Data Protection Policy


Personal data plays an increasingly important role in our economy, society and everyday life. New and innovative technologies are generating vast amounts of personal data, and modern communication networks and processing systems enable organizations to collect, analyze, use, share, and store data globally.
It is in this context that data protection legislation has been developed and implemented around the world.
Cartrack recognizes the privacy rights of data subjects and is committed to protecting and controlling the use of the personal data it collects in accordance with the regulatory requirements of the jurisdictions in which it operates.
Executive management continually assesses whether further policies, procedures and terms and conditions need to be developed and implemented or modified, including those relating to data protection; Consent to policies and forms; data access; Security breaches and employee privacy requirements.


This Policy applies to the collection, use and disclosure of personal data provided to Cartrack. It directs how we collect, store and process the personal data of data subjects, customers and other stakeholders in accordance with relevant data protection legislation.


This Policy applies to all legal entities within the Cartrack Group, including all employees, and third parties who provide services to the Group, covering personal data collected and managed by the Cartrack Group.

What is a profile

"Personal data" means any information or piece of information relating to an individual that can be identified directly (e.g. by name) or indirectly (e.g. by pseudonymous data). As a result, personal data includes things like email/home addresses, usernames, profile pictures, user-generated content, financial information, and geolocation.

Principles for the collection and processing of personal data

1. Collection/Processing
Cartrack only collects personal data when it is necessary to comply with an applicable legal obligation, or when such processing is necessary for the performance of a contract or pre-contractual procedure.
Cartrack may also process information if it has a legitimate interest, provided that in each case our interests are compatible with applicable law and the rights of the data subject.
When there are no other lawful processing conditions to support data processing operations, Cartrack will only process personal information if it has obtained the consent of the data subject to process said personal data for specific, explicit and legitimate purposes.
2. Purpose
Cartrack will only disclose or use personal data for the specific purpose for which it was obtained or for other lawful processing.
3. Accuracy
Cartrack will take all reasonable steps to ensure that the personal data it processes is accurate, complete and up-to-date.
4. Openness
Cartrack is committed to making public its policies and practices regarding the handling of personal data.
5. Security
Cartrack will ensure that appropriate security safeguards are in place to protect personal data from loss, unauthorized access, destruction, use, modification or disclosure.
6. Pick-up
Cartrack may transfer personal data outside the European Union for processing by some of its service providers, companies associated with and/or belonging to the Cartrack Group. In this context, Cartrack ensures that such transfers are carried out in accordance with the legislation in force and guarantees an adequate level of protection for personal data in accordance with Article 46 of the EU General Data Protection Regulation ("GDPR") in accordance with the standard data protection clauses adopted.
Under no circumstances will Cartrack transfer personal data outside of the above conditions or sell personal data to third parties.
7. Retention
Cartrack will retain Personal Data for as long as the purposes for which it was collected. In some cases, data may be retained for a longer period of time, especially if required to do so by applicable law.
8. Access
Data subjects may request a copy of their personal data from Cartrack and, if necessary, direct Cartrack to make changes in accordance with local regulations to correct the data or permanently delete their personal data.

Rights of Data Subjects

Withdrawing consent or opting to delete certain types of personal data may prevent Cartrack from providing certain services to data subjects or responding to inquiries as a potential employee or supplier. To better protect personal data, Cartrack takes steps to verify the identity of data subjects before granting access or making changes to personal data.
InformationData subjects have the right to clear, transparent and understandable information about how we use personal data and what the data subject's rights are
usufructData subjects have the right to access any personal data we hold about an individual and to obtain a copy (subject to certain restrictions). There may be a reasonable fee for providing such access, but only as permitted by law
RectificationIf the personal data is incorrect or outdated, the data subject has the right to rectification of the personal data and/or completion if it is incomplete
ForgottenThe data subject has the right to have personal data deleted or deleted; Retain personal data for legal or legitimate reasons
direct sellingData subjects may unsubscribe or opt out of direct marketing communications at any time
Withdrawal of ConsentWhen such processing is based on consent, the data subject may withdraw consent to our processing of personal data. In the case of withdrawal of consent, the lawfulness of the processing prior to its withdrawal remains unaffected
Objection HandlingWhere the processing of personal data is based on a legitimate interest pursued by the data controller, the data subject may object to the processing of personal data, such as:
To improve our products and services
Enhance our communication with data subjects
To properly administer our website
risk management
Protection of legitimate rights and interests
complaintsData subjects have the right to contact the relevant data protection authority to lodge a complaint about our data protection and privacy practices
Data portabilityData subjects have the right to move, copy or transfer personal data from our database to another database. This only applies to personal data provided by the data subject, where the processing is based on a contract or explicit consent and the processing is carried out by automated means of output
limitIn the case of GDPR restrictions, the data subject may restrict the processing of personal data so that it can be stored, but not further used or processed, such as:
Inaccurate data contested by the data subject must be restricted until it is verified and corrected
The processing is unlawful but the data subject objects to its deletion
Cartrack no longer needs the data subject's data, but the data subject requests that the data be stored for the establishment, exercise or defense of legal claims
The data subject objects to processing based on Cartrack's legitimate interests until priority is verified

Data Protection Officer

"Data subjects with any questions or concerns about Cartrack's data protection policies or procedures may contact the Data Protection Officer at: South Africa, Kenya, Tanzania, Namibia, Nigeria, Singapore, Mozambique: Poland, Portugal and Spain: United States: Hong Kong, Indonesia, Philippines, Malaysia, Thailand, UAE: The data subject also has the right to lodge a complaint with the local supervisory authority. ”


This policy framework falls within the scope and responsibilities of the Risk Committee reporting to the Cartrack Board of Directors. Compliance is verified by internal audits that report independently to the Board