Introduction

We respect your privacy and take the protection of personal information/information very seriously. The purpose of this policy is to describe the way that we collect, store, use, and protect your personal information collected as a result of you using the telematics device and / or the app (collectively ‘the telematics offering’). When we refer to ‘personal information’, we refer to personal information as defined in the Protection of Personal Information Act, 2013.

Application

This policy applies to you if you are:

• Downloading and using the dotsure.co.za Smart Driver App from which ever platform is compatible with your smartphone.
• Using the Smart Driver Tag to be attached to your vehicle.

What is and what is not Personal information | information

1. Personal information | information includes:

   • certain information that we collect automatically when you visit our website;
   • certain information collected on registration (see below);
   • certain information collected on submission, whether automatically or not; and
   • optional information that you provide to us voluntarily (see below);

2. Personal information | information excludes:

   • information that does not identify a specific person;
   • non-personal statistical information collected and compiled; and
   • information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board 3.2.1. Common examples

3. Personal information | information

   • We may also collect sensitive personal information | information, like geographical location.

Who collects your data and for what purpose

The telematics offering is provided by Dotsure Limited (Dotsure) of 127 A York Street, George, Western Cape, South Africa and Swiss Reinsurance Company Ltd., Mythenquai 60, 8002 Zurich, Switzerland (Swiss Re).

Dotsure will act as the responsible party and Swiss Re will act as an operator, as defined in the Protection of Personal Information Act, 2013.

Swiss Re does not provide any insurance benefits.

The purpose of collecting the data is described in more detail below as well as in your policy wording. At the core, the data is collected to obtain data on the driving behaviour of the drivers of your motor vehicle. The data will be used to assess on claims and improve the algorithms and scoring mechanisms of both the responsible party and the operator.

Note that this device and application is not to be used by you to monitor the geographic location, or the driving behaviour of other people, or any purpose not intended other than within this privacy policy or your insurance policy or any other purpose that may be agreed to between you and us from time to time.

You indemnify both the operator and the responsible party from any liability it may attract as a result of your use of the device and application, other than for its intended purpose.

Acceptance

By attaching the device to your vehicle and / or downloading and activating the app on your smartphone, you accept all the terms and conditions of this policy.

You must ensure that you only send us your own personal information | information as a Dotsure Policyholder.

Changes, messages and updates

We may change the terms of this policy at any time. We will notify you of any changes to this policy through any electronic means that is accessible to us. If you do not agree with the changes, then you must inform us that you do not agree and we will provide you with further instructions. This may, however, result in Dotsure cancelling your insurance policy.

By your continued use of the telematics solution after you have been notified of a change in this policy, you consent to such a change and regard it as binding.

In addition, we may send messages and updates in the same manner, which may include our marketing material, or the marketing material of some of our strategic partners.

Collection

We collect the following data

1. On registration

   Once you have registered on the app, the following data will be pushed to us:

   This personal information | information may include:

   • your name and surname;
   • your email address;
   • your telephone number;
   • your company name, company registration number, and VAT number;
   • your postal address or street address;
   • your vehicle registration data; and
   • your username.

2. During use

   When you use the telematics solution, the following data will be pushed to us:

   1. Technical data

      Once installed on your smartphone, successfully activated and operating, the Coloride logs technical data about the smartphone (make, model, IMEI, system version, battery and charge status).

   2. Driving data

      Once the app has been installed on your smartphone and successfully activated and is operating, it logs the following driving data at regular intervals:

      • GPS time;
      • GPS position;
      • Current speed to GPS positions;
      • GPS signal quality;
      • Force of driving manoeuvres such as accelerating, braking or taking bends (G-force);
      • Time trip started (first acceleration recorded in the smartphone by the G-sensor);
      • Time trip ended (motionless for more than a preset interval or stage);
      • Use of smartphone during the trip.

   3. Data collection (app permissions)

      • Location and speed (precise real time location information through GPS coordinates)
      • GPS accuracy
      • Accelerometer data (three-axis accelerations)
      • Motion & fitness data (activities)

How we use this data

We use the data for the following purposes:

• to analyse your driving behaviour, which may be used for analytics purposes and to determine a potential correlation between driving data and rating factors and for comparison against other sets of data;
• to adjudicate on claims;
• to assist in the recovery of vehicles, if possible;

Note that neither Dotsure nor Swiss Re offer vehicle recovery services.

What information will you get back

Dotsure may, in its sole discretion, allow you access to or provide any one of the following, or any combination thereof:

• information about your driving profile through some visual statistics about speed, acceleration, braking, cornering and jerking.
• A list of the trips that have been recorded by the app and some details for each trip (route, start time, end time, duration, distance and visual statistics about speed, acceleration, breaking, cornering and jerking).

Disclosure

Dotsure may, in its sole discretion, allow you access to or provide any one of the following, or any combination thereof:

1. Sharing

   • other divisions or companies within the group of companies to which we belong to provide joint content and service,
   • an affiliate, in which case we will seek to require the affiliates to honour this privacy policy;
   • emergency services, if we reasonably believe that you require same;
   • credit bureaus to report account information, as permitted by law;
   • banking partners as required by credit 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); and
   • other third parties who provide us with relevant services where appropriate.

2. Regulators

   We may disclose your personal information | information where required by law.

3. No selling

   We will not sell personal information. No personal information | information will be disclosed to anyone except as provided in this privacy policy.

4. Employees

   We may need to disclose personal information | information to our employees that require the personal information | information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel. Any of our employees or personnel that handle your personal information | information will have signed non-disclosure and confidentiality agreements.

Indemnity

We cannot accept any liability whatsoever for unauthorised or unlawful disclosure of your personal information | information by third parties who are not subject to our control.

By using the telematics solution, you will indemnify Dotsure Limited and Swiss Re against any and all damage, however that damage may occur and whether such damage is to your device, vehicle, person or any such damage which you may become liable for to a third party as a result of using the telematics solution.

The indemnity will apply insofar as allowed by law.

Security

We take the security of personal information | information very seriously and always do our best to comply with applicable data protection laws. We will implement and maintain appropriate technical and organisational measures to protect the security and confidentiality of the personal information | information. We host a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. All personal information | information is securely stored in our customer database and is not retained for longer than is absolutely necessary. We authorize access to personal information | information only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.

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 defined in this policy. From time to time we may request you to update your personal information on the website. You are able to review or update any personal information that we hold on you by accessing your account online or emailing 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. Throughout your interaction with us you retain the right to rectify personal information that is incorrect or inaccurate. This does not apply if we process your personal information in our capacity as a Processor | Operator on behalf of you or the Administrator when you or the Administrator act as the Data Controller | Responsible Party.

Transfer to another country

We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent.

Updating or removing

You may choose to correct or update the personal information you have submitted to us by contacting us at smartsupport@dotsure.co.za.

You are entitled to a right to be forgotten. We will delete any personal information that you don’t want us to have. You may request such a request to be processed through the email stipulated above.

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.

Enquiries

If you have any questions or concerns arising from this Privacy Policy, please contact us on informationofficer@dotsure.co.za.