Privacy Policy
This privacy notice explains the privacy practices followed at Comtrack (Pty) Ltd , hereinafter referred to as “COMTRACK”, “We”, “Our” or “The organization”. This privacy notice is applicable to information collected via this web site and other sources – both online and offline. A brief overview of the information contained in this privacy notice is as follows:
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What personally identifiable information is collected from you through the web site and other sources
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How personal data is used and with whom it may be shared.
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What are the legal rights/privacy rights available to you regarding the use of your data by COMTRACK
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How to exercise your Privacy rights with respect to your personal data processed by COMTRACK
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How you can correct any inaccuracies in the information COMTRACK has about you
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Types of Personal data we collect, use and share
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We may collect a wide variety of personal data including but not limited to:
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Name
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Email address
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Postal Address
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Company name
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IP address
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Browser cookies
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How do we get personal information?
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We collect Personal Data about you when you provide such Personal Data directly to COMTRACK, when third-party businesses such as our partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically processed in connection with your use of services of a customer of COMTRACK.
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Information collected directly from you:
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COMTRACK receives Personal Data directly from you when you provide us with such data, including but not limited to the list mentioned under section “Types of personal data we collect, use, share”
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Why do we store personal information?
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We collect and process the above categories of Personal Data due to contractual necessities so that we can provide the Services to. For example, we cannot identify you as an individual and provide your genetic data to your healthcare provider, if you do not provide us with your first, last name and email address. When we process Personal Data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services provided by COMTRACK.
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We may also collect user content from you when you provide it to us. For example, COMTRACK website allows you to provide us with your personal details like name and designation and other contact details like email address, phone number so that we can reach out to you. By sharing this user content through a website, you are choosing to disclose any Personal Data included in such content to us, and we do not have control over your decision. We process user content, including any Personal Data included in any such user content, on the basis of our legitimate business interest in providing you with the Services.
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We also use the Personal Data we collect directly from you to operate, improve, understand and personalize our Services based on our legitimate business interest in operating our Services in a way that benefits us and our users. For example, we use the Personal Data to:
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– Create and manage user profiles for COMTRACK service
– Communicate with you about the Services
– Contact you about Service announcements, updates or offers
– Provide support and assistance for the Services
– Personalize website content and communications based on your preferences
– Meet contract or legal obligations
– Respond to user inquiries
– Fulfill user requests
– Comply with our legal or contractual obligations
– Resolve disputes
– Protect against or deter fraudulent, illegal or harmful actions
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Information we receive from third party sources: Some third parties provide us with Personal Data about you, such as the following:
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– Account information for third party services: If you interact with a third party service which use COMTRACK Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect), or if you share content from our Services through such third party service, the applicable third party service will send us certain Personal Data if the third party service and your account settings allow such sharing. We process this Personal Data based on our legitimate business interest of personalizing and optimizing the Services to improve user experience.
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– Information from our advertising partners: We receive information about you from some of our service providers (e.g., LinkedIn, Google, Facebook, Instagram, native ad networks) who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications. We process this Personal Data based on our legitimate business interest in providing direct marketing about our products and services.
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Information we automatically collect when you use our Services: Some Personal Data is automatically collected at our servers when you use our Services, such as the following:
– IP address
– Device identifiers
– Web browser information
– Page view statistics
– Browsing history
– Usage information
– Cookies and other tracking technologies (e.g. pixel/tags)
– Location information (e.g. GPS data, IP address, zip code )
– Log data (e.g. access times, hardware and software information)
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We process the aforementioned Personal Data based on the following legitimate business interests:
– Network security
– Personalization of web content
– Web analytics
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Whom do we share your data with?
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We share Personal Data with vendors, third party service providers who work on our behalf and provide us with services related to the. These parties include:
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– Analytics service providers (eg: G-Analytics)
– Staff augmentation and contract personnel (by the HR function)
– 3rd party service providers (eg: AWS)
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We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
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– Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
– Social media services (if you interact with COMTRACK through one of our Social Media Channels like Twitter, LinkedIn, Instagram, Facebook, etc.)
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We also share Personal Data when we believe it is necessary to:
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– Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
– Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
– Maintain the security of our products and services
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We also share Personal Data with third parties when you give us consent to do so.
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Safeguards to store personal information
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Right to be informed
Individuals, in certain jurisdictions, have a right to be informed about the collection and use of their personal data. COMTRACK provides such individuals with the information about the purposes of processing personal data, how long the personal data is supposed to be stored and whom it will be shared with. If COMTRACK obtains personal data from sources other than the individual, (to whom the personal data belongs to) we will provide such individuals with the privacy information acquired within one month of acquiring such information.
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Right of access
Individuals have the right to receive a copy of their personal data. COMTRACK allows individuals to exercise their right of access to their personal data by responding to such requests within a reasonable time period.
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Right to rectification
Individuals can request to rectify inaccurate and incorrect personal data about them. While COMTRACK strives to maintain accurate records, any inaccurate personal information can be brought to our notice to be corrected
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Right to erasure
The right to be forgotten, as it is also known as, allows individuals to request deletion of their personal information. Considering other legal obligations like contractual necessities, we respond to data erasure requests and fulfil them
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Right to restrict processing
Under certain circumstances, you may have the right to request COMTRACK to stop processing your personal data while allowing us to just store your personal data.
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Right to data portability
COMTRACK provides your personal data in a format that is suitable to be used across different systems.
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Right to object
COMTRACK honors your right to object to the processing of your personal data, provided that we do not have a compelling reason not to do so.
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Exercising your privacy rights
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Natural persons, living in certain jurisdictions with specific privacy rights, can exercise their privacy rights by writing to COMTRACK Privacy office at info@comtrack.co.za
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How to complain?
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If you have any concerns regarding our privacy practices or about exercising your Data Protection rights, or any specific grievance that needs to be addressed with respect to your privacy rights, you may complain to us here – info@comtrack.co.za