EN 
ZH Data protection policy
Preface
Personal data plays an increasingly important role in our economy, society and daily life. New and innovative technologies are generating large amounts of personal data, and modern communication networks and processing systems enable organizations to collect, analyze, use, share and store data on a global scale.
It is against this background 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 personal data it collects in accordance with regulatory requirements in the jurisdictions in which it operates.
Executive management continually assesses the need to develop and implement or modify further policies, procedures and terms and conditions, including those related to data protection; consent policies and forms; data access; security breaches and employee privacy requirements .
Purpose
This policy governs the collection, use and disclosure of personal data provided to Cartrack. It guides how we collect, store and process the personal data of data subjects, customers and other stakeholders in accordance with relevant data protection legislation.
application
This policy applies to all legal entities within the Cartrack Group, including all employees, as well as third parties that provide services to the Group, and covers personal data collected and managed by the Cartrack Group.
What is personal data
"Personal Data" means any information or piece of information relating to an individual that can identify that individual directly (e.g. by name) or indirectly (e.g. by pseudonymous data). Thus, Personal Data includes email/home address, username, profile Content such as images, user-generated content, financial information, and geolocation.
Principles for collecting and processing personal data
1. Collection/Processing
Cartrack collects personal data only where such processing operations are necessary for compliance with applicable legal obligations, or where such processing operations are required for the performance of a contract or pre-contractual procedures.
Cartrack may also process information where it has a legitimate interest, provided that in each case our interests are consistent with applicable law and the rights of the data subject.
When there are no other lawful conditions for processing supporting the data processing operations, Cartrack will only process personal information with the data subject's consent to the processing of said personal data for specific, explicit and legitimate purposes.
2.Purpose
Cartrack will only disclose or use personal data to fulfill 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 its policies and practices for processing personal data public.
5.Safety
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 and drop off
Cartrack may transfer personal data outside the EU for processing by some of its service providers, companies associated with and/or part of the Cartrack Group. In this case, Cartrack ensures that such transfers are carried out in accordance with current legislation and guarantees adequate protection of personal data in accordance with the adopted standard data protection clauses in accordance with Article 46 of the EU General Data Protection Regulation ("GDPR").
Under no circumstances will Cartrack transfer personal data outside of the above conditions or sell personal data to third parties.
7.Reserved
Cartrack will retain personal data for the purposes for which it was collected. In some cases, data retention may be longer, particularly where applicable law requires this.
8.Access
Data subjects may request a copy of their personal data from Cartrack and, if necessary, instruct Cartrack to make changes to correct the data or permanently delete their personal data in accordance with local regulations.
Data subject rights
Withdrawing consent or choosing to delete certain types of personal data may prevent Cartrack from providing certain services to the data subject, or from responding to inquiries as a potential employee or supplier. To better protect personal data, Cartrack takes steps to verify the identity of the data subject before granting access or making changes to personal data.
| right | explain |
|---|---|
| information | Data subjects have the right to receive clear, transparent and understandable information about how we use personal data and what their rights are. |
| right to use | The data subject has the right to access and obtain a copy of any personal data we hold about an individual (subject to certain restrictions). A reasonable fee may be charged for providing such access, but only as permitted by law |
| Rectify | The data subject has the right to have the personal data corrected if they are incorrect or out of date and/or completed if incomplete. |
| forgotten | The data subject has the right to delete or delete personal data; to retain personal data based on legal or legitimate reasons |
| direct selling | Data subjects may unsubscribe or opt-out of direct marketing communications at any time |
| Withdraw consent | The data subject may withdraw his or her consent to our processing of personal data where such processing is based on consent. In the event of withdrawal of consent, the lawfulness of the processing before the withdrawal will not be affected |
| Objection handling | The data subject may object to the processing of personal data when the processing is based on the legitimate interests pursued by the data controller, for example: Improve our products and services Enhance our communication with data subjects Properly manage our website Risk Management |
| Protect legitimate rights and interests | |
| complaint | Data subjects have the right to lodge a complaint about our data protection and privacy practices by contacting the relevant data protection authority |
| Data portability | The data subject has the right to have personal data moved, copied or transferred from our database to another database. This only applies to personal data provided by the data subject, where the processing is based on contract or explicit consent and where the processing is carried out by automated means |
| limit | In the case of GDPR restrictions, the data subject can restrict the processing of personal data so that it can be stored, but not further used or processed, for example: Inaccurate data challenged by a data subject must be restricted until verified and corrected The processing is unlawful but the data subject objects to its erasure Cartrack no longer needs the data of the data subject, but the data subject requests their storage 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 who have 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: dataprotection@cartrack.com Poland, Portugal and Spain: dpo@cartrack.com United States: dataprotection@cartrack.com Hong Kong, Indonesia, Philippines, Malaysia, Thailand, UAE: dataprotection@cartrack.com Data subjects also have the right to lodge a complaint with their local supervisory authority.”
Responsibilities
The policy framework falls within the scope and responsibilities of the Risk Committee reporting to the Cartrack Board of Directors. Compliance is verified by internal audit, which reports independently to the Board of Directors