1. Introduction As it is within our scope of business to opt your security in and around our geographical  areas we operate in, we understand and ensure to uphold the importance of your personal  information and the protection thereof. Within the scope of this Privacy Policy, we describe how Pulsit Electronics (Pty) Ltd  (“Pulsit”) collects, process and use your personal information. We also indicate which third  parties will have access to your personal information and what your rights are relating to  your personal information. This policy specifically applies to all the personal information collected from you or within  the scope of any borderless digital environment during your professional interaction with  us. This in essence includes whether the interaction is in writing; orally; through media  sites and mobile applications which has a direct link to this Privacy statement; any personal  information that may be collected offline or received from any third party; throughout all  our websites and whether or not the interaction is with us on any online platform,  application or forum. 2. Personal information collected Pulsit, is subjected to the Protection of Personal Information Act, 4 of 2013 (“POPIA”), of  which the operative provisions came into effect on 1 July 2020, leaving public and private  bodies with a grace period until 1 July 2021 to be fully compliant with POPIA. In essence,  it is important to be familiarised with the definitions of the concepts used within POPIA as  well as this Policy. “Personal Information” This, as defined by POPIA, is the information relating to an identifiable, living, natural  person and where applicable, an identifiable, existing juristic person, including but not  limited to:1 (a) information relating to the race, gender, sex, pregnancy, marital status, national,  ethnic or social origin, colour, sexual orientation, age, physical or mental health,  well-being, disability, religion, conscience, belief, culture, language and birth of  the person; (b) information relating to the education or the medical, financial, criminal or  employment history of the person; (c) any identifying number, symbol, e-mail address, physical address, telephone  number, location information, online identifier or other particular assignment to  the person; (d) the biometric information of the person; (e) the personal opinions, views or preferences of the person; (f) correspondence sent by the person that is implicitly or explicitly of a private or  confidential nature or further correspondence that would reveal the contents of  the original correspondence; (g) the views or opinions of another individual about the person; and (h) the name of the person if it appears with other personal information relating to  the person or if the disclosure of the name itself would reveal information about  the person. Type of personal information collected It all depends of what manner you intend to interact with us, but the personal information  that we may collect will include, without any limitations: • Your name • E-mail address • Postal address • Telephone number (fixed of mobile) • Log-in and account information for authentication purposes and account access • Your gender;  • Vehicle information; and • Location of your tracked vehicles; Other that the above, it is also within our policy that we may also collect other information  that does not personally identify you. This information includes device and browser  information, IP addresses, website and application usage data, home language, 2 demographic information such as marketing preferences, geographic location, and  information collected through cookies and other technologies or information that has been  anonymised or aggregated. As soon as the above mentioned information is linked with  your personal information, we shall treat such linked formation as personal information. You always have the option not to provide your personal information to us when requested.  Your choice not to provide your information may affect the outcome of our services if these  information is crucial to proceed. This will definitely effect how we provide you with our  solutions, services and products, access to our Internet Service or to perform  administrative functions. In specific cases, and where applicable, we may be subjected to the General Data  Protection Regulations 2016/679 of the European Union [‘EU’] (“GDPR”). This is the  primary legislation dealing with the protection and regulation of personal information. That  in essence mean that if you are a natural person based in the EU, and who wish to make  use of our service or products, and who in the process, provide us with your personal  information, we will supplement our obligations as set out herein with additional aspects  of GDPR where applicable and appropriate some of which are referred to Section 10. 3. Purpose for the collection of data Within the scope of our services, we may collect and make use of your Personal  Information to provide you with the necessary products, services, customer support, and  to bill you for the services and products you requested. We may also make use of your  information to market our products and services which we think might be within your  interest, or to communicate with you for other purposes which are evident from the  circumstances that may occur. You will however not be required by us to provide all your personal information, and only  that as specified above. This does not prevent you to make use of our services, browse  through our website or obtain more information from what our business consist of, without  providing us with your personal information.  You must also take note that we will notify you as soon as we collect your Personal  Information. 4. How your personal information is collected3 When we collect your personal information, in the different ways as stipulated previously  and during the times that you to interact with us, we will collect your information on one  or more of the following ways: • As soon as when you access our Internet Services, or interact with us in one way  or another, or make use of our solutions, services and/or products: o We will collect your personal information as soon as you place orders for  one or more of our products and/or services; in the event where you create  an account with us, when we process your orders and payment transactions;  when we perform further administrative and business functions; by using it  for marketing our products and services; and when we provide you with  seminars and/or workshops or when you subscribe to receive our latest  newsletters or mailing list. • At times when you communicate with us o We will collect your personal information at times when we respond to your  requests and inquiries, obtaining feedback from yourself about our products,  solutions and services, or when you apply to become part of our team by  being employed with us. • Collection of data from third parties o We also make use of third parties by collecting personal information from  them which include, public databases, social media sites, business partners  with whom we offer co-branded services or engage in joint marketing  activities and third parties that provide list enhancement or similar services. • Other aspect as to when and how we collect your personal information is: o If we are required to do so because of an applicable law; and/or if it is  requested from public and government authorities (which includes a court  order, subpoena, or any other governmental regulations), within and  outside the Republic of South Africa o When enforcing our terms and conditions;4 o When it is our belief and in good faith that we need to make use of Personal  Information which is necessary to protect legal rights, the security and/or  integrity of our website, products, and/or services. o To protect your safety and the safety of others o As part of any criminal or legal investigation within the Republic or any other  country, subjected to an court order providing such evidence; or o To the extend for any extent reaspnably necessary for the development of  or to proceed with negotiations, and/or the completion of our transactions. It is also within your interest to know that when you make use of our Internet Services,  we may, and together with third parties we engage may automatically collect data,  including personal information through the use of cookies and similar technologies. For  more information hereto, please see the section “Cookies and the use thereof” below. 5. Processing your personal information When it comes to processing your personal information and within the scope and purpose  as set in this Policy, we will only process your information which may rely on one or more  of the following aspects: • Whether we have obtained your prior consent; • That the processing is necessary to carry out action for the conclusion or  performance of a contract to which you are a party; • When the process is necessary to comply with our legal or regulatory obligations • When the processing protects your legitimate interests, • When the processing is necessary for our legitimate interests or the legitimate  interests, and for the purpose of managing, operating or promoting our business,  which includes direct marketing, and transfers within the Pulsit Group of companies  of personal information for business and administrative purposes, and/or transfers  to and from a third party to whom the personal data is supplied, which does not  unduly affect your interest or fundamental rights and freedom. It is also within your best interest to know that when we process your personal data, we  always seek to maintain a balance between your privacy and our legitimate interests. For  ease of reference, we also enclose hereto a list of what may constitute as “legitimate  interests” which may include:5 • To benefit from any cost-effective services; • To be enabled to offer our products and services to our customers; • In an attempt to prevent any criminal activity, any fraudulent activity, or the misuse  of our services and/or products (which includes the security of our IT systems) or  our networks; • To sell any part of our business or its assets, or to be enabled to the acquisition of  part of or the hole of our business or its assets by a third party; and • To meet our corporate and social responsibility objectives. 6. Dealing with information of minors and special personal information It is not common or in the scope of our products and/or services to interact with minors,  and forthwith we do not direct our brand, website or any advertisement to minors. Hence,  we do not knowingly collect personal information from children under the age of 18, and  in the event where we do, we acknowledge that same information is being provided by  the minor with the prior consent of his or her parents, /legal guardian and in compliance  with POPIA. 7. The use of personal information When we make use of your personal information, we may make use of your personal  information to: • Enable you to effectively make use of, and to improve our solutions, services and  products, for an example: o To perform administrative and business functions; o Tracking and recovery of stolen vehicles; o To send administrative information to you; o To obtain any feedback from yourself about our services, products and/or  solutions which includes, without any limitations, our client satisfactory  surveys (where we will only make use of your personal information for the  main purpose of sending you a survey); o To enable us to respond to your inquiries and full your requests; o To inform you about and to provide you with more information about our  products, solutions and services;6 o To ensure that our records are updated and to keep your contact details up  to date. It is within the scope of our business to engage in these different activities to manage and  control all our contractual relationships with you, so that all parties comply with the legal  obligations, or for our legitimate interests: • Providing you with marketing materials and to personalise your experience with  our office, by one way or another, for example: o By sending marketing communications to you; o To enable you to subscribe to our newsfeeds and mailing lists; o Enabling you to register for any events hosted by Pulsit, workshops and/or  seminars. Further to the above, we also engage in these activities, and only with your consent or for  the legitimate interests of our business: • To achieve our purpose and analysing the information, for example to: o Establish, manage, and continuously maintain our business’ relationship  with you; o Compile usage statistics for our online offerings; o Recruit staff; o Process and respond to privacy requests, questions, concerns and  complaints; o Fulfil legal and contractual obligations; and o We engage in these activities to manage our contractual relationship with  you, to comply with a legal obligation and for our legitimate business  interests. 8. Addressing your rights as a data subject As defined by POPIA, you are a Data Subject. Hence you are enclosed with the right to  have your personal information processed in accordance with the requirements to lawfully  process your personal information as described in Chapter 3 of POPIA. These rights include  the right to:-7 • To be notified that – o Your personal information is being collected as provided for in terms of  Section 18; or – o Your personal information has been accused or acquired by an unauthorised  person as provided for in terms of Section 22; • to establish whether a responsible party holds personal information of you and to  request access to your personal information as provided for in terms of section 23; • requesting, where necessary, the correction, destruction or deletion of your  personal information as provided for in terms of section 24; • to object, on reasonable grounds relating to your particular situation to the  processing of your personal information as provided for in terms of section 11 (3)  (a); • to object to the processing of your personal information— o at any time for purposes of direct marketing in terms of section 11 (3) (b);  or o in terms of section 69 (3) (c); • not to have your personal information processed for purposes of direct marketing  by means of unsolicited electronic communications except as referred to in section  69 (1); • not to be subject, under certain circumstances, to a decision which is based solely  on the basis of the automated processing of your personal information intended to  provide a profile of you as provided for in terms of section 71; • to submit a complaint to the Regulator regarding the alleged interference with the  protection of your personal information as a data subject or to submit a complaint  to the Regulator in respect of a determination of an adjudicator as provided for in  terms of section 74; and • to institute civil proceedings regarding the alleged interference with the protection  of your personal information as provided for in section 99. All references to sections above are to sections in POPIA.8 9. Sharing your personal information When it comes to the sharing of your personal information, we may share it for the  purposes set out in this Privacy policy (where applicable) and such sharing includes the  following: • With our subsidiaries for the main purposes set out herein. We acknowledge that  we are the party responsible for managing your personal information. • With business partners in the event where we offer co-branded services or engage  in joint marketing activities. • We may share your information with service providers to provide several  operational services or to facilitate transactions on our behalf, which includes  without any limitations, the assistance with sale-related activities or post-sale  support, client support, e-mail delivery, auditing and data analytics. • At the times where you consent to the sharing of your personal information. • When in connection with any joint venture, merger, sale of company assets,  consolidation or restructuring, financing, or acquisition of all or a portion of our  business by or to another company. • Only and when applicable, for credit references, prevention of fraud and/or  business scoring agencies, or any other credit scoring agencies. • For the purpose of debt collecting agencies or any other debt recovery  organisations. • And for any other legal reason which may include: o The sharing of your personal information in response to a request thereof  by a competent court or authority, where it is required by any applicable  law, legal process or regulations; o If and where it is necessary to comply with the judicial proceedings, court  orders or government orders; or o In the protection of the rights, property and/or safety of Pulsit, our business  partners, yourself or any other third party, or as per requirements of the  applicable law. On several occasions, our third parties, service providers and Pulsit may make use of  Internet tags (which is also known as action tags, single-pixel GIF’s, clear GIF’s, invisible  GIF’s or 1-by-1 GIF’s) together with cookies at the site. We may also deploy these 9 tags/cookies through a third-party advertising partner or a web analytical service partner  which may be located and store the respective information in a foreign country.  You should note that any third party with whom we will share your personal information  with, we are contractually required to implement appropriate data protection and security  measures to ensure the protection and safe keeping of your personal information and to  ensure that the personal information is not being used for any form of unauthorised  processing, provided to any third party or made public to any third party without your  consent. We make use of these tags/cookies are placed on both online advertisements  that would bring users to use on our site and other web-pages. Within the scope hereof,  we make use of these technologies to measure the visitor’s responses to our sites and to  calculate and evaluate the effectiveness of our advertising campaigns. This includes how  many times a page is opened and what type of information is consulted.  The third-party web analytical service or third-party partner may be in the position and be  able to collect the necessary data about all visitors on our page and other sites based on  the other sites because of the internet tags/cookies. This may compose reports regarding  the website’s activity for us and may provide other further services which are related to  the use of our website and the internet. In the event where there is a legal requirement,  they may provide this information to other parties, or in the event where they hire other  parties to process the information on their behalf.  It is also within our Policy to make use of a number of technologies offered by different  service providers to support our website analytics and user tracking. This includes  technologies offered by the different providers. In the event where you wish to prevent or  control the use of these technologies, please contact our offices. 10. Security & safeguarding of your Personal Information Here at Pulsit, we are committed to protect not only your assets, but also your personal  information from accidental or unlawful destruction, loss, damage, alteration,  unauthorised access or disclosure by using reasonable, appropriate, physical,  administrative and technical safeguards which are either contractually bound by yourself  and us, or third parties to whom we disclose your personal information of which we require  the exact same standard.10 11. Cross border transit It might come to the fact that we may be required to fulfil all our contractual obligations  with yourself outside the borders of the Republic of South Africa. This may further require  us to transfer your personal information to the countries where we do our business, or to  international organisations in connection with the purpose identified herein above.  It is our duty to uphold this Policy statement by ensuring that any sharing of your data to  any third party, will comply with our standards, and the standards prescribed by POPIA,  including the protection and security of your personal information. 12. Data Protection and your rights in the EU Pulsit adheres to applicable data protection laws of the EU, which provide you with certain  rights relating to your personal information (if you are an EU citizen), subject to any legal  exceptions. Your rights include: • The right to access personal information that we hold about you. • The right to rectify inaccurate personal information we hold about you without  undue delay, and considering the purposes of the processing, to have incomplete  personal information about you completed. • The right to ask us to erase your personal information (the right to be forgotten)  without undue delay in certain circumstances. • The right to restrict the processing of your personal information in certain  circumstances. • The right to receive your personal information from us in a structured, commonly  used and machine readable format and to transmit your personal information to a  third party without obstruction (right to data portability) in certain circumstances. • Where we process personal information based on your consent, you have the right  to withdraw your consent at any time for future processing. • Where we process your personal information based upon our legitimate interests  or those of a third party, you have the right to object to the processing of your  personal information at any time (including to any profiling). • Where we process your personal information for direct marketing purposes, you  have the right to object to processing of your personal information at any time,  including profiling to the extent that it is related to such direct marketing.11 • The right not to be subject to a decision based solely on automated processing,  including profiling, which produces legal effects concerning you or similarly  significantly affects you. You may lodge a complaint with the European Commission’s online complaint procedure  ( if you believe that your data protection rights relating to your  personal information have been breached by Pulsit or that your personal information has  been compromised in some way. You may contact us with requests, complaints or  questions regarding these rights as set forth in the “How to contact us” section, below. Similarly, individuals in countries outside of the EU may exercise their rights under any  applicable data protection laws by contacting us in accordance with the “How to contact  us” section, below 13. Links to third party websites It is within our internet services may contain links to third parties websites and  applications. We are not responsible for and make no representations or warranties in  relation to the privacy practices or the content of any third party’s website and/or  applications. We confirm that the use of these websites or applications by yourself or any  person with the authority to act on your behalf, are subjected to the applicable third party’s  privacy policy and is at your own risk. 14. Direct Marketing We may send you direct marketing communications about our solutions, products and  services. Within the scope of this policy, you can choose whether you wish to receive  marketing communications from Pulsit by way of e-mail, SMS, post and/or other telephonic  manners. You have the option to opt out of receiving marketing materials from us at any  time and manage your communication preferences by: • Following the unsubscribed instructions included in each marketing material such  as email, SMS text messages from us; or • Sending an email to the sender of the marketing communications; or writing to: o Physical address: 12 Eeufees Crescent Meyerton Gauteng12 o Telephone: +27-10-476 2500 (Head Office) o Email: In the event where you choose to opt out of receiving any marketing related  communications from us, we may still send you administrative messages as part of our  ongoing use of our productions, services and/or solutions, which you will be unable to opt  out off.  We ensure you that we will not and do not provide any personal information to unaffiliated  third parties for direct marketing purposes, nor do we sell, rent, distribute or otherwise  make personal information commercially available to any third party for the purposes of  direct marketing, or anything else other than as specified herein. 15. Retaining and deletion of your personal information It is within our policy to retain your personal information for as long as it is necessary to  fulfil the purpose of which it was collected and as specified within this Policy, unless a  longer retention period is required to comply with legal obligations, resolve disputes,  protect or assets, or enforce agreements. These criteria we use to determine retention  periods include whether: • We are under a legal contractual or other obligation to retain personal information,  or as part of an investigation or for litigation purposes; • Where your personal information is needed to maintain accurate business and  financial records; • When there ate automated means to enable you to access and delete your personal  information at any time; • And when you have consented to us, to retain your personal information for a  longer period, in which case, it is within our duty to retain your personal information  in line with your consent. As soon as the period ended to which we retained your personal information, we ensure  you that we will destroy such information within the means and standards prescribed by  POPIA without disclosing any information to any third party. 16. Updates to this Privacy Policy13 It is within our right to update this Privacy Policy at any time when it is needed. When it  comes to any update, you will be notified about same update accordingly. You may also  see such update in the “last modified” section of the Privacy Policy statement. We therefore encourage you to regularly review our Privacy Policy so that you may stay  informed and updated at all times regarding our privacy practices. 17. Contact information In the event where you have any further queries regarding our Privacy Policy, please feel  free to contact us: Physical address: 12 Eeufees Crescent Meyerton Gauteng Telephone: +27-10-476 2500 (Head Office) +27-10-476-2540 (Sales) Email: If you have any queries, or you want to lodge a complaint in terms of non-compliance with  the POPIA, you may do so at any time and as per the regulations of and read together  with POPIA.