SD Group Privacy Policy Summary 1. Summary We respect your privacy. This is a summary of our privacy policy and contains the most important and relevant points for you. 2. Collection We collect certain information: - on registration, when you register on our website; - on registration, when you register as a dealer or customer; - when you make use of our services, necessary to provide the service to you; when you share third-party information necessary to provide the service to you; - from your web browser; - from cookies we may send to your computer and from web beacons on our website to track how you use our website and to try and give you a personalised experience; and - optional information, that you provide when you upload or download content from our website, enter login details or when you enter competitions, take advantage of promotions, respond to surveys, request communication from us, or register and subscribe for certain additional services. 3. Use We may use your information: - for analytical, statistical or informational purposes; - for reporting purposes as part of a fee based information analytics services - to send you administrative messages and email updates to you; - for marketing purposes; - for providing, as determined at our discretion, services that may be of benefit to you; - targeted content in certain, specified instances. 4. Disclosure We might disclose your information in the specific circumstances mentioned in this policy. 5. Security We protect your information in the manner specified in our policy. 6. Your choices - You can turn off cookies in your browser; or - You can opt-out of marketing communications with us. 7. Contact us You can contact us with privacy related questions at [privacy@sdgroup.co.za] SD Group Privacy Policy 1. Audience This policy applies to all visitors to our website and prospective customers who have enquired about our services and customers who have subscribed to the services we offer (“you” and “your”). The terms ‘customers’ and ‘dealers’ are used interchangeably. 2. Purpose of this policy We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way we collect, store, use, and protect information that can be associated with a specific natural or juristic person and can be used to identify that person (“personal information”). Personal information: 2.1 includes - certain information collected on registration (see below); and - optional information that you voluntarily provide to us (see below). 2.2 excludes - information that has been made anonymous so that it does not identify a specific person; - permanently de-identified information that does not relate or cannot be traced back to you specifically; and - non-personal statistical information collected and compiled by us and information that you have provided voluntarily in an open, public environment or forum including (without limitation) any blog, chat room, community, classifieds or discussion board. Because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy. 3. Acceptance of terms You must accept all the terms of this policy when you register for any of our services and/or if you input any personal information on our website and/or provide any personal information to us by means of other communication, including but not limited to telephone and electronic mail. If you do not agree with anything in this policy, then you may not register for and use any of the services. You may not access our website or use our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts. By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all its terms. 4. Changes We may change the terms of this policy at any time. We will notify you of any changes by placing a notice on the website or by email. If you do not agree with the change you must stop using the services. If you continue to use the services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted such terms. 5. Collection 5.1 On registration. Once you register on our website, or once you input information into our website forms, you will no longer be anonymous to us as you will provide us with personal information. This personal information may include: - your name, surname, identity number, company name, company registration number, and VAT number - your postal address, email address, telephone number, and postal code; - your user ID and password; - your payment card number and details; - identification of our products and services that you are interested in; - other forms of personal information as defined by the protection of personal information act 4 of 2013; and 5.2 Collection on use. In order to provide the services to you, you will be asked to provide us with additional information on a voluntary basis which may apply to specific products, promotions or circumstances and such additional service information may differ from time to time (“service information”). 5.3 Optional details. You may also provide additional information on a voluntary basis such as (“optional information”). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, register and subscribe for certain additional services, request communication from us, or otherwise use the optional features and functionality of the website. 5.4 Collection from browser. We may automatically receive and record Internet usage information on our server logs from your browser, such as your Internet Protocol address (“IP address”), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (“usage information”). Please note that other websites visited before entering our website might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information. 5.5 Cookies. When you access our website we may send one or more cookies (small text files containing a string of alphanumeric characters) to your computer to collect certain usage information. We may use session cookies (which disappear after you close your browser) and persistent cookies (which remain after you close your browser and which can be removed manually) and may be used by your browser on subsequent visits to our website. We may use information gathered by cookies to improve the website. Please note that some of our business partners (e.g. advertisers) use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any such cookie or widget is governed by the privacy policy of the company that created it, and not by us. 5.6 Web beacons. Our website may contain electronic image requests (called a “single-pixel gif” or “web beacon” request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website. 5.7 Purpose for collection. We may use any service information and optional information or personal information provided by you for such purposes as indicated to you at the time. You agree to provide such service information or optional information. We may use your usage information for the purposes described above and to: - remember your information so that you will not have to re-enter it during your visit or the next time you access the website; - monitor website usage metrics such as total number of visitors and pages accessed; and - track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website. - We may collect personal information from you in order to provide services that may be of benefit to you; 6. Consent to collection We will obtain your consent to collect personal information: - Through this personal information and privacy policy; - in accordance with applicable law; and - at the time you provide us with any registration information or optional information. 7. Use 7.1 Messages and updates. We may send administrative messages and email updates to you regarding the website, our products and services. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages. 7.2 Targeted content. While you are logged into the website, we may display targeted adverts and other relevant information based on the personal information. In a completely automated process, computers process the personal information and match it to adverts or related information. 7.3 Sharing. We may share your personal information with: - Other individuals, companies or institutions where such information may be beneficial to them; - Other divisions or companies within the group of companies to which we belong, or affiliates or strategic partners or selected service providers so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services and communications. - An affiliate, in which case we will seek to require the affiliates to honour this privacy policy; - Our service providers under contract who help with parts of our business operations (including fraud prevention, bill collection, marketing, technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit; - Credit bureaus to report account information, as permitted by law; and - Banking partners as required by payment card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria). 7.4 Regulators. We may disclose your personal information as required by law or governmental audit. 7.5 Law enforcement. We may disclose personal information if required: - by a subpoena or court order; - to comply with any law; - to protect the safety of any individual or the general public; and - to prevent violation of our service terms. 7.6 Selling. We may sell your personal information. You hereby provide us with consent to do so and understand we will only engage in sales to the extent that it is permissible by law. 7.7 Statistical or Marketing purposes. We may disclose aggregate statistics about the personal information of customers and users to customers or advertisers or business partners. 7.8 Employees. We may need to disclose personal information to our employees that require the personal information to do their jobs. 7.9 Change of ownership. If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information. 8. Security of personal information Generally we use computer safeguards such as firewalls and data encryption to protect personal information and we enforce physical access controls to our buildings and files. We authorize access to personal information only for those persons who require it to fulfil their job responsibilities. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to mitigate interference or access from outside intruders. 9. Accurate and up to date We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes explicitly defined in this policy. From time to time we will request you to update your personal information. You are able to review or update any personal information that we hold on you by accessing your account online, by emailing us, or by phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information. 10. Retention of personal information We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless: - retention of the record is required or authorised by law; or - you have consented to the retention of the record. During the period of retention, we will continue to abide by our non disclosure obligations and will not share or sell your personal information beyond the consent already given for the sharing or sale thereof. 11. Transfer of personal information outside South Africa We may transmit or transfer personal information outside South Africa to a foreign country. Personal information may be stored on servers located outside South Africa in a foreign country whose laws protecting personal information may not be as stringent as the laws in South Africa. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent. 12. Updating or removing You may choose to correct or update the personal information you have submitted to us, by contacting us at: privacy@sdgroup.co.za. 13. Limitation We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites. 14. Enquiries If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us at: privacy@sdgroup.co.za