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MAZDA SA INFORMATION PROCESSING POLICY

 

Mazda Southern Africa Data Protection Policy
Effective date 30-Jun-21

 

WHO WE ARE

When we refer to “we”, “us”, “our” or “MAZDA SA”, herein we are referring to Mazda Southern Africa (Pty) Ltd (Registration Number 2013/113879/07) and its affiliated companies, or any of them, as the context requires, as well as our successors in title. Our principal place of business is at 4 Travertine Ave, N1 Business Park, Midrand, 0157, but we recommend you contact us via telephone at +27 12 670 7700 or electronic mail at customercare@mazda.co.za

The Protection of Personal Information Act, 2013 (Act. 4 of 2013) regulates the manner in which personal information may be processed, by establishing conditions, in harmony with international standards, that prescribes how organizations collects, handles and stores personal information.

We process personal information in accordance with the stipulations of the Protection of Personal Information Act. The details of which data is processed and how this is used depends largely on the services requested or agreed in each case.

“Personal information” refers to information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person.

Personal information includes any information that lets Mazda identify you as a unique individual such as your name/ and surname combined with your physical address, contact details and or passport/identity number.

Personal information also refers to the personal information that uniquely identifies a legal entity, such as the trading name of a company combined with the company registration number.

Personal information may be given or collected by Mazda in writing as part of a written application form, electronically, telephonically, social media or online (www.mazda.co.za).

 

ACCOUNTABILITY

MAZDA SA is committed to protecting your privacy. We respect all rights to your personal information.  For this reason, this policy governs our processing of your personal information. This document sets out:

  • How we collect your personal information
  • What types of personal information we collect and retain of individuals
  • The purposes for which we use such personal information
  • Your rights to the personal information held by us

The Information Officer have the following responsibilities:

  • Developing, publishing and maintaining a Protection of Personal Information Policy which addresses all relevant provisions of the Act, including but not limited to the following:
  • Reviewing the Act and periodic updates as published
  • Ensuring that the Act induction training takes place for all staff
  • Ensuring that periodic communication awareness on POPI Act responsibilities takes place
  • Ensuring that Privacy Notices for internal and external purposes are developed and published
  • Handling data subject access requests
  • Approving unusual or controversial disclosures of personal data
  • Approving contracts with Data Operators
  • Ensuring that appropriate policies and controls are in place for ensuring the Information Quality of personal information
  • Ensuring that appropriate Security Safeguards in line with the POPI Act for personal information are in place
  • Handling all aspects of relationship with the Regulator as foreseen in the POPI Act provide direction to any Deputy Information Officer if and when appointed

Consideration will be given on an annual basis to the re-appointment or replacement of the Information Officer, and the need for any Deputy to assist the Information Officer.

 

HOW WE COLLECT INFORMATION

We collect information about you directly from you as well from third parties and publicly accessible sources. We collect information about you in the following manner:

  • From you, when you make use of our website, enquire about our products, offers and/or subscribe to our services, when you enter into agreements with us as well as when you subscribe to our newsletters or consent to receiving communications from us
  • From public registers, credit bureaus, money laundering, fraud prevention and law enforcement agencies
  • From our business partners and the persons employed by us to provide services for us, which may include debt collection services, communications services and data hosting, processing and management services
  • From such persons or entities which may be legally entitled to provide us with information about you;
  • From persons or entities which you may consent to providing us with information about you.
  • We potentially collect your data at point of purchase to protect your own interest as well as complying with the Consumer Protection Act for safety critical recalls.

 

COOKIES

When you visit our website we may collect certain information about your usage preferences and history. Such information will be stored in a cookie on your computer's hard drive by your web browser. Cookies are intended to assist and improve your use of our website. Most browsers accept cookies automatically, but usually you can alter the settings of your browser to prevent automatic acceptance. If you choose not to receive cookies, you may not be able to use all of the features of our website. Please consult the MAZDA SA Manage Cookie Policy.

Every time you connect to our website we store web server logs which show your IP address (the unique number which your machine uses when it is connected to the Internet); what you looked at; whether the page request was successful or not, and which browser you used to view the pages. The use of this data is strictly for statistical and personalisation purposes only. This helps us understand which areas of the site are of particular interest and also which pages are not being requested. It also tells us how many hits and page requests we get.

 

INFORMATION WE HOLD ABOUT YOU

We record and hold the following types of information about you:

  • Details of when you contact us and when we contact you, including the IP addresses when you contact us via electronic mail or through our website, via a social media platform, electronic mail addresses and telephone numbers you contact us from as well as the content of the communications between us, which we may record
  • All information contained in the forms, requests or orders you submit to us, via electronic mail, our website or using any other means
  • Details about you which you provide to us when you subscribe to or use our services or which you provide to us in accordance with any agreement which we have with you, including your name, contact details, location, identity number and place of residence;
  • Information received pursuant to our enquiries with public registers, credit bureaus, money laundering, fraud prevention and law enforcement agencies; and
  • Details of your preferences regarding our services, including which of services you have made enquiries with us about.
  • Details regarding any vehicle and/or product purchased from MSA or any MSA Dealer, including the date of purchase, the dealer at which the purchase was made, as well as details pertaining to any financing arrangement relating to the vehicle and/or product, which details shall include: 
  • If the financing is obtained through Mazda Finance, the repayment period and monthly instalment payable by you, as well as all necessary information relevant to the finance application, which information shall be treated with the necessary care and privacy and retained in accordance with the prescribed statutory requirements;

    or
  • If financing is obtained other than through Mazda Finance then the information shall include, the identity of the financier and the period of the financing arrangement.

 

RECORD RETENTION

  • We will hold your personal information for a period which exceeds the maximum period permitted by applicable law and would be destroyed or deleted as soon as possible when the responsible party is no longer authorized to retain the record.
  • Above and beyond this, we are subject to various retention and documentation obligations that emanate from legislation, code of conduct and statutory provisions that may require a longer retention period.
  • We may also use this personal information for statistical, historical or research purposes after this period and for no other purpose.
  • After this period we will destroy or de-identify this personal information as soon as reasonably possible.
  • Processing of your personal data may involve transferring of your data via a directory in other countries including but not limited to Japan and Europe where the level of protection of your personal information may not be as high as within South Africa.

 

THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

Certain of the mandatory information which we collect about you, as identified below, we need to use in order to enable you to participate in our services and to process your requests for and instructions regarding our products, offers and/or services and also, if applicable, to exercise our rights under any agreements we have concluded with you and the execution of your explicitly defined orders In particular, the processing thus serves to provide the manufacturer warranty and service plan, optional extended warranty, recall campaigns (Consumer Protection Act no 68 of 2008), roadside assistance, maintenance of the digital service record, goodwill processes. If we do not have the right to use such information, it may not be possible for you to make use of our products, offers and/or services or for us to exercise our rights under the agreements which we have entered into with you. Such information includes:

  • Your name, contact details, identity number and place of residence; 
  • Your preferences regarding our products, offers and/or services which you make use of or have made enquiries about;
  • Details of your geographic location when you submit data to us in connection to our products, offers and/or services; 
  • The information about you which we have received from public registers, credit bureaus, money laundering, fraud prevention and law enforcement agencies; and
  • The information which you and third parties have provided to us which we need to verify that the information which we have received from or about you are accurate, complete and up to date.

 

FURTHER PROCESSING LIMITATION

To the extent that we hold information about you which we do not need for purposes of providing our products or services to you or to exercise our rights under any other agreement which we may have with you, and in respect of which you have given us your consent to use, such information will be used by us only for the purposes as agreed to by you, in particular for the following purposes:

  •  Advertising or market opinion research, as far as you have not objected to the use of your data in this respect
  • Updates on products and services
  • Solely used for historical, statistical or research purposes and will not be published in an identifiable form
  • Benchmarking
  • Performing customer satisfaction surveys to measure the degree to which the products or services of business meet consumers’ expectations
  • Answering any customer’s and/or prospect’s questions and/or requests for services through our call center, as well as the provisions of such requested services (including contact us services)
  • The further development of services and products as well as existing systems and processes
  • Any monitoring or recording of telephone conversations for quality control and training purposes.

 

SHARING YOUR INFORMATION

Keeping your personal and financial information secure is one of our most important responsibilities. We cannot disclose your information unless legally permitted thereto. Save as set out below, we will not transfer your information to a third-party without your consent unless legally obliged thereto. In particular, we do not sell lists or databases with our clients’ information and will not provide any of your information to entities outside our group so as to permit them to market their products or services to you. You agree that we may transfer your information to the following people and organisations in pursuit of the data processing purposes set out in this policy:

  • To all persons in our employ or in the employ of our affiliated companies, including to our directors, employees, contractors, agents, auditors, legal and other professional advisors and of our affiliated companies
  • To governmental, judicial, regulatory and law enforcement bodies and agencies, including the South African Revenue Services and the National Credit Regulator
  • To persons employed by us to provide services on our behalf that adhere to principles similar to ours regarding the treatment of your information, including delivery, debt collection, data hosting, processing and management services
  • To any person to whom we cede, delegate, transfer or assign any of our rights or obligations pertaining to the services provided to you or any agreement which we have with you
  • To any person that acts as your legal guardian, executor of your estate, curator or in a similar capacity.
  • To such other persons as may be permitted by applicable law or that you may consent to.

 

INFORMATION QUALITY

We will take reasonable steps to ensure your information is complete, accurate and not misleading.

You have the right to ask us to update, correct or delete your personal information. We will require a copy of your ID document and NATIS document (Vehicle detail) to confirm your identity before making changes to personal information we may hold about you.

 

SECURITY

We will strive at all times to ensure that your records will always be protected against unauthorised or accidental access, processing, damage or loss of your information. We maintain this commitment to data security by implementing appropriate reasonable technical and organisational measures to safeguard and secure your information. If we use a third-party to host, manage or process your data on our behalf we will require that such third-party also commit to implementing appropriate reasonable technical and organisational measures to safeguard and secure your information. If we are not prevented by a law enforcement or regulatory agency, we will notify you and the regulator without undue delay if we believe that unauthorised access to your information may have occurred, providing you with such information as you may reasonably require to implement protective measures.

 

Your rights regarding your information

Provided that you give us suitable and adequate proof of your identity, you have the right:

  • To know which records we hold about you
  • If our right to process your personal information requires your consent, to withdraw such consent at any time, provided that this shall not affect the lawfulness of processing which occurred prior to such withdrawal
  • To object to the further collection, use, sharing or processing of your personal information by us at any time where such processing activities are not required by us to exercise our rights under any agreement, we have with you or for such other purposes as may be required or permitted by applicable law
  • To require us to correct, erase or cease processing information or records we hold about you and for which we require your consent to process, or that we are no longer permitted to retain, or which are inaccurate, irrelevant, excessive, out of date, incomplete, misleading or has been unlawfully obtained;

 

Any of the above can be done by contacting us directly by any means provided by us, including by submitting a written request to us via email at customercare@mazda.co.za

We will notify you of the steps taken as a result of your request. We will not be obliged to provide you with information or agree to your request to the extent that we are prohibited thereto by applicable law, if compliance would unreasonably prejudice our legitimate interests or that of a third-party, or if we have a legal basis upon which to deny your request.

Please note that we may require a reasonable period to comply with your request. If you have a complaint relating to the protection of your personal information, including the way in which it has been collected or processed by MSA, please contact us using the local contact details as listed above. If you have not had your complaint dealt with satisfactorily, you may lodge a complaint with the regulator by visiting their website at the following link https://www.justice.gov.za/inforeg.

 

Right to amend this Data protection statement

Mazda Southern Africa reserves the right to change this statement at any time. All changes to this statement will be posted on the MSA website. Unless otherwise stated, the current version shall supersede and replace all previous versions of this statement.

 

 

END OF POLICY.