Effective Date: 9 July 2025
1. Introduction
GW Trailers (Pty) Ltd (“we”, “us”, “our”, or “the Company”) is committed to protecting your privacy and personal information in accordance with the Protection of Personal Information Act, 2013 (Act No. 4 of 2013) (“POPIA”) and other applicable South African laws.
This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you:
- Visit our website at https://gwtrailers.co.za (“Website”)
- Use our trailer rental services
- Complete our Know Your Customer (KYC) application
- Interact with us in any other capacity
By using our services or providing us with your personal information, you acknowledge that you have read, understood, and agree to this Privacy Policy.
2. Responsible Party Details
Company: GW Trailers (Pty) Ltd
Registration Number: [Company Registration Number]
Website: https://gwtrailers.co.za
Physical Address: [Complete Physical Address]
Postal Address: [Complete Postal Address]
Information Officer: Gustav Bohme
Email: gwtrailers01@gmail.com
Telephone: +27 82 787 0123
3. Personal Information We Collect
3.1 Information Collected for Rental Services (KYC Process)
When you apply for trailer rental services, we collect the following personal information:
Personal Identification Information:
- Full name and surname
- South African ID number
- Date of birth
- Nationality
- Selfie photograph for identity verification
Contact Information:
- Primary mobile number
- Alternative contact number
- Email address
- Residential address
- Postal address (if different)
Documentation:
- Copy of valid South African ID document
- Copy of valid driver’s license
- Proof of residence (not older than 3 months)
- Bank statement or proof of income
Vehicle Information:
- Vehicle make and model
- Vehicle registration number
- Vehicle owner details
- Insurance information
Next of Kin Information:
- Full names of two next of kin
- Relationship to you
- Contact numbers
- ID numbers
- Addresses
Employment Information:
- Employer name and address
- Employment position
- Contact person and number
- Length of employment
- Salary information
3.2 Website Usage Information
Automatically Collected Information:
- IP address
- Browser type and version
- Device information
- Pages visited and time spent
- Referral source
- Geographic location (general)
Cookies and Tracking Technologies:
- Essential cookies for website functionality
- Performance cookies for website analytics
- Preference cookies for user settings
Comments and Communications:
- Information provided in website comments
- Email communications with us
- Customer service interactions
4. Lawful Basis for Processing
We process your personal information based on the following lawful grounds under POPIA:
4.1 Consent (Section 11)
- Marketing communications (where you have opted in)
- Non-essential cookies and tracking
- Promotional materials and updates
4.2 Contractual Necessity (Section 11(1)(b))
- Processing rental applications
- Managing rental agreements
- Providing customer service
- Processing payments
4.3 Legal Compliance (Section 11(1)(c))
- Compliance with financial legislation
- Tax reporting requirements
- Regulatory reporting
- Law enforcement requests
4.4 Legitimate Interests (Section 11(1)(f))
- Fraud prevention and security
- Risk assessment
- Business administration
- Website security and maintenance
5. How We Use Your Personal Information
5.1 Primary Purposes
Service Delivery:
- Process and evaluate rental applications
- Verify your identity and creditworthiness
- Execute rental agreements
- Manage bookings and reservations
- Provide customer support
- Process payments and manage accounts
Security and Risk Management:
- Prevent fraud and unauthorized access
- Conduct security checks
- Protect our assets and property
- Ensure compliance with rental terms
Legal and Regulatory Compliance:
- Maintain records as required by law
- Respond to legal requests
- Comply with tax and financial regulations
- Report to relevant authorities when required
5.2 Secondary Purposes
Business Operations:
- Improve our services and website
- Conduct market research and analysis
- Develop new products and services
- Maintain business records
Communications:
- Send transactional communications
- Provide service updates
- Send marketing materials (with consent)
- Respond to inquiries
6. Information Sharing and Disclosure
6.1 Third-Party Service Providers
We may share your personal information with:
Identity Verification Services:
- Credit bureaus and verification agencies
- Identity verification service providers
- Fraud prevention services
Business Service Providers:
- IT service providers and cloud hosting
- Payment processing companies
- Legal and professional advisors
- Insurance companies
- Debt collection agencies (if applicable)
Legal Requirements:
- South African Police Service
- Court orders and legal proceedings
- Regulatory authorities
- Tax authorities (SARS)
6.2 Data Sharing Safeguards
All third-party service providers are:
- Contractually bound to protect your information
- Required to use information only for specified purposes
- Subject to appropriate security measures
- Located in jurisdictions with adequate data protection laws
7. International Data Transfers
Some of our service providers may be located outside South Africa. When we transfer your personal information internationally, we ensure:
- The recipient country has adequate data protection laws, or
- Appropriate safeguards are in place through contractual arrangements
- The transfer is necessary for service delivery or legal compliance
Current international transfers may include:
- Cloud hosting services
- Email and communication platforms
- Analytics and website services
8. Data Security Measures
We implement comprehensive security measures including:
Technical Safeguards:
- Encryption of data in transit and at rest
- Secure servers and firewalls
- Regular security updates and patches
- Access controls and authentication
- Secure backup procedures
Organizational Measures:
- Staff training on data protection
- Regular security audits and assessments
- Incident response procedures
- Confidentiality agreements for employees
- Restricted access on a need-to-know basis
Physical Security:
- Secure facilities and offices
- Locked filing cabinets for physical documents
- Controlled access to premises
- CCTV monitoring where appropriate
9. Data Retention Periods
We retain your personal information for the following periods:
KYC and Rental Information:
- Duration of rental agreement plus 7 years for legal and tax compliance
- Identity documents: 5 years after termination of business relationship
Financial Records:
- 5 years as required by tax legislation
- Payment information: 5 years after final transaction
Website Data:
- Analytics data: 26 months
- Cookie data: As specified in cookie settings
- Comments: Indefinitely unless requested for deletion
Communications:
- Email correspondence: 5 years
- Customer service records: 3 years
10. Your Rights Under POPIA
10.1 Right of Access (Section 23)
You have the right to request confirmation of whether we process your personal information and access to such information.
10.2 Right to Rectification (Section 24)
You may request correction of inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or unlawfully obtained personal information.
10.3 Right to Erasure (Section 24)
You may request deletion of your personal information where:
- It is no longer necessary for the original purpose
- You withdraw consent (where applicable)
- The processing was unlawful
- Subject to legal retention requirements
10.4 Right to Object (Section 11(3))
You may object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation.
10.5 Right to Data Portability
You may request your personal information in a structured, commonly used format for transfer to another organization.
10.6 Right to Restrict Processing
You may request restriction of processing in certain circumstances, such as when accuracy is contested.
10.7 Right to Complaint
You have the right to lodge a complaint with the Information Regulator of South Africa:
Information Regulator South Africa
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017
Email: inforeg@justice.gov.za
Telephone: +27 10 023 5200
11. Exercising Your Rights
To exercise any of your rights, please contact our Information Officer with:
- Clear identification of the right you wish to exercise
- Sufficient information to locate your personal information
- Proof of identity
- Specific details of your request
We will respond within 30 days of receiving a valid request. Some requests may be subject to administrative fees as prescribed by law.
12. Cookies and Website Technologies
12.1 Essential Cookies
Required for website functionality, including:
- Session management
- Security features
- Basic website operations
12.2 Performance Cookies
Used to analyze website performance and user experience:
- Google Analytics (anonymized)
- Website optimization tools
12.3 Managing Cookies
You can control cookies through your browser settings. Disabling certain cookies may affect website functionality.
13. Marketing Communications
13.1 Consent-Based Marketing
We will only send marketing communications with your explicit consent. You can:
- Opt-out at any time using unsubscribe links
- Update your preferences by contacting us
- Withdraw consent without affecting existing services
13.2 Transactional Communications
We will send necessary service-related communications regardless of marketing preferences.
14. Children’s Privacy
We do not knowingly collect personal information from children under 18 years without proper parental consent. If you believe we have collected information from a child, please contact us immediately.
15. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect:
- Changes in our business practices
- Updates to applicable laws
- Improvements to our services
We will notify you of material changes by:
- Email notification to registered users
- Prominent notice on our website
- Updating the effective date
16. Data Breach Notification
In the event of a data breach that poses a risk to your rights and freedoms, we will:
- Notify the Information Regulator within 72 hours
- Inform affected individuals without undue delay
- Implement measures to address the breach
- Provide regular updates on our response
17. Automated Decision-Making
We may use automated processes for:
- Credit and risk assessment
- Fraud detection
- Application processing
You have the right to request human review of automated decisions that significantly affect you.
18. Contact Information
For any privacy-related queries, requests, or complaints:
Information Officer: Gustav Bohme
Email: gwtrailers01@gmail.com
Telephone: +27 82 787 0123
Address: [Complete Physical Address]
Business Hours: Monday to Friday, 08:00 – 17:00
Response Time: We aim to respond within 48 hours
19. Governing Law
This Privacy Policy is governed by the laws of South Africa, including POPIA and other applicable data protection legislation.
Last Updated: 9 July 2025
Version: 2.0
This Privacy Policy should be read in conjunction with our Terms of Service and Rental Agreement.