cTrack Zambia

LEGAL

Ctrack provides easy access to our online legal, privacy and compliance documents. Please ensure that you have read and understood the applicable terms, policies and notices when using our website, platforms, products and services.

TERMS & CONDITIONS

Our Terms & Conditions govern the provision and use of Ctrack products and services.

View Terms & Conditions

PRIVACY POLICY

Ctrack Zambia is committed to protecting the privacy and security of personal information processed in connection with our website, products and services.

This Privacy Policy explains how Ctrack Zambia collects, uses, stores, shares and protects personal information and the rights available to individuals whose personal information we process.

Ctrack processes personal information in accordance with the Zambia Data Protection Act, 2021, the Data Protection (General) Regulations, 2024, and other applicable laws and regulations.

By using our website, products or services, you acknowledge that you have read and understood this Privacy Policy.

1. Who We Are

This Privacy Policy applies to Ctrack Zambia and the relevant Ctrack entity responsible for providing the applicable website, products or services.

The applicable Ctrack entity may act as a Data Controller where it determines the purposes and means of processing personal information, and as a Data Processor where it processes personal information on behalf of a customer.

Where Ctrack provides fleet-management and telematics services to a business customer, that customer may determine the purposes for which driver, vehicle and other personal information is processed. In such circumstances, Ctrack may process personal information on behalf of the customer as a Data Processor.

2. Personal Information We Collect

Depending on how you interact with Ctrack, we may collect and process:

  • Name and surname
  • Contact details
  • Email address
  • Telephone or mobile number
  • Company and job-title information
  • Account and login information
  • Vehicle registration and identification information
  • Driver identification information
  • Vehicle location and GPS information
  • Journey and trip information
  • Vehicle utilisation information
  • Driving behaviour and driver-performance information
  • Speed, acceleration, braking and cornering information
  • Vehicle diagnostic and technical information
  • Accident and incident information
  • Video footage, where video telematics services are used
  • Images and other information captured by vehicle-mounted cameras
  • Device identifiers and technical information
  • IP addresses
  • Website usage information
  • Cookie and similar tracking information
  • Information contained in enquiries, correspondence and support requests
  • Billing and transaction information
  • Any other information reasonably required to provide our products and services.

We will seek to collect only information that is relevant and reasonably necessary for the applicable purpose.

3. Telematics, Vehicle Tracking and Driver Information

Ctrack provides fleet-management and telematics services that may involve the processing of information relating to vehicles, drivers and journeys.

Depending on the services and equipment used, this may include:

  • Vehicle location and GPS coordinates
  • Journey routes and history
  • Date and time information
  • Vehicle speed
  • Distance travelled
  • Vehicle utilisation
  • Driver identification
  • Driving behaviour
  • Harsh braking and acceleration
  • Cornering behaviour
  • Idling
  • Vehicle and engine information
  • Safety events
  • Accident and incident information
  • Vehicle security and theft-related information
  • Video and images where video telematics is enabled.

This information may be processed to provide fleet-management services, improve road safety, manage vehicle fleets, investigate incidents, assist with vehicle recovery, identify vehicle or driver risks, provide reports and analytics, and support other legitimate purposes associated with the Ctrack service.

Where Ctrack processes driver or other personal information on behalf of a customer, the customer is responsible for determining the purposes of the processing and for providing appropriate notices to its employees, drivers and other relevant data subjects.

4. Video Telematics

Where video telematics or vehicle-mounted cameras are used, cameras may capture images or video of:

  • Drivers
  • Passengers
  • Pedestrians
  • Other road users
  • Vehicles
  • Vehicle registration plates
  • Roadways and surrounding areas
  • Incidents and accidents.

The purpose of video processing may include improving driver and road safety, investigating accidents and incidents, preventing fraud, supporting vehicle security, providing evidence and managing fleet risks.

Where audio recording is technically available and enabled, applicable users will be informed through appropriate notices or contractual documentation.

Video and associated information will be retained only for as long as reasonably necessary for the applicable purpose, subject to contractual, legal, regulatory and security requirements.

5. Purposes for Processing Personal Information

We may process personal information for purposes including:

  • Providing fleet-management and telematics services
  • Monitoring vehicle location and utilisation
  • Providing driver and vehicle safety information
  • Managing customer accounts
  • Installing and maintaining equipment
  • Providing technical and customer support
  • Investigating accidents and incidents
  • Supporting vehicle security and theft recovery
  • Providing reports, dashboards and analytics
  • Monitoring and improving driving behaviour
  • Conducting predictive analytics and maintenance analysis
  • Detecting fraud, misuse and security threats
  • Maintaining and securing our websites, applications and systems
  • Processing quotations, orders, contracts and invoices
  • Communicating with customers and users
  • Responding to enquiries
  • Managing complaints and disputes
  • Conducting business and service analytics
  • Sending marketing communications where legally permitted
  • Complying with legal and regulatory obligations
  • Protecting our rights, property and systems
  • Preventing or investigating unlawful activity
  • Performing other purposes disclosed at the time information is collected.

6. Lawful Basis for Processing

We process personal information only where there is a lawful basis for doing so.

Depending on the circumstances, this may include:

  • Performance of a contract
  • Taking steps at the request of an individual before entering into a contract
  • Compliance with a legal or regulatory obligation
  • Protection of legitimate interests
  • Consent, where required
  • Other lawful grounds recognised under applicable data-protection legislation.

Where processing is based on consent, the individual may withdraw consent where applicable. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.

7. Direct Marketing

We may use contact information to communicate with customers and prospective customers about Ctrack products, services, events and relevant information where permitted by law.

Where consent is required, we will obtain the appropriate consent.

Individuals may request that their personal information no longer be used for direct marketing by using the unsubscribe mechanism provided or by contacting Ctrack.

8. Cookies and Similar Technologies

Our website may use cookies and similar technologies to operate the website, remember preferences, understand website usage, improve functionality and, where applicable, support analytics and marketing activities.

Cookies may include:

  • Strictly necessary cookies
  • Functional cookies
  • Analytics and performance cookies
  • Marketing or advertising cookies
  • Third-party cookies.

Where required by law, we will obtain consent before placing non-essential cookies on a user’s device.

Users may manage or disable cookies through the cookie-consent mechanism provided on the website or through their browser settings.

Disabling certain cookies may affect website functionality.

For further information, please see our Cookie Policy.

9. Information Collected Automatically

When you visit our website, we may automatically collect certain technical information, including:

  • IP address
  • Browser type
  • Device type
  • Operating system
  • Approximate location
  • Referring website
  • Pages visited
  • Date and time of access
  • Website interaction information
  • Technical and diagnostic information.

This information may be used to operate, secure, analyse and improve our website and services.

10. Third-Party Service Providers

We may use trusted third-party service providers to support our business and services.

These may include:

  • Cloud-hosting providers
  • Information-technology providers
  • Telecommunications providers
  • Cybersecurity providers
  • Customer relationship management providers
  • Analytics providers
  • Payment providers
  • Email and communications providers
  • Professional advisers
  • Technical and maintenance providers
  • Other service providers required to operate our business.

Where third parties process personal information on our behalf, we will implement appropriate contractual, technical and organisational safeguards as required by applicable law.

11. Sharing Personal Information

We may share personal information where reasonably necessary with:

  • Ctrack group companies
  • Our customers, where they are authorised to receive the information
  • Service providers and processors
  • Professional advisers
  • Financial institutions and payment providers
  • Insurers where applicable
  • Law-enforcement authorities and regulators where legally required
  • Courts and other authorised bodies
  • Other parties where permitted or required by law.

We do not sell personal information to third parties for their own unrelated purposes.

12. International Transfers

Certain Ctrack group companies, technology providers, service providers or other authorised third parties may process or store personal information outside Zambia.

Where personal information is transferred or stored outside Zambia, Ctrack will comply with applicable requirements of Zambian data-protection law and implement appropriate safeguards and obtain any required authorisations where applicable.

13. Data Security

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

  • Unauthorised access
  • Unauthorised disclosure
  • Loss
  • Destruction
  • Alteration
  • Misuse
  • Accidental or unlawful processing.

Security measures may include access controls, authentication mechanisms, encryption where appropriate, monitoring, backup procedures, security testing, employee confidentiality requirements and incident-response procedures.

No method of transmitting or storing information can be guaranteed to be completely secure.

14. Data Security Incidents and Breaches

Ctrack maintains procedures for identifying, investigating, managing and responding to personal-data breaches and other information-security incidents.

Where required by applicable law, Ctrack will notify the relevant regulatory authority and affected individuals of a personal-data breach.

15. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected.

The retention period may depend on:

  • The nature and purpose of the information
  • The contractual relationship
  • Legal and regulatory requirements
  • Accounting and tax obligations
  • Security requirements
  • Dispute resolution
  • Fraud prevention
  • Business requirements
  • The nature of the applicable Ctrack service.

Different categories of information may therefore be retained for different periods.

When personal information is no longer required, we will securely delete, destroy or anonymise it where appropriate and in accordance with our applicable retention and destruction procedures.

16. Automated Decision-Making, Profiling and Artificial Intelligence

Ctrack may use analytics, algorithms, machine learning, artificial intelligence and automated technologies to support services such as:

  • Predictive maintenance
  • Driver-risk analysis
  • Safety monitoring
  • Vehicle performance analysis
  • Anomaly detection
  • Fleet optimisation
  • Automated alerts and recommendations.

Where applicable, Ctrack will provide information about automated decision-making and profiling and respect rights available to individuals under applicable data-protection law.

17. Your Data Protection Rights

Subject to applicable law and any lawful limitations, individuals may have rights including:

  • The right to know whether personal information is being processed
  • The right to access personal information
  • The right to request correction of inaccurate or incomplete information
  • The right to request deletion or erasure where applicable
  • The right to object to certain processing
  • The right to object to direct marketing
  • The right to withdraw consent where processing is based on consent
  • Rights relating to automated decision-making and profiling
  • The right to lodge a complaint concerning the processing of personal information
  • Other rights provided under applicable data-protection legislation.

Requests to exercise these rights may be subject to identity verification and applicable legal limitations.

18. How to Exercise Your Rights

To exercise your data-protection rights or make a privacy enquiry, please contact our Data Protection Officer using the contact details below.

We may request additional information to verify your identity before processing a request.

We will respond to valid requests within the period required by applicable law.

19. Data Protection Officer

Ctrack has appointed a Data Protection Officer to oversee applicable data-protection and privacy matters.

Data Protection Officer – Ctrack Zambia

Email: [INSERT EMAIL ADDRESS]

Telephone: [INSERT TELEPHONE NUMBER]

Physical Address: [INSERT PHYSICAL ADDRESS]

Postal Address: [INSERT POSTAL ADDRESS]

20. Complaints

If you believe that your personal information has been processed unlawfully or that Ctrack has not adequately addressed your privacy request, you should first contact our Data Protection Officer.

You may also lodge a complaint with the Data Protection Commissioner of Zambia where permitted by applicable law.

21. Children’s Personal Information

Our website and services are not generally directed at children.

We do not knowingly collect personal information from children except where permitted by law and where appropriate safeguards are in place.

If you believe that a child has provided personal information to us unlawfully, please contact our Data Protection Officer.

22. Third-Party Websites

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

Ctrack is not responsible for the privacy practices, security or content of third-party websites.

Users should review the privacy policies of third-party websites before providing personal information.

23. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, legal requirements or privacy practices.

The updated version will be published on our website with the applicable effective or revision date.

24. Contact Us

If you have questions about this Privacy Policy, our processing of personal information or your data-protection rights, please contact our Data Protection Officer using the details provided above.


WEBSITE TERMS OF USE

The Ctrack Zambia website and associated online portals are provided subject to these Terms of Use.

By accessing or using the website or portals, you agree to comply with these Terms of Use.

1. Acceptable Use

You may use the website and portals only for lawful purposes.

You must not:

  • Use the website unlawfully
  • Attempt to gain unauthorised access to systems or accounts
  • Interfere with website security
  • Introduce malicious software
  • Copy or reproduce website content without permission
  • Use automated systems to extract information without authorisation
  • Misrepresent your identity
  • Use the website in a manner that could damage Ctrack or its systems.

2. Intellectual Property

All intellectual property rights in the website, content, trademarks, logos, software and associated materials belong to Ctrack or its licensors unless otherwise stated.

No rights are transferred to users except those expressly granted under these Terms of Use.

3. Website Availability

Ctrack will use reasonable efforts to maintain the availability and functionality of the website.

However, Ctrack does not guarantee that the website will always be available, uninterrupted, secure or error-free.

4. Information on the Website

Information provided on the website is intended for general information purposes.

Ctrack makes reasonable efforts to keep information accurate and current but does not warrant that all information will always be complete, accurate or up to date.

5. Third-Party Links

The website may contain links to third-party websites.

Ctrack does not control or accept responsibility for third-party websites or services.

6. Limitation of Liability

To the extent permitted by applicable law, Ctrack will not be responsible for losses arising from use of or reliance upon the website where such liability cannot lawfully be imposed or has been excluded under applicable contractual terms.

Nothing in these Terms of Use excludes or limits liability that cannot lawfully be excluded or limited.

7. Privacy

The processing of personal information through the website is governed by the applicable Ctrack Privacy Policy.

8. Changes to These Terms

Ctrack may amend these Terms of Use from time to time.

Updated Terms of Use will be published on the website.

9. Governing Law

These Terms of Use shall be governed by the laws applicable to the relevant Ctrack Zambia entity and the applicable contractual relationship, subject to any mandatory provisions of Zambian law.


DATA RETENTION & DESTRUCTION POLICY

Ctrack maintains procedures governing the retention, archiving and destruction of business and personal information.

Information is retained only for as long as reasonably necessary, taking into account applicable legal, regulatory, contractual, operational, security and business requirements.

When information is no longer required, it will be securely deleted, destroyed or anonymised in accordance with applicable retention and destruction procedures.

Different categories of information may have different retention periods.

Where information is subject to a legal hold, investigation, dispute or other legitimate requirement, destruction may be suspended until the applicable matter has been resolved.


EMAIL SIGNATURE DISCLAIMER

The information contained in this e-mail may be confidential, legally privileged or protected by law and is intended solely for the recipient.

If you are not the intended recipient, please notify the sender immediately and delete this communication.

Any unauthorised use, disclosure, copying, distribution or dissemination of this communication is prohibited.

The views or opinions expressed in this communication are those of the individual author unless expressly stated otherwise.

Ctrack does not accept responsibility for unauthorised alteration of this communication or for any loss arising from the use of this communication or its attachments.

Although reasonable precautions may be taken, Ctrack does not warrant that this communication or its attachments are free from errors, malware, interference, interception or other security risks.


COOKIE POLICY

Ctrack Zambia uses cookies and similar technologies on its website.

Cookies are small text files placed on your device that allow a website to recognise your device and remember certain information.

We may use cookies for the following purposes:

Strictly Necessary Cookies

These cookies are required for the website to operate and cannot generally be disabled through our cookie-management system.

Functional Cookies

These cookies allow the website to remember preferences and provide enhanced functionality.

Analytics Cookies

These cookies help us understand how visitors use our website and allow us to measure and improve website performance.

Marketing Cookies

Where applicable, marketing cookies may be used to understand browsing activity and support relevant marketing or advertising.

Third-Party Cookies

Certain third-party services integrated into our website may place their own cookies or similar technologies.

Where required by applicable law, Ctrack will request consent before using non-essential cookies.

Users may change their cookie preferences through the cookie-consent mechanism provided on the website or through their browser settings.

Some website functions may not operate correctly if certain cookies are disabled.


COMPLIANCE & INFORMATION SECURITY

ISO/IEC 27001:2022

Ctrack is committed to protecting information, managing information-security risks and continually improving its information-security management practices.

Where applicable to the relevant Ctrack entity and certification scope, our ISO/IEC 27001:2022 certification demonstrates our commitment to maintaining appropriate information-security management practices.

View Certificate Details