Who we are
Our website address is: https://www.silvertonradiators.com.
Introduction
This Privacy Policy outlines how Silverton Radiator, Brake and Clutch Gaborone (Pty) Ltd, Tracker Botswana, Auto Armor, and Tint My Ride (collectively referred to as “we,” “us,” or “our Companies”) collect, use, store, share, and protect your data in accordance with the Botswana Data Protection Act, 2018 (“DPA”). We are committed to protecting your privacy and ensuring transparency, fairness, and accountability in our handling of your data. This policy applies to all services we offer, including automotive repairs, vehicle tracking, smash-and-grab film installation, window tinting, and related services provided at our premises, through our websites, and via digital and tracking platforms.
Data We Collect
We may collect and process the following categories of data:
– Identity Data: Full name, ID/Omang/passport number, driver’s license.
Contact Data: Address, phone number, email address.
– Vehicle Data: Make, model, year, registration number, VIN, engine number.
– Transaction Data: Payment details, invoices, purchase and service history.
– Tracking Data (Tracker Botswana): GPS coordinates, vehicle route history, location data, geofencing events, ignition status.
– CCTV Footage: Video recordings at our business premises for security purposes.
– Technical Data: IP addresses, browser type, device ID, website usage patterns via cookies and analytics.
– Marketing Data: Communication preferences and marketing engagement (only if you opt in).
How we collect your data:
– Directly from you (e.g., in-person, phone, online forms).
– From your vehicle via installed tracking devices.
– Automatically through our websites via cookies and analytics.
– From third parties such as insurance partners or financial institutions.
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3. Legal Basis for Processing
We only process your data where the DPA permits. Our lawful bases include:
– Consent: For direct marketing, optional location sharing, and website cookies.
– Contract: To provide services you have requested or purchased.
– Legal Obligation: For tax, anti-fraud, security, or regulatory compliance.
– Legitimate Interests: To improve service delivery, ensure premises security, recover stolen vehicles, or analyse service usage—only where your rights do not override our interest.
4. How We Use Your Data
We use your data for the following purposes:
– To deliver and manage automotive services (repairs, installations, tinting, tracking).
– To process payments and issue invoices.
– To track and monitor vehicle movements (Tracker Botswana) for security and operational efficiency.
– To manage customer relationships and respond to inquiries.
– To protect our premises and assets via CCTV surveillance.
– To send marketing communications, offers, or service updates (with your consent).
– To analyse website usage and service trends using cookies and analytics tools.
– To comply with legal obligations (e.g., warranty tracking, insurance reporting).
5. Data Sharing
We only share your data where necessary, and in accordance with the DPA:
– With affiliated companies listed above for operational coordination.
– With service providers and contractors (e.g., payment processors, IT service providers) under binding confidentiality agreements.
– With insurance partners, such as Hollard Insurance Botswana, for claims verification and policy linkage.
– With law enforcement or regulatory authorities where legally required or to assist in stolen vehicle recovery.
– With cloud service providers for secure data hosting (see Section 10).
We do not sell your data.
6. Data Security
We implement appropriate technical and organisational measures to protect your data, including:
– Encrypted data transmission and storage.
– Role-based access controls and password protection.
– Physical security controls at all business premises.
– Firewalls and intrusion detection systems.
– Regular audits and vulnerability assessments.
– Staff training on data protection responsibilities.
7. Data Retention
We retain data only as long as necessary for the purposes collected, or as required by law:
– Financial Records: 7 years (e.g., invoices, payment records).
– CCTV Footage: 30 days, unless required for investigations.
– Vehicle Tracking Data: 12 months, unless retained longer at the customer’s request or due to an ongoing case.
– Customer Profiles and Service History: Retained for up to 5 years for recurring services or until the customer account is closed.
– Marketing Consent Records: Retained until consent is withdrawn.
Data scheduled for deletion is securely erased or anonymized.
8. Your Rights Under the DPA
You have the following rights with respect to your data:
– Access: Request a copy of the data we hold about you.
– Rectification: Request correction of inaccurate or incomplete data.
– Erasure: Request deletion of your data in certain circumstances.
– Restriction: Request temporary suspension of processing under specific conditions.
– Objection: Object to processing for direct marketing or where based on our legitimate interest.
– Data Portability: Request transfer of your data to another provider.
– Withdrawal of Consent: Withdraw consent at any time for processing based on consent.
To exercise your rights, please contact our Data Protection Officer using the contact details below. We may need to verify your identity before acting on your request.
9. International Data Transfers
Some of our service providers or data hosting partners may be located outside Botswana. When transferring data internationally:
– We ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or equivalent protection.
– Transfers are limited to jurisdictions with adequate data protection laws or contractual commitments that meet DPA standards.
10. Cookies and Tracking Technologies
Our websites use cookies and similar technologies to:
– Improve user experience and functionality.
– Track website usage and performance.
– Personalise content and promotional messages (with your consent).
You may adjust your browser settings to reject cookies, but this may impact functionality.
Tracker Botswana also collects GPS location data through devices installed in vehicles for fleet management and anti-theft purposes. Data is processed securely and in compliance with DPA obligations.
11. Complaints and Enforcement
If you have concerns about our use of your data, you may:
– Contact us directly using the contact details below.
– Lodge a complaint with the Information and Data Protection Commission of Botswana once it has been formally established.
We are committed to resolving all complaints in a timely and fair manner.
12. Updates to this Policy
We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, or data practices. When changes are made:
– We will revise the “Effective Date” at the top of this document.
– Where significant, we will notify customers via our websites or direct communication.
We encourage you to review this policy periodically.
13. Contact Details
For questions, concerns, or to exercise your data protection rights, please contact:
Human Resources Officer
Silverton Radiator, Brake and Clutch Gaborone (Pty) Ltd, Tracker Botswana, Auto Armor, Tint My Ride
Email: hr@srbc.co.bw
Phone: +267 742 17103
Physical Address: Plot 14457/8 Kamushongo Rd, G-West Industrial, Gaborone, Botswana
This Privacy Policy is issued in compliance with the Botswana Data Protection Act, 2018 and reflects our commitment to responsible data handling, accountability, and your rights as a valued customer.