Marsh Auto Flames (Pty) Ltd.

Privacy Policy

Last updated:

Company Registration Number: 2025/249073/07

Proposed effective date: Date of publication Website: https://marshautoflames.com Privacy contact: info@marshautoflames.com

1. INTRODUCTION

Marsh Auto Flames (Pty) Ltd. ("Marsh Auto Flames", "MAF", "we", "us" or "our") respects your privacy and is committed to protecting your personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA) and other applicable South African laws.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you visit our website, submit a vehicle request, communicate with us, use our services or interact with our business.

Marsh Auto Flames operates as a vehicle sourcing and automotive brokerage business. We assist customers in finding vehicles through dealership networks and facilitate introductions between customers and suitable dealerships.

We process personal information only for defined and lawful purposes, using an appropriate lawful basis under POPIA.

2. PERSONAL INFORMATION WE COLLECT

Depending on the services you request and your interaction with MAF, we may collect the following categories of personal information:

2.1 Customer identification and contact information

  • Full name and surname.
  • Telephone and WhatsApp number.
  • Email address.
  • Residential or delivery location, where relevant.
  • Other contact information voluntarily provided.

2.2 Vehicle sourcing information

  • Vehicle make and model.
  • Preferred year, mileage and specifications.
  • Purchase budget.
  • Preferred vehicle condition and transmission.
  • Vehicle financing preferences.
  • Trade-in vehicle information.
  • Delivery and location preferences.

2.3 Enquiry and communication information

  • Messages and correspondence with MAF.
  • Vehicle requests and enquiry history.
  • Customer preferences and feedback.
  • Records of dealership introductions.
  • Customer decisions and service interactions.

2.4 Finance and trade-in information

Where a customer specifically requests assistance with financing or a trade-in, we may process relevant information supplied by the customer to facilitate that request.

We will not collect more information than is reasonably necessary for the relevant purpose.

Customers should not submit identity documents, banking details or other highly confidential information through ordinary enquiry forms or WhatsApp unless a specific, secure and appropriate process has been established.

2.5 Technical information

When you visit our website, certain technical information may be collected, depending on the website's configuration. This may include IP address, browser type, device information, website usage and diagnostic information.

2.6 Cookies and analytics

Our website may use cookies or similar technologies to support functionality, security and website performance.

The specific cookies and tracking technologies used will depend on the website configuration. Where required, we will provide appropriate information and obtain consent before using non-essential cookies.

3. HOW WE USE YOUR PERSONAL INFORMATION

MAF may process personal information for the following purposes:

  1. To receive and manage vehicle sourcing requests.
  2. To identify suitable vehicles through dealership networks.
  3. To assess vehicle specifications against customer preferences.
  4. To communicate suitable vehicle opportunities.
  5. To facilitate introductions between customers and dealerships.
  6. To manage customer enquiries through our CRM.
  7. To coordinate trade-in and finance enquiries where requested.
  8. To provide customer support and follow-up services.
  9. To maintain business, transaction and service records.
  10. To prevent fraud, protect our systems and maintain security.
  11. To comply with legal and regulatory obligations.
  12. To improve our website, services and customer experience.

We rely on the applicable lawful grounds permitted under POPIA, depending on the particular processing activity. These may include consent, steps taken at the request of the customer before entering into a contract, contractual necessity, legal obligations and other lawful grounds where applicable.

4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

MAF does not sell customers' personal information.

However, our vehicle sourcing and brokerage services may require certain personal information to be shared with selected third parties.

4.1 Dealership introductions

When MAF identifies a suitable vehicle at a dealership, we may facilitate an introduction between the customer and that dealership.

Before sharing identifiable customer contact information for an introduction, our normal process is to:

  • Identify the dealership to the customer.
  • Explain the purpose of the proposed introduction.
  • Explain which personal information will be shared.
  • Obtain and record the customer's affirmative authorisation for the introduction, where consent is the applicable lawful basis and as a customer-trust safeguard.
  • Share only the information reasonably necessary for that introduction.

The information may include the customer's name, contact number, relevant vehicle requirements and other details specifically authorised or necessary for the introduction.

The dealership may then contact the customer directly to discuss the vehicle, availability, pricing, test drives, financing or the potential purchase.

Once the customer is introduced, the dealership may process the customer's information under its own privacy policy and legal responsibilities.

4.2 Finance and trade-in service providers

Where a customer requests assistance with financing or trade-in services, MAF may facilitate a referral to an appropriate service provider.

Information will be shared only where necessary for the requested service and under an appropriate lawful basis, with appropriate transparency and safeguards.

4.3 Service providers and operators

MAF may use third-party service providers to support its business operations, including website hosting, CRM systems, database management, communications, technical support, security and analytics.

Where a provider processes personal information on our behalf as an operator, appropriate written confidentiality and security obligations will apply.

4.4 Legal disclosures

We may disclose personal information where required or authorised by applicable law, court order or a lawful regulatory requirement, or where otherwise permitted under POPIA.

5. DIRECT MARKETING AND COMMUNICATIONS

MAF may communicate with customers about their specific vehicle requests, enquiries and services they have requested.

Promotional communications and unrelated marketing are treated separately from communications required to handle a customer's enquiry.

We will comply with section 69 of POPIA and applicable regulations when conducting direct marketing through unsolicited electronic communications, including email, SMS, WhatsApp and other electronic channels.

Where prior consent is required, we will obtain it in the prescribed manner.

Marketing consent will be optional and separate from the submission of a vehicle sourcing request.

Customers may withdraw marketing consent or unsubscribe from marketing communications at any time, without affecting the handling of their existing vehicle enquiry.

6. STORAGE, SECURITY AND PROTECTION OF PERSONAL INFORMATION

MAF takes reasonable and appropriate technical and organisational measures to protect personal information against:

  • Unauthorised access.
  • Unlawful processing.
  • Accidental loss or destruction.
  • Unauthorised disclosure.
  • Damage or alteration.

These safeguards may include access restrictions, authentication controls, appropriate password practices, secure hosting, backups, staff confidentiality obligations and security monitoring, according to the systems and measures actually implemented.

Access to customer information will be restricted to authorised persons who require it to perform their responsibilities.

Where a third-party operator processes personal information for MAF, appropriate written security and confidentiality arrangements will be maintained.

In the event of a security compromise involving personal information, MAF will follow the applicable POPIA notification requirements and notify the Information Regulator and affected data subjects where required.

7. DATA RETENTION AND DELETION

MAF retains personal information only for as long as reasonably necessary for the purpose for which it was collected, or where retention is required or permitted by law.

Retention periods may depend on:

  • The nature of the customer's enquiry.
  • Whether a vehicle transaction or introduction occurred.
  • Applicable legal and regulatory obligations.
  • Accounting and record-keeping requirements.
  • Dispute resolution and enforcement of agreements.
  • Legitimate business and security requirements.

When personal information is no longer required and there is no lawful reason to retain it, it will be securely deleted, destroyed or de-identified where appropriate.

Requests for deletion will be assessed in accordance with applicable law. Information may need to be retained where a legal obligation or other lawful ground applies.

8. CUSTOMER RIGHTS

Subject to applicable law, customers and other data subjects have the right to:

  1. Request confirmation of whether MAF holds their personal information.
  2. Request access to personal information held by MAF.
  3. Request correction or deletion of inaccurate, irrelevant, excessive, outdated or unlawfully obtained information.
  4. Object to certain processing activities where POPIA provides this right.
  5. Withdraw consent where processing relies on consent.
  6. Object to direct marketing.
  7. Lodge a complaint with the Information Regulator.

To exercise these rights, contact:

Information Officer: Ifeanyi N Okoye Email: info@marshautoflames.com

We may need to verify your identity before processing a request.

Requests will be handled in accordance with POPIA and other applicable laws.

9. INFORMATION OFFICER AND PRIVACY ENQUIRIES

The designated contact for privacy and personal information matters is:

Marsh Auto Flames (Pty) Ltd. Information Officer: Ifeanyi N Okoye Email: info@marshautoflames.com Website: https://marshautoflames.com Business location: Annlin, Pretoria, South Africa.

Privacy enquiries, requests to access or correct information, objections and complaints may be submitted using the contact details above.

The Information Officer's statutory duties and registration will be maintained in accordance with applicable requirements.

10. THIRD-PARTY WEBSITES AND SERVICES

Our website or communications may contain links to third-party websites or services.

MAF does not control the privacy practices of independent third parties. Customers should review the relevant privacy policies before submitting personal information to those third parties.

11. CHILDREN'S PERSONAL INFORMATION

Our services are intended for individuals legally able to participate in the relevant vehicle sourcing and purchasing arrangements.

Where personal information relating to a child is processed, MAF will apply the additional protections and requirements applicable under POPIA.

12. CHANGES TO THIS PRIVACY POLICY

MAF may update this Privacy Policy from time to time to reflect changes in our services, business operations, technology or legal obligations.

The updated policy will be published on our website, together with its effective or last-updated date.

Where a material change requires additional notice or consent, MAF will take the appropriate steps.

13. COMPLAINTS TO THE INFORMATION REGULATOR

If you believe that your personal information has been processed unlawfully or that your privacy rights have been infringed, you may contact MAF using the details provided above.

You may also lodge a complaint with the Information Regulator of South Africa.

Website: https://inforegulator.org.za Email: POPIAComplaints@inforegulator.org.za Telephone: 010 023 5200

14. GOVERNING LAW

This Privacy Policy is governed by the laws of the Republic of South Africa, including the Protection of Personal Information Act 4 of 2013 (POPIA), as amended or applicable from time to time.

MARSH AUTO FLAMES (PTY) LTD. Registration Number: 2025/249073/07

End of Privacy Policy