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PARTXCHANGE PRIVACY POLICY

Last Updated: [DATE]

PartXchange (Pty) Ltd (“PartXchange”, “we”, “our” or “us”) respects your privacy and is committed to protecting your personal information in accordance with the Protection of Personal Information Act, 4 of 2013 (“POPIA”).

Any person, whether natural or juristic, who provides PartXchange with personal information for the purpose of registering on the PartXchange marketplace, purchasing products, selling products, requesting quotations, obtaining services, making enquiries, participating in promotions, or engaging with PartXchange in any capacity, acknowledges that such personal information may be processed by PartXchange and agrees to the terms of this Privacy Policy.

This Privacy Policy explains how we collect, use, store, disclose and protect your personal information and your rights relating to such information.

Should you elect not to provide personal information required by PartXchange, or withdraw consent for the processing thereof, PartXchange may be unable to provide certain services, facilitate transactions, maintain user accounts, process orders, verify vendors, or otherwise fulfil its obligations to you. In such circumstances, PartXchange shall not be liable for any resulting inability to provide services.

  1. INFORMATION WE COLLECT AND RECEIVE

1.1 Personal Information Processed

PartXchange may collect and process the following personal information:

1.1.1 Full names and surnames;

1.1.2 Company or business names;

1.1.3 Identity numbers, passport numbers, company registration numbers and VAT numbers;

1.1.4 Contact numbers and email addresses;

1.1.5 Physical, postal and delivery addresses;

1.1.6 Banking and payment information;

1.1.7 Vehicle and fleet information where required for parts identification;

1.1.8 Vendor verification information;

1.1.9 Order history, quotation history and transaction records;

1.1.10 Communications between buyers, vendors and PartXchange;

1.1.11 Customer service interactions;

1.1.12 Device information and website usage information; and

1.1.13 Any other information reasonably required to facilitate transactions, verify users, comply with legal obligations or provide marketplace services.

By providing personal information, you acknowledge that the information processed is adequate, relevant and not excessive for the purposes for which it is collected.

1.2 How Personal Information Is Obtained

1.2.1 Information Provided Directly By You

Personal information may be collected when:

1.2.1.1 You register as a buyer or vendor;

1.2.1.2 You submit a quote request;

1.2.1.3 You purchase products through the Platform;

1.2.1.4 You list products for sale;

1.2.1.5 You communicate with our support team;

1.2.1.6 You participate in promotions, surveys or competitions;

1.2.1.7 You subscribe to marketing communications; or

1.2.1.8 You provide information during correspondence with PartXchange.

1.2.2 Information Collected Automatically

When using our website or mobile applications, we may automatically collect:

1.2.2.1 IP addresses;

1.2.2.2 Browser and operating system information;

1.2.2.3 Device identifiers;

1.2.2.4 Website activity and navigation behaviour;

1.2.2.5 Location information where permitted;

1.2.2.6 Cookies and tracking information; and

1.2.2.7 Analytics information relating to usage of the Platform.

  1. PURPOSE FOR WHICH PERSONAL INFORMATION IS PROCESSED

PartXchange processes personal information for the following purposes:

2.1 To create and manage user accounts;

2.2 To verify buyers and vendors;

2.3 To facilitate transactions between buyers and vendors;

2.4 To process payments and refunds;

2.5 To arrange collections and deliveries;

2.6 To provide customer support;

2.7 To investigate disputes, returns and warranty claims;

2.8 To detect and prevent fraud or unlawful activity;

2.9 To comply with legal and regulatory obligations;

2.10 To improve marketplace functionality and user experience;

2.11 To conduct market research and analytics;

2.12 To communicate service-related information;

2.13 To provide marketing communications where legally permissible; and

2.14 To protect PartXchange’s legal rights and interests.

  1. HOW WE SHARE THE INFORMATION WE COLLECT

3.1 PartXchange does not sell personal information to third parties.

3.2 Personal information may be shared with:

3.2.1 Vendors for purposes of order fulfilment;

3.2.2 Buyers where required to complete transactions;

3.2.3 Payment processors and banking institutions;

3.2.4 Courier and logistics providers;

3.2.5 Technology service providers including hosting providers, ERP systems, CRM systems and analytics providers;

3.2.6 Professional advisors including attorneys, auditors and consultants;

3.2.7 Regulatory authorities, law enforcement agencies and courts where required by law; and

3.2.8 Third parties involved in fraud prevention, dispute resolution or debt recovery.

3.3 PartXchange may transfer personal information to cloud-based service providers located outside South Africa provided appropriate safeguards are in place.

  1. YOUR RIGHTS

You have the right to:

4.1 Request access to personal information held by PartXchange;

4.2 Request correction of inaccurate information;

4.3 Request deletion of information where legally permissible;

4.4 Object to the processing of personal information;

4.5 Withdraw consent where processing is based on consent;

4.6 Request information regarding third parties to whom information has been disclosed; and

4.7 Lodge a complaint with the Information Regulator.

  1. COOKIES

PartXchange uses cookies and similar technologies to improve website functionality, enhance user experience and analyse website performance.

Users may disable cookies through browser settings; however, certain website functions may not operate correctly if cookies are disabled.

  1. RETENTION OF PERSONAL INFORMATION

PartXchange retains personal information only for as long as necessary to:

6.1 Fulfil the purposes for which it was collected;

6.2 Comply with legal obligations;

6.3 Resolve disputes;

6.4 Enforce agreements; and

6.5 Meet accounting, taxation and regulatory record-keeping requirements.

  1. INFORMATION SECURITY

PartXchange implements reasonable technical and organisational safeguards to protect personal information, including:

7.1 Secure servers and hosting environments;

7.2 Encryption technologies;

7.3 Access controls and authentication measures;

7.4 Multi-factor authentication where applicable;

7.5 Network monitoring and security controls;

7.6 Regular system updates and vulnerability management; and

7.7 Staff confidentiality obligations.

While PartXchange takes reasonable measures to protect information, no system can guarantee absolute security.

  1. ACCESS TO PERSONAL INFORMATION

Users may request:

8.1 Confirmation of whether PartXchange holds their personal information;

8.2 Access to personal information;

8.3 Details regarding disclosure of personal information;

8.4 Correction of inaccurate information; or

8.5 Deletion of personal information where legally permissible.

Requests must be submitted in writing to the Information Officer.

  1. INFORMATION OFFICER

Information Officer

Luke Swanepoel

Email: privacy@partxchange.co.za

Website: www.partxchange.co.za

  1. INFORMATION REGULATOR

If you believe your rights under POPIA have been infringed, you may lodge a complaint with:

The Information Regulator (South Africa)

JD House 27 Stiemens Street Braamfontein Johannesburg 2001

Email: POPIAComplaints@inforegulator.org.za

Website: www.inforegulator.org.za

  1. CHANGES TO THIS PRIVACY POLICY

PartXchange reserves the right to amend this Privacy Policy from time to time.

Any amendments will be published on the PartXchange website and will become effective upon publication.

Continued use of the Platform after publication of any amendments shall constitute acceptance of the revised Privacy Policy.