EZ Shuttle is committed to protecting your personal data and respecting your privacy. This privacy policy will explain how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your rights in respect of privacy, as well as how the law protects you.
1. Important information
Purpose of our privacy policy
Our privacy policy provides you with information on how EZ Shuttle collects and processes your personal data through your use of our website, including data that you provide via our website when you make request a quote, make a booking, sign up to our email list or any other free information or competition on our website, or submit a question or comment to EZ Shuttle via the website.
Our website is not intended for children, and we do not knowingly collect data relating to children.
For your information and safety, it is important that you read our privacy policy, as well as any other privacy policy or fair processing policy that we may issue on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of why and how we store and use your data. This privacy policy complements our other privacy policies and notices and does not override them.
Changes to our privacy policy and your obligation to inform us of changes
We continually review our privacy policy.
It is important that the personal data we hold about you is correct and current. Please inform us at [email protected] if your personal data changes during your relationship with us.
Third-party links
The EZ Shuttle website may include links to third-party websites, applications and plug-ins. By clicking on those links or allowing those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies and encourage you to read the privacy policy of every website you visit.
2. Data we collect about you
Personal data or information implies any information about an individual that makes them identifiable. It does not include anonymous data (where the identity has been removed).
EZ Shuttle may collect, store, use and transfer different kinds of Personal Data about you which we have grouped together as follows:
- Identity Data including first name, last name, gender, date of birth, marital status, and title.
- Contact Data includes telephone numbers, email addresses, billing addresses, and service delivery addresses.
- Transaction Data includes details about services you have purchased from us, and payments to and from you.
- Financial Data includes bank account and payment card details.
- Technical Data includes IP (internet protocol) addresses, time zone and location settings, your login data, browser type and version, browser plug-in types and versions, operating system and platform, and other technology on the devices that you use to access our website.
- Usage Data includes information about how you use our website and services.
- Profile Data includes your username and password, purchases or bookings made by you, your preferences and interests, and your feedback, and survey responses.
- Marketing and Communications Data includes your preferences for receiving communication marketing from us and our third parties.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data by law, as it data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users that access specific pages or features of our website. In the event that we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we regard and handle the combined data as Personal Data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you, such as your race, ethnicity, religion, sexual orientation, political opinions, philosophical beliefs, sex life, trade union membership, information about your health, and bio-metric and genetic data, criminal convictions or offences.
Failing to provide your personal data
Where we need to collect personal data, either by law or under the terms of a contract between you and EZ Shuttle, and you fail to provide that data when requested, we may not be able to execute the contract we have or are trying to enter into with you (for example, providing you with adequate services). In this case, we may have to a service agreement you have with us, but we will notify you if this is the case.
3. How your personal is data collected
We use different methods to collect data from and about you including, but not limited to:
- Direct interactions where you may provide your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data that you provide when you:
- Sign up for and/or participate in our marketing material, competitions and promotions, surveys and free offers.
- Apply for and/or purchase our services.
- Create, request or consent to the creation of an account or profile on our website.
- Subscribe to our service or publications.
- Request that marketing to be sent directly to you, or to be included in bulk marketing communication (opt in).
- Give us feedback or contact us.
- Automated technologies or interactions means that as you interact with our website, we will automatically collect Technical Data about your browsing actions, patterns, and equipment. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details in this regard.
- Third parties or publicly available sources where we may receive personal data about you from various third parties and public sources, such as:
- Contact, transaction, and financial data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources such as the Companies & Intellectual Properties Commission in South Africa (“CIPC”).
- Analytics providers, such as Google.
4. Use of your personal data
We will only use your personal data when/how the law permits. Most commonly, we will use your personal data in the following circumstances:
- Where we need to comply with a legal obligation.
- To perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Generally, we do not rely on consent as a legal basis for processing your personal data. We will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for use of your personal data
We have set out below a description of all the ways in which we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where fitting.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new client | (a) Identity (b) Contact | Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, promotion, competition, free offer or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with External Third Parties (as defined in the Glossary) for the purposes set out in the table Purposes for which we will use your personal data above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
7. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8. Glossary
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties means:
- Service providers based in South Africa and the United States of America who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in South Africa and/or the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- The South African Revenue Service (SARS), regulators and other authorities based in South Africa or elsewhere.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
9. Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways: [email protected]
EZ Shuttle (Pty) Ltd
184 Bronkhorst St, Nieuw Muckleneuk, Pretoria, 0181