Privacy Policy

Effective Date: 1 November 2021

Last updated: 10 June 2024

Silverline Investments Pty Ltd (t/a Tiger Wheel & Tyre Botswana) (“we”, “us”, or “our”) is committed to protecting your Personal Information which you provide to us.

This Privacy Policy sets out what Personal Information we collect and how we use it. It has been compiled in compliance with Botswana law in terms of the Data Protection Act 32 of 2018 (“Act”) and it sets out what we process, the purpose it is processed for, our security measures and your rights in respect of your Personal Information.

By communicating with us, purchasing our goods and/or services, and/or using our website https://www.twt.co.bw/, you expressly consent to us collecting, collating, processing and using your Personal Information and to sharing your Personal Information with our parent company TiAuto Investments (Pty) Ltd and its group of companies, as well as our partners Everlytic, Copper Table and Social Places based in South Africa, unless we require your prior written consent as set out in this Privacy Policy.

This Privacy Policy is incorporated into and considered part of any of any our agreements that references this Privacy Policy.

In terms of the Act, Data Subjects are natural persons only.

The Act defines “Personal Information” which includes:

  1. Personal data: information relating to an identified or identifiable individual, which individual can be identified directly or indirectly, in particular by reference to an identification number, or to one or more factors specific to the individual’s physical, physiological, mental, economic, cultural or social identity; and
  2. Sensitive personal data: racial or ethnic origin, political opinions, religious beliefs or philosophical beliefs, membership of a trade union, physical or mental health or condition, sexual life, affiliation; or personal financial information includes any commission or alleged commission by a Data Subject of any offence, any proceedings for any offence committed or alleged to have been committed by a Data Subject, the disposal of such proceedings, or the sentence of any court in such proceedings; and genetic data, biometric data and the personal data of minors.

We do not collect all categories of Personal Information. We only collect the Personal Information we need for our specific business purposes. Sensitive personal data will not be collected without your prior written consent.

We collect Personal Information directly from you and via our website.

  • Customers: We collect your Personal Information directly from you when you contact us by phone, email, social media or in person at one of our stores in relation to our products or services; general queries or complaints or when you respond to any marketing campaigns including Personal Information collected includes your name, surname, email address and telephone number.
  • Drivers and car owners: We collect Personal Information about the driver and owner of a vehicle  that is brought to us in order to perform an inspection or assessment of a vehicle and to provide products and/or services purchased from us.

Personal Information processed includes the driver and/or vehicle owner’s name, email  address, telephone number, identity number, vehicle details including vehicle photographs, vehicle registration number, vehicle licence number, and VIN number of the vehicle.

  • Credit applicants: We collect your Personal Information when you complete a credit application form including your name, trading name, company registration number, identity number, VAT number, postal, delivery and physical address details, your telephone numbers, fax numbers, email address and banking In the case where the credit applicant is a company, we also request you to provide the Personal Information of third parties such as your landlord, your shareholder(s), your auditor/accounting officer, your directors/trustees/partners/members/owners details and the surety’s details, where applicable. We also collect Personal Information from third parties (including credit bureaus).
  • Suppliers: The Personal Information collected includes your bank account details, address, points of shipment, telephone number, email addresses, and details of contact persons within your business.
  • Job applicants: We collect Personal Information directly from you, from third parties (such as verification agencies and recruitment agencies), and from public records (such as LinkedIn). This Personal Information includes any Personal Information you have supplied on your job application form, in your CV, during your interview with us, and your academic history and records. Criminal record verification will only be conducted with your prior written
  • Employees: We collect and process your Personal Information when you are on-boarded as an This includes your name, tax details, email address, telephone numbers, physical address, trade union membership details (with your prior written consent), and bank details.

In certain instances, we may request you to provide the Personal Information of your friends or family (e.g. your next of kin) who can be contacted in the case of an emergency.

  • Visitors: In order to maintain the security of our premises the Personal Information we collect includes your name, contact details, and car registration number.
  • Website users: We collect Personal Information when you visit our website. Please refer to our cookies policy described below.
  • Biometric: We collect video footage when you make use of our premises for security and monitoring

Please note failing to provide certain Personal Information may impact our ability to, amongst other things:

  • provide you with our products or services;
  • extend credit to you;
  • provide you access to all webpages and websites;
  • on-board you as a supplier;
  • assess you in respect of a job opportunity;
  • perform in terms of a contract (such as an employment contract) with you; or
  • allow access to our premises.
  1. Provision of products and services
  • In order to provide you with the products and services you have requested;
  • To verify your instructions to us;
  • To analyse, assess and improve our services to you; and
  • For training and quality

b. Invoicing and payments

To invoice you in respect of products and services purchased by you and for the collection of amounts due to us for the provision of such products and services. If you are a supplier or employee we and/or TiAuto will use your Personal Information to make payment to you.

c. Queries and complaints

To respond to any questions, requests, concerns, or complaints you may have regarding our products, service offerings, or processing activities.

d. Marketing

  • We and/or TiAuto may contact you to market our products and services and to communicate with you regarding competitions, events, and other promotions we are involved in.
  • We may use email, telephone, and text to communicate with you for marketing purposes. You may change any communication preferences by:
    • Lodging a formal request to: marketing@tiauto.co.za for instructions and/or relevant forms on how you can update your preferences.
    • Clicking on the relevant links included in any communication that is sent. This will take you to our communication partner Everlytic who manages our client communications on our
  • You have the right to opt-out of direct marketing at any stage by following the “opt out” instructions or selecting the “unsubscribe” link available in the direct marketing or other communication you receive from us. Please note that it may take up to 5 days for your opt-out to be effective. Should you continue to receive direct marketing from us or TiAuto beyond this period please inform our Information Officer at the address below.

e. Online advertising

Neither we norTiAuto currently performs any online behavioural advertising, however, this may be revisited in  the future. Should the current position change we will update this privacy policy.

f. Credit check and verification

  • If you have sent us a credit application for the purchase of our products and services we will submit your Personal Information to a credit bureaux to perform credit checks. Credit checks assist us in determining whether or not we would like to extend credit to
  • Your Personal Information will be used to open your account with us, to verify your identity when we are in contact with you, and to analyse your account with us in order to efficiently provide you with our products and services.

g. Compliance with laws

We process Personal Information in order to comply with any obligations imposed on us by law.

h. Supplier assessment and on-boarding

Personal Information is processed to determine whether we require your goods or services, to register you as a supplier on our procurement system, and in order to fulfill our contract with you (i.e. including processing payment).

i. Recruitment and employment

We process your Personal Information in order to:

  • evaluate you in respect of a job you have directly or indirectly applied for;
  • on-board you as an employee;
  • administer benefits and make payment of your salary or wages as agreed in your employment contract;
  • comply with employment, health and safety and tax laws which apply to you;
  • assess your performance
  • take disciplinary action, where necessary
  • comply with any other obligation imposed on us by law.

j. Security

We process Personal Information to secure our premises, our assets, and our employees.

  • Related companies: We may share your Personal Information with related companies within the group held by our parent company TiAuto Investments (Pty) Ltd (“TiAuto”) in South Africa (including its franchises) (“Group”).
  • Business Partners: We may also share your Personal Information with our or the Group’s business partners, suppliers, or agents who are tasked with delivering our products and services to you, but only to the extent strictly necessary.
  • Credit bureaus and verification agencies: in order to assess the credit worthiness of credit applicants, to job applicants’ criminal records or to authenticate their
  • Debt collectors: where you default on the payment of fees due to us in connection with the products and services provided to you.
  • Law enforcement agencies: including, but not limited to, the Botswana Police Service, local, provincial, and national government entities, regulators, and courts, where we are compelled by law to do so.
  • Mergers and acquisitions: Should TiAuto be reorganised or sold to another company or entity, your Personal Information may be provided to such company or
  1. Cross boarder transfer: Our parent company TiAuto is based in South Africa and is a multinational organisation with group entities located outside of South Africa including, Botswana, Tanzania, Zambia, and Zimbabwe. Accordingly, Personal Information will only be transferred to recipients in South Africa unless requested otherwise by the data subject.
  2. we will only transfer your Personal Information to approved countries on the Transfer of Personal Data Order 2022 as amended and updated.

Each time you interact with our websites, we may automatically collect the following Personal Information:

  • Technical information including, but not limited to, browser type, operating system, device information, IP address, domain name, referral URL.

Usage information including, but not limited to, geographic location information (such as your country or province), the numbers and frequency of visitors to our site, page views, unique page views, video views, form conversions, and your clickstream behaviour (e.g. clicking links to, through and from our Website).

We may use various technologies such as cookies, web beacons (also referred to as clear gifs), and e-tags to collect Personal Information, to analyse trends, and to provide you with a more personalized customer experience.

Cookies are small pieces of information that are placed on your computer to enable our system to recognize your computer when you return to our website and to collect various technical and usage information about your visits. Cookies may be used by us, TiAuto and our third-party suppliers who help us provide our website. We may link information stored in cookies to the Personal Information we have in our systems.

In addition, we and our third-party partners and suppliers may use cookies and other similar technologies to enhance the quality of your interactions with our website, provide you with targeted advertising, and to analyse the effectiveness of any such advertising (such as user engagement and interaction). We may also receive reports based on the use of certain technologies by these companies on an individual and anonymized basis.

Most browsers have options for deleting, blocking or otherwise disabling the use of cookies.

For more information on how to do so, please refer to the documentation accompanying your browser. If you choose to disable cookies, some areas of our website may not function properly.

To learn more about third-party cookies and other advertising networks and their opt-out instructions, please visit http://www.aboutads.info/choices or http://preferences-mgr.truste.com.

To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect.

These include but are not limited to:

  • Hosting of our systems in secure data centre
  • Limiting of access to information and personal information via clear segregation of roles in our
  • Ongoing education of our staff on the secure handling of personal information in our
  • Encryption of data where
  • Securely storing of physical records in controlled filing locations where
  • Securely destroying operational records and data when they are no longer required in terms of relevant operational or legislative retention
  • We will retain your Personal Information only for as long as we need it in terms of our group policy and schedule and as required by law. We will take all reasonable steps to destroy, delete, or de-identify Personal Information records as soon as reasonably possible after the retention period has been In determining the retention periods we have had regard to:
  • the purpose for which the Personal Information was collected or subsequently processed;
  • whether the retention of the Personal Information record is required or authorised by law;
  • whether we reasonably require the Personal Information record for lawful purposes related to our functions or activities;
  • whether the Personal Information record is required by a contract between us or TiAuto and you;
  • whether you have consented to the retention of the Personal Information record for a longer period than would ordinarily apply;
  • whether Personal Information records are required for historical, statistical or research purposes.

We set out your rights regarding your Personal Information below. Should you wish to exercise any of these rights please contact TiAuto’s Information Officer using the details provided below:

a. Right to access Personal Information

You have the right to inquire as to whether or not we or TiAuto holds any of your Personal Information without  incurring any fees or charges. You may also request us to provide a description of the Personal Information we hold about you and/or  to request access to such Personal Information records. In order to respond to such requests there may be a fee or charge payable by you. However, we will provide you with a written estimate of such fee before providing you with services associated with your request for access.

 

b. Right to correct or delete Personal Information

You have the right to request the correction or deletion of your Personal Information if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully; or if we or TiAuto are no longer authorised to retain such Personal Information having regard to the requirements of the Act.

 

c. Right to object to the use of Personal Information

You have the right to object to direct marketing at any time. You also have the right to object to the processing of your Personal Information by us and/or TiAuto, unless required in terms of the law.

Please note your Personal Information may be processed in the following instances, where:

  • We or TiAuto consider it necessary to process such Personal Information to protect a legitimate the interest of yours; or
  • We or TiAuto consider it necessary to process your Personal Information for pursuing its legitimate interests or the legitimate interests of a third party to whom the Personal Information is

d. Right to withdraw consent

You have the right to withdraw your consent in instances where TiAuto relies on consent as a justification to process your Personal Information and you have previously given such consent.

e. Right to lodge a complaint You have the right to lodge a complaint with TiAuto’s Information Officer/Deputy Information Officer or the data protection authority in your country.

TIAUTO INFORMATION OFFICER INFORMATION REGULATOR
Information Officer: Alex Taplin Botswana Communications Regulatory Authority

Plot 50671 Independence Avenue

Gaborone, Botswana

T : +267 395 7755

F : +267 395 7976

E : info@bocra.org.bw.

Physical Address: Investments (Pty) Ltd, Corner K101 and Old Pretoria road, Halfway House Estate, Midrand,1685.  
Email address: compliance@tiauto.co.za  

Should you require any further information regarding the Personal Information processed by us or TiAuto, wish to exercise any of your rights in respect of your Personal Information, or to lodge a complaint regarding the manner in which your Personal Information is being processed by us or TiAuto you may contact the Information Officer via courier or email per the details below.

Information Officer: Alex Taplin

Physical Address:

TiAuto Investments (Pty) Ltd Corner K101 and Old Pretoria road Halfway House Estate

Midrand 1685.

Email address: compliance@tiauto.co.za