For clarity, here are some definitions:
“Woodford” or “we” refers to Woodford Car Hire Pty Ltd registration number 2017/050797/07, a company registered with the Company and Intellectual Property Commission in South Africa.
“Data Subject” means any person (whether a natural or juristic person) who has provided us with information, or from whom we have collected information.
“Personal Information” or “Information”, for the purposes of this policy, means any information that we collect from you. Please see clause 4 for more details on the information that we collect.
“Processing” means any operation or activity of Woodford, whether automatic or otherwise, including to the collection, storage, updating or use of information.
“IO” or “Information Officer” means the person designated to handle complaints and requests in terms of this policy or any of the information that Woodford processes, so mandated in terms of Clause 11 of this policy.
Woodford is a business in the logistic and vehicle rental industry and for the purposes of this policy focuses on the services of vehicle rentals to the public in the Republic of South Africa. The Protection of Personal Information Act 4 of 2013 requires that we keep you informed on how we use your information, for what purpose we use your information, and how long we intend to keep it. We respect our clients’ right to privacy and endeavour to collect and use your information minimally, transparently, and for the purpose for which it was collected.
Woodford is committed to keeping your information safe and secure, to provide you with reasonable access to your information, and to give effect to your rights in terms of POPI and the ECTA. To this extent, we emphasise that only your necessary information is collected and used accordingly. The collection serves to protect your legitimate legal interests.
Any information that we collect from you will be with your consent. Consent may be obtained from our clients during engagements with you whether via physical or electronic means. If we are mandated by a law to collect your information, we will notify you of the authorising law.
Where you provide us with information, you do so willingly and voluntarily with the understanding that we require the information to protect yours and our interests and will treat it with utmost confidentiality.
Woodford requires certain categories of information to ensure that you receive high quality services and that your client needs are met and to ensure that we and the general public are protected. Information may be collected for explicitly defined purposes or incidental to the function, activity or service of Woodford or a responsible third party.
The purpose of collecting your information includes, but is not limited to:
a. To assist the transactions that you request, such as reserving, renting, purchasing or leasing motor vehicles.
b. To provide customer service related to your interactions with us or to respond to your enquiry.
c. To enroll you in our loyalty programmes and send non-promotional information relating to your ongoing membership of these programmes.
d. To share information about your vehicle's location with emergency services in the event that you are involved in a road accident.
e. To share information with government and regulatory authorities when required by law or in response to legal process, obligation, or request.
f. To communicate important information about your rental, such as arrival and return alerts.
g. To assist us in providing better products and services: for example, to evaluate the performance of our staff, to assess the quality of products and services received and to help us improve our websites, facilities and services.
h. To compile statistics and analysis about our customers' use of our websites, products and services.
i. To develop a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you.
j. To protect our legal rights and manage the security of our networks and property.
k. To share your information with third parties in order to prevent fraud and protect our business interests and rights, privacy, safety and property, or that of the public. We will do this to collect unpaid accounts, to avoid liability for penalties you incur (e.g. traffic violations and fines) and for claims processing purposes.
l. To share your information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain and to enforce the terms of any rental agreement or our websites' terms and conditions.
m. To share your information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain and to enforce the terms of any rental agreement or our websites' terms and conditions. We will also disclose your information to third parties if the rights of another individual may be violated.
n. assessing legal claims.
Woodford warrants that your information will never be used for a reason that is not in line with what it was collected for. Should the purpose for which we collect your information not be specified in this clause, the purpose will be communicated to you in writing and agreed to.
Woodford collects different categories of information from our clients depending on their needs. We do not collect information that is unnecessary or irrelevant for the purpose specified, striving to collect only the information that is necessary for us to deliver our service.
To the extent that we require information from you, you can expect to provide us with information including but not limited to:
4.1 full names and surnames for natural persons;
4.2 name and registration number for legal entities
4.3 postal and/or physical addresses;
4.4 identity number of the client in the case of natural persons;
4.5 contact details:
4.5.1 email addresses;
4.5.2 telephone numbers;
4.5.3 mobile phone numbers; and/or
4.5.4 fax numbers
4.6 any other information that may be necessary to enable us to provide the service we offer.
Please bear in mind that this is not an exhaustive list and we may at times require information that is not contained herein. We will inform our clients as to the information we collect from them whenever practicable, whether such information is voluntary or mandatory, and what the consequences are if information (whether voluntary or mandatory) is not provided.
We may collect information about you from external sources such as online booking site, insurance providers, hotel and airline clubs, credit bureaus and marketing agencies.
Our vehicles are fitted with technology which collects and transmits date such as tracking devices, cameras and vehicle diagnostic devices which will provide us with information relating to your location, the vehicle you hire and the manner of use thereof for your own safety.
We are not responsible for any information that is left by you in the vehicle which you have hired and cannot guarantee the privacy and confidentiality thereof.
Woodford staff are regularly reminded that they have a confidentiality obligation towards our clients who hold a Right to Privacy under the Constitution, and neither Woodford nor its staff will disclose your information to a third party unless:
a. we are required to do so by law; or
b. the disclosure is necessary to enable us to carry out our services;
c. the disclosure is necessary to protect the rights of third partiers or
d. it is vital to protecting the rights of Woodford
In the event that your information is to be disclosed to a third party, Woodford will attempt to ensure that the third party receiving your information is as committed to protecting your privacy and information as we are.
We specifically record that we share your personal information with for the following purposes:
a. To manage your rental and communicate with you about or assist with your rental.
b. In relation to any incident arising from your dealings or an additional authorized driver's dealings with if thinks that, as a result of such incident, you or an additional authorized driver could be a risk for future rentals.
c. In order for and its third-party service providers to carry out phone customer satisfaction surveys.
d. To send you marketing communications about similar products or services which thinks may be of interest to you, including targeted advertising on sites, selected partner sites and social networks.
e. To compile statistics and analysis about you – and any applicable additional authorized drivers’ – use of products and services, including statistics based on anonymized data, which enable to provide you and other customers in the future with better customer service, products, features and functionalities.
Woodford is committed to maintaining the integrity and accuracy of your information. To this extent, clients are reminded that they may request access to their own information at any time and to request that we update or correct any information that may be outdated or incorrect.
We take reasonable and routine steps to ensure that the information we collect is up to date and accurate. Where information does not need to be updated to fulfil the purpose for which it was collected, such information will not be updated without the client’s express request.
Woodford provides for four categories of requestors for access to information:
6.1 a person requesting his or her own information;
6.2 a person requesting information for and on behalf of another person;
6.3 a person requesting information about another person; or
6.4 a public body that requests information in the public interest
Requestors must provide proof of identity and a Power of Attorney where applicable. Woodford request any other information to verify the requestor’s identity.
Our websites may include social media features, such as the Facebook button. These features may collect your IP address, pages you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.
If you use one of these social media sites and do not want them to collect data through our website and link it to your member data, you must log out of your user account before visiting our website and delete the relevant cookies. You can also block social plug-ins with browser add-ons. See the social media site for their plug-in instructions or see our Cookie Policy for more information.
The safety and confidentiality of your information is of paramount importance to Woodford and its staff. To this extent, Woodford is committed to preventing unauthorised access, damage, loss of or destruction of your information by ensuring that industry- appropriate and adequate security measures are implemented and persistently reviewed.
We do our best to identify risks both internally and externally, and to adapt accordingly we implement security systems with due regard to generally accepted information security practices.
Where there are reasonable grounds to suspect that the personal information of a data subject has been breached (accessed, acquired, deleted or damaged by an unauthorised third party), we will notify the data subject of such a breach as well as inform the information regulator as soon as reasonably possible after the breach is discovered.
Information we collect on data subjects will not be held for longer than necessary, or if the purpose for which said information was collected has ultimately been fulfilled, or if the collected information has become obsolete.
Where no agreements, other laws or terms in this policy apply, a record of personal information will be kept for one year after the information was used, including the specific purpose for which the information was collected
We will destroy Records of Personal Information as soon as reasonably practicable, unless further retention is required by the laws of the Republic of South Africa or agreed to between the parties.
Woodford will endeavour to ensure that information is destroyed, where reasonable, after its retention period has lapsed in terms of clause 8.
If clause 8 does not apply, clients are reminded that they have the right to obtain the erasure of their personal data without an undue delay if:
10.1 the information is no longer necessary for the specified purpose it was collected for; or
10.2 where the data subject withdraws consent in terms of clause 2 of this policy; or
10.3 the collected personal information is inaccurate, irrelevant, excessive or incomplete.
If clients prefer for Woodford to cease processing their information instead of deleting it, reasonable notice may be given to this effect following which we will immediately stop processing your information.
We will never process your information for the purpose of direct marketing (or spam) unless:
11.1 you have consented to such processing; or
11.2 you had not previously refused consent; and if
11.3 your contact details were obtained in the context of providing you with our services; and if
11.4 you were given reasonable opportunity to object to the direct marketing; or
11.5 you are already a client.
Woodford Information Officer is responsible for:
12.1 Ensuring information policies are reviewed, up to date and sufficient;
12.2 Handling complaints or requests made in terms of this policy;
12.3 Supporting this policy with relevant documentation;
12.4 Ensuring Information Security training is conducted;
12.5 Backing up data;
12.6 Reporting incidents and allocating security responsibilities; and
12.7 Any other relevant information-related duty or responsibility.
Woodford Information Officer is Marlon Ellis with Contact Number: +27 (0)31 207 8669 and E-Mail Address: privacy@woodford.co.za
The obligations in this policy apply to Woodford, its management, staff members, and representatives. Any external individuals who Woodford entrusts personal information or the security thereof to are also bound by the terms in this policy.
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