supply our products or services to them, or for them to enjoy all of the features and functionality on the Website. Users that decide not to provide SMH Car Hire with such compulsory Personal Information, agree that we may limit our engagement with them, our procurement or delivery of goods and services and certain features and functionality on the Website.

DEFINITIONS

• COOKIES means a small text file created by a website that is stored in the user’s computer –either temporarily for that session only or permanently on the hard disk. Cookies provide a way for the website to recognize users and keep track their preferences,
• DATA means information in any electronic form,
• DATA SUBJECT means the person to whom any personal information relates,
• IP ADDRESS means a unique address that identifies a device on the Internet or a local network,
• PERSONAL INFORMATION means information relating to an identifiable, living and natural person, and where it is applicable, an identifiable and existing juristic person, including, but not limited to-
  – information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of a person,
  – information relating to the education or the medical, financial, criminal or employment history of a person,
  – any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or any other particular assignment to a person,
  – any biometric information of a person,
  – any personal opinions, views or preferences of a person,
  – any correspondence sent by a person that is implicitly or explicitly of a private or confidential nature,
  – any further or related correspondence that would reveal the contents of the original correspondence,
  – any views or opinions of another individual about a person.
• POPIA means the Protection of Personal Information Act 4 of 2013,
• TRAFFIC DATA means any data processed for the purpose of the conveyance of a communication on an electronic communications network and includes data relating to the routing, duration or time of any communication,
• USER means a person who uses a computer or other device to access this website, and
• WEB BROWSER means an application used to access and view any website. This may include web browsers like Internet Explorer, Google Chrome, Firefox and Safari, but is not limited to them.

INFORMATION BEING COLLECTED

• SMH Car Hire gathers various types of information, including information that identifies or may identify individuals (“Personal Information”) as explained below.
• SMH Car Hire may collect information directly from individuals that provide us with personal details, such as first name, surname, mobile number, e-mail information and all information necessary to facilitate the type of business transaction being conducted, or the service being provided.
• SMH Car Hire website may also collect certain information related to devices, such as the device’s IP address, referring website, what pages the device visited, and the time that the device visited our website.
• SMH Car Hire may passively collect certain Personal Information from the device used to access and navigate the website by way of various technological applications, for instance using server logs to collect and maintain log information.
• SMH Car Hire also uses cookies and anonymous identifiers which enable our computer system to recognise users when they next visit the website to distinguish them from other users and to improve our service to them. The data collected can be used to enhance the content of the website and make it more user-friendly, as well as to give users a more personalised experience.

PURPOSE OF COLLECTION

• SMH Car Hire only processes personal information for the purposes explained in this Privacy Policy or as agreed-upon when we collected the personal information, in accordance with all applicable data laws and the underlying commercial transaction.
• We use personal information to:
  – Email personalized offers and/or newsletters,
  – Provide our service offerings or related service offerings,
  – Customize users’ experience on our website, or
  – Improve our website’s usability.
• All personal information collected is only with our clients’ full consent and any client can opt-out at any time.

THIRD-PARTY AND PUBLIC SOURCE COLLECTION

• SMH Car Hire may from time to time also receive Personal Information about users from various third parties including recruitment agencies, suppliers of background checks services and other publicly available sources.

WEBSITE ANALYTICS

• Any user may visit the website without providing any personal information. The website servers will in such instances only collect the IP address used by the data subject to access the website, but not the e-mail address or any other personal identifiable information. The information gathered on IP addresses is aggregated to measure the number of visits, the average time spent at the website, pages viewed, etc. SMH Car Hire analyses non-identifiable traffic data to improve our services, and may do so via third party analytics tools, for example Google Analytics and Google Search Console.
• SMH Car Hire may collect, hold, and use statistical information about website visits to help improve the website. Such information includes:
  – The IP address,
  – The search terms used,
  – The pages accessed on SMH Car Hire website and the links visitors clicked on,
  – The date and time the website was visited,
  – The referring website or email link (if any) which was clicked through to SMH Car Hire website, and
  – The type of web browser used (e.g. Internet Explorer, Mozilla Firefox, Google Chrome, etc.).
• The traffic data is aggregated and is not personally identifiable. SMH Car Hire website analysis will also respect any “do not track” setting that a user might have set on their web browser.

USE OF COOKIES

• SMH Car Hire uses cookies on its website where they are required for particular features to work, and also uses cookies to track and analyse website usage. The cookies do not collect any personal information about users or data subjects.

LINKS TO SOCIAL NETWORKING SERVICES

• SMH Car Hire uses social networking services which may include Facebook, LinkedIn, Twitter and other social media networks to communicate about its services and value offerings. When communicating with SMH Car Hire through any of these services, that particular social networking service may collect personal information for its own purposes.
• These services may track the use of SMH Car Hire website on those pages where their links are displayed. Users logged in to those services (including any Google services) while using SMH Car Hire website will have their tracking associated with their profile with those service providers.
• These services have their own privacy policies which are independent of the privacy policy and practices ofSMH Car Hire

INTERNATIONAL DATA TRANSFERS

• Personal Information collected and/or processed may be sent to other countries and territories. SMH Car Hire will ensure that the recipient country is subject to data privacy laws, binding corporate rules or binding agreements which provide an adequate level of protection.

RECIPIENTS OR CATEGORY OF RECIPIENTS OF THE INFORMATION

• SMH Car Hire may share information with third party vendors, consultants and other service providers whom it employs to perform tasks on its behalf. These companies may include website analytics companies, CRM service providers, email service providers and others.

SECURITY AND SHARING OF PERSONAL INFORMATION

• SMH Car Hire will take all reasonable technical and organisational measures to secure the integrity of Personal Information. We will use accepted technological standards to prevent unauthorised access to or disclosure of Personal Information, and to protect Personal Information from misuse, loss, alteration and destruction.
• SMH Car Hire will review our information collection, storage and processing practices, including physical security measures periodically, to ensure that we keep abreast of good practice.
• SMH Car Hire will not intentionally disclose any Personal Information, whether for commercial gain or otherwise, other than with the user’s permission, as permitted by applicable law or in the manner as set out in this Privacy Policy.

STORAGE OF PERSONAL INFORMATION

• SMH Car Hire can and may store Personal Information on:
  – our premises, in the form of hard copies,
  – the premises of third party service providers such as document storage service providers,
  – our servers, or
  – on the servers of our third party service providers, such as IT systems or hosting service providers.
• Where the storage site is not under our direct control, SMH Car Hire will ensure that we have entered into written agreements with those third party service providers that require them to secure the integrity and confidentiality of all Personal Information in their possession
  by taking appropriate, reasonable technical and organisational measures.
• From time to time, SMH Car Hire and/or its service providers may need to transfer to and/or store Personal Information on servers in a jurisdiction other than where it was collected (i.e. outside of South Africa).
• If the location to which the Personal Information is transferred and/or is stored does not have substantially similar data laws to those of South Africa, which provide for the protection of Personal Information, SMH Car Hire will take all reasonable and practical steps to ensure that all Personal Information is adequately protected in that jurisdiction.

DIRECT MARKETING

• SMH Car Hire also processes Personal Information for the purpose of direct marketing by way of various forms of electronic communication. We will only send users direct marketing materials who have specifically opted-in to receive these materials, or if the user is a client of SMH Car Hire, and at all times in accordance with all applicable laws.
• Users that complete any subscription form on the SMH Car Hire website agree to receive marketing communication from us.
• Users may refuse to accept, require us to discontinue, or pre-emptively block any communication from SMH Car Hire if that approach or communication is primarily for the purpose of direct marketing.
  Users may opt out of receiving direct marketing communication from SMH Car Hire at any time by requesting (in any manner, whether telephonically, electronically, in writing or in person) to stop providing any direct marketing communication to them.

DATA SUBJECT RIGHTS

• Data Subjects have the right to request access to all relevant information, including information about the identity of third parties, or categories of third parties, who have or had access to such information.
• Data Subjects also have the right to require SMH Car Hire to correct or delete personal information that is inaccurate, irrelevant, excessive, out of date, incomplete,misleading or obtained unlawfully, or to delete information that we can no longer retain.
• Data Subjects can also object to the processing of personal information unless the process is based on legitimate commercial interest or as agreed-upon for a commercial transaction, or in the performance of a public law duty. 

INFORMATION OFFICER CONTACT DETAILS

Contact person: Jakes van der Merwe
Contact number: +27 (011) 608 3442
Email: jakes.vandermerwe@smh-group.co.za