Privacy Policy
ACM Track (Pty) Ltd — Reg: 2004/096921/23 — VAT: 4480234436
Last updated: April 2026 — Aligned with POPIA Amendment Regulations 2025
1. Overview of Information Collection
This Privacy Policy outlines how ACM Track (Pty) Ltd and its associated entities collect, process, use, and protect your personal information. We gather data in various ways, including:
- Online interactions with our website or app
- Telephone communications
- When you use our services or request information
- Data from the ACM Track unit installed in your vehicle (if applicable)
By providing your information or using our services, website, or app, you agree to the terms of this Privacy Policy and consent to the collection, use, and sharing of your personal information as described herein.
If you disagree with any aspect of this Privacy Policy, please refrain from using our website, app, or services, and do not allow the ACM Track unit to be installed in your vehicle.
This Privacy Policy should be read in conjunction with our service terms and conditions available at www.acmtrack.com. Definitions used in this Privacy Policy align with those in our service terms.
Your privacy is important to us. We implement reasonable technical and organisational measures to safeguard your personal information in accordance with this Privacy Policy, the Protection of Personal Information Act 4 of 2013 (“POPIA”), the POPIA Amendment Regulations 2025 (effective 17 April 2025), and all other applicable South African law.
2. Definition of Personal Information
According to POPIA, “personal information” refers to any data related to an identifiable, living natural person and, where applicable, an identifiable existing juristic person, including but not limited to:
- Identifying characteristics such as race, gender, age, marital status, health, religion, and more
- Contact details including email and physical addresses, phone numbers, and identification numbers
- Educational and employment history
- Sensitive information including health status or financial data
- Personal opinions or preferences
- Correspondence of a private nature
- Location data, biometric data, and online identifiers such as IP addresses
3. Lawful Basis for Processing
We only process your personal information where a lawful basis exists under POPIA. We rely on the following lawful bases depending on the nature of the processing activity:
| Processing Activity | Lawful Basis |
|---|---|
| Providing tracking and fleet management services | Performance of contract |
| Sending service-related communications | Performance of contract / Legal obligation |
| Sending marketing communications | Your explicit consent |
| Processing location and vehicle data from installed units | Performance of contract |
| Fraud prevention and system security | Legitimate interest |
| Compliance with SARS, CIPC, or regulatory requirements | Legal obligation |
| Improving our products and services | Legitimate interest |
4. Methods of Information Collection
We gather personal information when you:
- Complete forms on our website or app
- Contact us by telephone, email, WhatsApp, or in person
- Enter into a service agreement with us
- Use our tracking or camera services
- Browse our website (via cookies and analytics tools)
Where possible, we will inform you which information is required and which is optional at the point of collection.
5. Information Collected from the ACM Track Unit
If you have an ACM Track unit installed in your vehicle, we collect location data, speed, route history, driving behaviour events, harsh braking, acceleration, vehicle diagnostics, and related telematics data. This data is processed to deliver the contracted fleet management and tracking services. Some of this processing involves automated analysis of driving behaviour. You have the right to request human review of any automated assessment that significantly affects you — see Section 13 below.
6. Processing, Use, and Disclosure of Your Information
We may process, use, and share your personal information in the following ways:
- To identify you and verify your identity
- To fulfil your requests and deliver contracted services
- To enhance service quality and improve our platform
- To send you service-related communications
- To send marketing communications where you have given explicit consent
- To share with authorised service providers who assist in delivering our services (under data processing agreements)
- To share with law enforcement or regulatory bodies where required by law
- To comply with our legal and regulatory obligations
- To prevent fraud and protect our systems and clients
We do not sell your personal information to any third party under any circumstances.
7. Direct Marketing
We will only send you marketing communications where you have given us explicit, voluntary, and informed consent to do so. Every marketing communication will include a clear and easy opt-out mechanism. You may withdraw your marketing consent at any time by:
- Clicking the unsubscribe link in any marketing email
- Sending an email to info@acmtrack.com with the subject "Opt Out"
- Contacting us by any of the channels listed under the Information Officer section below
Withdrawal of marketing consent does not affect our ability to send you service-related communications required under your contract.
8. Cookies and Website Data
Our website uses cookies and similar tracking technologies. We obtain your specific consent for each category of cookie before placing non-essential cookies on your device. Cookie categories:
Strictly Necessary
Required for the website to function. Cannot be disabled. Includes session management and security cookies. No consent required.
Always activeAnalytics & Performance
Helps us understand how visitors use the site. Includes tools like Google Analytics. Requires your consent.
Consent requiredMarketing & Personalisation
Used to show relevant content and measure campaign performance. Requires your explicit consent.
Consent requiredYou can withdraw or change your cookie consent at any time by clicking “Cookie Preferences” in the footer. Declining non-essential cookies may limit certain website features. Cookie walls are not used — you can access the site regardless of your cookie choices.
9. Data Security
We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, disclosure, or destruction. These measures include encrypted data transmission, access controls, and regular security assessments. While we strive to protect your data, no transmission over the internet is completely secure.
10. Data Breach Notification
In the event of a data breach that is likely to affect your rights and freedoms, we will notify the South African Information Regulator and affected data subjects as required by POPIA. Notification will be made as soon as reasonably possible after discovery of the breach. We maintain an internal breach response procedure and a register of all security incidents.
11. Data Retention
We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Retention periods vary by data category:
| Data Category | Retention Period |
|---|---|
| Client account and contract records | Duration of contract + 5 years |
| Vehicle and telematics data | 12 months rolling (unless otherwise agreed) |
| Financial and invoicing records | 5 years (SARS requirement) |
| Marketing consent records | Until consent is withdrawn + 1 year |
| Website analytics data | 26 months |
When data is no longer required it is securely deleted or anonymised.
12. International Transfers
Where personal information is transferred outside South Africa (for example to cloud service providers), we ensure adequate protection is in place in compliance with section 72 of POPIA. We only transfer data to jurisdictions that provide substantially similar protection to POPIA, or under binding contractual safeguards.
13. Your Nine Rights Under POPIA
1
Right to be Informed
You have the right to know when and why your personal information is being collected before or at the time of collection.
2
Right of Access
You may request confirmation of whether we hold your personal information and obtain a copy of that information.
3
Right to Correction or Deletion
You may request that inaccurate, outdated, or unlawfully collected information be corrected or deleted.
4
Right to Object
You may object to the processing of your personal information on reasonable grounds, including for direct marketing purposes.
5
Right to Withdraw Consent
You may withdraw consent to processing at any time. Withdrawal may take up to 10–15 business days to take effect.
6
Right to Restrict Processing
You may request that we limit how we use your personal information in certain circumstances while a dispute is being resolved.
7
Right to Data Portability
You may request your personal information in a structured, commonly used format where technically feasible.
8
Right to Lodge a Complaint
You have the right to lodge a complaint with the South African Information Regulator if you believe your rights have been violated.
9
Right to Opt Out of Automated Decision-Making
You have the right to request human review of any decision made solely through automated processing that significantly affects you, including automated driving behaviour assessments.
14. How to Exercise Your Rights
In accordance with the POPIA Amendment Regulations 2025, you may submit requests to exercise any of the above rights through any of the following channels at no charge:
- Email: info@acmtrack.com
- Phone: 010 594 0607
- WhatsApp: 060 330 4683
- In person: 1 Carlbert Close, Sundowner, Randburg, RSA
- Post: PostNet Suite 74, Private Bag X8, North Riding, 2162, JHB, RSA
Proof of identity may be required before we process your request. We will respond within a reasonable timeframe. For correction or deletion requests, changes may take up to 15 business days to reflect. Some information may be retained as required by law. Deletion of certain data may terminate our service relationship where that data is essential to delivering contracted services.
15. Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be communicated via our website and where appropriate by direct notification. The updated version supersedes all previous versions. It is your responsibility to review this policy regularly. The current version date is shown at the top of this page.
16. Information Regulator (South Africa)
If you wish to raise a complaint with the statutory authority:
17. Information Officer
ACM Track (Pty) Ltd has appointed a registered Information Officer in accordance with section 55 of POPIA. Our Information Officer is registered with the South African Information Regulator via the BizPortal as required by the POPIA Amendment Regulations 2025.
For all privacy-related queries, access requests, or complaints contact our Information Officer: