LEGAL INFORMATION
PRIVACY POLICY
PRIVACY POLICY
Privacy Policy
1. Interpretation
For the purposes of this Policy , the following definitions apply –
1.1 “Brands” means Alfa, Citroën, Fiat, Jeep, LeapMotor, Opel, Peugeot;
1.2 "Consent" means an informed, unconditional, specific and voluntary expression of will in terms of which permission is given for the Processing of Personal Information;
1.3 "Contractual Performance" – means we must Process your Personal Information in order to be able to provide you with one of our products or services;
1.4 "Data Subject" means the natural or juristic person to whom Personal Information relates;
1.5 “Dealers” means a juristic entity duly appointed as a Stellantis SA authorised dealer;
1.6 "Device(s)" includes printers, facsimile machines, computers, servers, laptops, notebooks, smartphones, tablet computers, memory sticks, any other external storage devices, and for the avoidance of any doubt, also includes personal Devices where those Devices are used for work related purposes and/or contain or have contained any information which belongs to Stellantis SA;
1.7 "Employee" means any such person as defined in the Labour Relations Act 66 of 1995, under the employ of Stellantis SA, and any other such person who may conduct work for or on behalf of Stellantis SA on a once off or ongoing basis, as the case may be;
1.8 "Information Officer" means the person/s designated by Stellantis SA to direct compliance with POPI within Stellantis SA;
1.9 "Information Regulator" means the body established in terms of section 39 of POPI;
1.10 "IS/IT Systems" means collectively and individually –
1.10.1 Stellantis SA's IS/IT infrastructures, telecommunications systems and all its components; and
1.10.2 Devices as well as the applications running on and services provided via such Devices, including e-mail, voicemail, internet and intranet;
1.11 "Legal Obligation" – means we are required by law to Process your Personal Information;
1.12 "Legitimate Interests" – means where Processing is necessary for us to conduct our business, but not where our interests are overridden by your interests or rights;
1.13 "Stellantis SA" means Stellantis SA South Africa Proprietary Limited, a private company duly incorporated under the laws of South Africa with registration number 1997/014154/07 and registered office at Building #2 Midrand Business Park, 563 Old Pretoria Road, Halfway House, Midrand 1685;
1.14 "Operator" means any person who Processes Personal Information for or on behalf of Stellantis SA in terms of a contract or mandate concluded between Stellantis SA and such person;
1.15 "Personal Information" means any information which may be used to identify you or is held in association with information that can be used to identify you including information such as name and surname, date of birth, contact details, physical address, email address or phone number amongst others and may include Special Personal Information;
1.16 "POPI" means the Protection of Personal Information Act, 4 of 2013, as amended, and all regulations promulgated thereunder;
1.17 "Process/Processing" means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information, and includes the meaning given to it in the POPI;
1.18 “South Africa” means the Republic of South Africa.
1.19 “Special Personal Information” relates to Personal Information concerning your religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health, sexual orientation or biometric information; or any criminal investigation or ongoing legal proceedings against you.
2. Introduction
2.1 Stellantis South Africa Proprietary Limited with Company Registration Number 1997/014154/07 ("Stellantis SA/we/us/our") includes many different Brands namely, Alfa, Citroën, Fiat, Jeep, LeapMotor, Opel, Peugeot.
2.2 This Privacy Policy forms part of our continued commitment to protect individual and corporate Personal Information and sets out our Processing activities to ensure compliance with the applicable laws and regulations when Processing your Personal Information.
2.3 We will only Process your Personal Information in accordance with this Policy and the Applicable Legislation.
2.4 We recognise that everyone has the right to privacy which includes protection against the unlawful collection, retention, dissemination and use of Personal Information. Consequently, this Policy sets out to achieve the following –
2.4.1 establish the principles that govern the lawful processing of Personal Information and promote ethical standards including, but not limited to, protecting confidential information, guarding against security threats and maintaining best practices;
2.4.2 provide a description of how we will collect, Process and store your Personal Information as well as your rights in relation thereto;
2.4.3 protect the Personal Information rights of Stellantis SA, our Employees, customers, and partners and/or affiliates;
2.4.4 clarify the practices and procedures that will enable us to monitor and audit compliance with the Policy and set out the consequences of non-compliance; and
2.4.5 minimise the inherent risks of non-compliance, including but not limited to reputational damage and regulatory sanctions.
3. Application of Policy
This Policy applies to –
3.1 Stellantis SA and all our authorised Dealers across South Africa;
3.2 all of our Employees and/or volunteers (which includes potential employees and/or volunteers) where applicable;
3.3 all of our customers (which includes potential customers);
3.4 all of our suppliers and service providers (which includes potential suppliers and service providers); and
3.5 any other natural or juristic person who interacts with us through our Dealers, over the phone, online, via email, mobile applications, social media or otherwise by using any of our websites.
4. Stellantis SA and Your Personal Information
4.1 Stellantis SA will be responsible for Processing your Personal Information.
4.2 Where appropriate and permissible in law, we will share your Personal Information with our global head office, Stellantis Global, which is situated in France.
4.3 We also use a number of third parties and affiliates to process your Personal Information on our behalf (“Operators”) and where we do so, we will ensure compliance with the law. See paragraph 7 for further detail.
4.4 Stellantis SA will mainly Process your Personal Information in the following respects –
4.5 Cookie Policy
4.5.1 Stellantis SA makes use of cookies on our websites for identification, analysis and advertising purposes. By using the websites, you consent to the storing and accessing of cookies on your device. To find out more about the cookies we use and how to set your preferences, please see our Cookie Policy
5. Security Safeguards
5.1 We limit physical access to our buildings and user access to our systems to only those that we believe are entitled to be there.
5.2 We use technology controls for our IS/IT Systems, such as firewalls, user verification, strong data encryption, and separation of roles, systems and data.
5.3 We utilise industry “good practice” standards to support the maintenance of a robust information security management system.
5.4 We further enforce a “need to know” policy, for access to any data or systems.
6. Data Retention
6.1 We will not retain your Personal Information longer than the period for which it was originally needed, unless we are required by law to do so, or you Consent to us retaining such information for a longer period.
6.2 The nature and lifespan of the services or products purchased from us will determine the extent and duration of the Legitimate Interest that we have to Process your Personal Information.
6.3 We will, on your request, promptly return or destroy any and all of your Personal Information in our possession or control, save for that which we are legally obliged to retain.
7. Sharing of Information
7.1 We may share your personal information with other entities within our international group of companies, with companies providing a service to us or Our Group including agents and subcontractors, or with our dealers. However, such entities and persons will only use your personal information for the purposes set out above. Please note that, other than the third-parties listed above, we will not disclose your personal information to any other third-party whatsoever without your consent and we will never sell your personal information.
7.2 We will not intentionally disclose, for commercial gain or otherwise, your Personal Information other than as set out in this Privacy Policy or with your permission.
7.3 Once information has been shared with another company, that company is now the Responsible Party of that information and as such information falls under their Privacy Policy and practices.
7.4 Your information may be shared under the following circumstances:
7.4.1 to our agents, advisers, service providers and suppliers which have agreed to be bound by this Privacy Policy;
7.4.2 to our employees, suppliers, service providers and agents if and to the extent that they need to know that information in order to process it for us and/or to provide services for or to us, such as hosting, development and administration, technical support and other support services relating to the Website. For protection, we will authorise any information processing done by a third-party on our behalf, amongst other things by entering into written agreements with those third parties governing our relationship with them and containing confidentiality and non-disclosure provisions;
7.4.3 to our affiliates, which includes our holding companies and subsidiaries;
7.4.4 in order to enforce or apply any contract between you and us;
7.4.5 in order to protect our rights, property or safety or that of our customers, employees, contractors, suppliers, service providers, agents and any other third-party;
7.4.6 to mitigate any actual or reasonably perceived risk to us, our customers, employees, contractors, agents or any other third-party;
7.4.7 to governmental agencies, exchanges and other regulatory or self-regulatory bodies if we are required to do so by law or if we reasonably believe that such action is necessary to:
7.4.8 comply with the law or with any legal process;
7.4.9 protect and defend the rights, property or safety of us, or our customers, employees, contractors, suppliers, service providers, agents or any third-party;
7.4.10 detect, prevent, or deal with actual or alleged fraud, security or technical issues or the abuse, misuse or unauthorised use of the Website and/or contravention of this Privacy Policy;
7.4.11 protect the rights, property or safety of members of the public (if you provide false or deceptive information about yourself or misrepresent yourself as being someone else, we may proactively disclose such information to the appropriate regulatory bodies and/or commercial entities).
7.4.12 You hereby provide consent to Stellantis SA to share, transfer and process your Personal Information as follows or as otherwise described in this Policy with Secondary or Third Party Independent Service Providers for further consideration of the intended vehicle finance in relation to disqualified leads;
7.4.13 You hereby provide consent to Stellantis SA to share, transfer and process your Personal Information as follows or as otherwise described in this Policy with Secondary or Third Party Independent Service Providers and for those Secondary or Third Party Independent Service Providers to contact you via the appropriate channels in relation to the intended vehicle Finance.
8. Cross Border Information Transfers
We may share and/or transfer and/or store your information with our International Group for purposes of collection. Where Stellantis SA transfers Personal Information about you to a company outside of South Africa, we will ensure that such jurisdictions have adequate levels of protection with regards to their data protection legislation.
9. Your Rights
9.1 As the Data Subject, you have a number of rights under law which, in certain circumstances, you may exercise in relation to the Personal Information we Process about you.
9.2 These rights include –
9.2.1 the right to access a copy of the Personal Information that we have about you;
9.2.2 the right to correction of inaccurate Personal Information we hold about you;
9.2.3 the right to restrict our use of your Personal Information;
9.2.4 the right to request that your Personal Information be deleted; and
9.2.5 the right to object to our use of your Personal Information.
9.3 Further information on these rights can be found at the Information Regulator's website at https://inforegulator.org.za/.
9.4 Where we rely on Consent as the legal basis on which we Process your Personal Information, you may also withdraw that Consent at any time.
9.5 Any formal and/or legal requests relating to your Personal Information as referenced throughout this document can be formally made as set out in our PAIA Manual.
10. Consent
10.1 If you show interest in a vehicle, book a test drive one of our vehicles, make enquiries through any web forms, engage on our social media or digital platforms and/or if you select to purchase our vehicles, we need to process your application in order to ensure that you can afford the vehicle asset finance.
10.2 By booking a test drive or doing a finance application either directly through our Dealers or making enquiries through our Stellantis Finance Website you agree to:
10.2.1 doing a full credit assessment on you;
10.2.2 accessing your credit profile by making enquiries about your credit history with any credit bureau such as TransUnion or other credit bureaus for the credit assessment and in the event that your loan is successful, for on-going account maintenance purposes, setting limits, development of credit tools/models and assessments for insurance purposes;
10.2.3 using the above information for scorecard and product development;
10.2.4 reporting the fact that we have concluded any credit agreement with you to the National Loans Register in compliance with our duties under the National Credit Act;
10.2.5 using your personal information to communicate with you on an on-going basis related to our services and products.
10.3 You declare that the information you have provided to us is true and correct in all material respects.
10.4 If there is any error, omission or dispute with your credit bureau information, you need to contact the credit bureaus directly to rectify the error, omission or dispute.
10.5 You further acknowledge and consent to be bound by the applicable finance provider’s own terms and conditions.
11. Who to Contact in Case of Concerns
11.1 Should you wish to raise any questions, concerns, possible violations, and reportable conditions, please contact our Information Officer at customercareza@stellantis.com
12. General
12.1 If any provision of this Privacy Policy is judged to be illegal, void or unenforceable due to applicable law or by order of a court of a competent jurisdiction the offending provision shall be deemed severable from the remaining terms of this policy and deleted. The unaffected portions of this Policy will continue to be in full force and effect and the remainder of the provisions will not be prejudiced.
12.2 If we or you do not enforce any right in terms of this Policy, it will not constitute a waiver of that right.
15. Contact Us
If you have any questions about this Policy , our treatment of your Personal Information or you wish to exercise any of your rights please address an email to –