The Protection of Personal Information Act (POPIA)

Client / User Privacy Protocols Policy


1.    Preamble

The purpose of this policy is to advise the client / user (data subject) of Blackcircles South Africa (BCZA), a division of Sumitomo Rubber South Africa (Pty) Ltd. (SRSA), services, both electronic and otherwise, why data is collected and processed, what data is in focus as well as how it is processed. BCZA is committed to full compliance with the POPI Act insofar as the utilisation and disclosure of data subject Personal Information (PI) is concerned. Hence, technical and operational measures have been put in place to protect data subject privacy and BCZA invites all data subjects and / or requesters to engage with its Information Officer (IO) in respect of any matter related hereto.


2.    Scope of Application

This policy applies to data subjects under the POPI Act and its principles extend to the Promotion of Access to Information Act (PAIA) in respect of requesters of records held by BCZA. PI applies to both natural and juristic persons. Data subjects and requesters are invited to engage with the BCZA IO about any matter pertaining to the POPIA and PAIA, including but not limited to updating PI, deletion of PI, complaints in respect of how PI is being processed and updating consent for electronic direct marketing. The “Information Officer” Portal on the website facilitates these types of engagement.


3.    About Sumitomo Rubber South Africa (Pty) Ltd. 


Sumitomo Rubber South Africa (Pty) Ltd is owned by Japanese listed company Sumitomo Rubber Industries Ltd (SRI), situated in Kobe, Japan. SRI is one of the leading premium manufacturers of automotive tyres and industrial rubber products in the world. The existing South African plant in Ladysmith (founded in 1973) currently produces passenger car, sport utility vehicle, light truck and truck and bus radial tyres, which are sold in South Africa and exported across Africa and other countries. SRI operates four domestic and several overseas tyre factories with plants in Japan, China, Thailand, Indonesia, Brazil, Turkey and Africa. More details in this regard can be obtained in the “About THE COMPANY” link to our website.


4.    About Blackcircles South Africa 


Blackcircles was Founded in 2001 in the United Kingdom, since then it has taken the tyre industry by storm pioneering the way that motorists buy tyres. Blackcircles has now launched a Franchise in South Africa, which is owned by Sumitomo Rubber South Africa (Pty) Ltd. and will be run as a separate division. The South African online tyre shopping platform is dedicated to simplifying the tyre buying process so that consumers can research and purchase tyres, as well as schedule an installation appointment. 


5.    Definition of Personal Information (PI)


‘‘Personal information’’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to: 

(a)     information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person; 

(b)     information relating to the education or the medical, financial, criminal or employment history of the person; 

(c)     any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person; 

(d)     the biometric information of the person; 

(e)     the personal opinions, views or preferences of the person; 

(f)     correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence; 

(g)     the views or opinions of another individual about the person; and 

(h)     the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person;


6.    Purpose of Collecting and Processing Personal Information (PI)


BCZA processes PI for various purposes including for: 

    Engaging in various forms of direct marketing 

    Facilitating transactions with data subjects

    Collecting data for statistical purposes to improve its services

    Fulfilling its contractual obligations to its clients and client contacts

    Complying with the provisions of statute and regulations

    Attending to the legitimate interests of data subjects

    Identifying prospects for enhanced service delivery and business sustainability

    Tracking data subject activity on the website and its links as well as their transactions with BCZA;

-    These BCZA partners who are recipients of PI are business organizations who are permitted to use the information only for lawful sales, marketing, and engagement

-    Confirm and verify data subject identity or to verify that they are authorised users for security purposes;

-    Conduct market or customer satisfaction research

-    Audit and record keeping purposes

-    In connection with legal proceedings.


7.    Lawful Basis


In respect of the processing of PI as provided for above, BCZA will adhere to the conditions for the lawful processing of PI, based on its desire to provide data subjects services in their best interests as well as a legitimate interest of BCZA to achieve its business objectives. 


8.    Period of Holding Personal Information (PI)


BCZA endeavours to provide the most accurate information possible to stakeholders, including data subjects. BCZA seeks to verify the accuracy of its information as frequently as possible and to remove information that it learns to be inaccurate. Thus, BCZA intends to process the information it has about data subjects for so long as it is accurate or until the data subject instructs BCZA to refrain from processing it – in order to instruct BCZA to refrain from collecting and / or processing, please contact us immediately.  

Notwithstanding the above, BCZA shall hold PI for such period as may be required in terms of statutes such as the Companies Act and various labour laws.

9.    Data Subject Rights


Data subjects have the right to request that BCZA provide them with access to their PI, to rectify or correct their personal information, erase PI or restrict the processing of PI, including refraining from sharing it or otherwise providing it to any third parties. Data subjects also have the right to raise complaints with the Information Regulator. The afore-going rights may be subject to certain limitations pursuant to applicable law. In order to access any of these rights, please contact us. 


10.    Sources of Personal Information (PI)


BCZA gathers PI from several sources, which include directly from data subjects, publicly available sources such as websites, social media, commercial transactions with BCZA, referrals, prospects, partner agreements, training engagements, conferences and the like. Given that PI can be extracted and / or obtained from several sources and consolidated into one CRM or other similar systems of record, it may be difficult or impossible to identify the exact source of one particular piece of information. 


11.    Categories of Personal Information (PI) Collected and Processed


BCZA collects information about data subjects who may be clients, client contacts, prospective clients and prospective client contacts. It also collects information on its employees and suppliers as well as third parties that are part of its scope of operation. 


In respect of clients, client contacts, prospective clients and prospective client contacts BCZA profiles business organizations and the contacts who work for the said organisations and it may have some or all of the following categories of personal information on data subjects, historical or current:


    Name and surname

    Identity Number

    Equity, Gender & Disability status

    Contact details (email, mobile)

    Birth date

    Position held and responsibilities

    Areas of interest in respect of BCZA offerings

    Record of services used 

    Email correspondence and attachments

    Organisation details

    Office address

    Office contact details

    Organisation email Address

    Organisation and data subject Social media URL’s

    Other information that is available in the public domain.


We collect and process your personal information mainly to contact data subjects for the purpose of understanding their requirements and delivering services accordingly. Where possible, we will inform data subjects what information they are required to provide to BCZA and what information is optional, as well as the consequences of not providing the said information.

Website usage information may be collected using “cookies” which allows BCZA to collect standard internet visitor usage information.


12.    Use of Cookies


Website usage information may be collected using “cookies” which allows SRSA and BCZA to use digital tools to enhance your user experience by collecting standard internet visitor usage information through the use of cookies/or user tracking.


Cookies are small text files placed on the device that you use to access our websites. These files do not contain your Personal Information but allow us to associate you with a particular device. 


Many websites use cookies and we use cookies to:


    Create a more user-friendly environment for our website visitors/audience.

    Personalise your interactions with our websites, tailor our Services and Platforms/Portals to your interests and needs, and ensure they work on your device.

    Serve advertising that is most relevant to you, limit the number of times you see the same advertisement and measure the effectiveness of the advertisements on our website and other websites/applications, based on your online activities and interests such as the websites and apps you use or content you view, and information we have about you.


13.    Disclosure of Information


BCZA may disclose data subject PI to its service providers who are involved in the delivery of products or services data subjects. BCZA has agreements in place to ensure that it complies with the privacy requirements as required by the POPI Act.


BCZA may also disclose data subject PI:

    Where it has a duty or a right to disclose in terms of law and/ or industry codes;

    Where it believes it is necessary to protect its rights.


14.    Information Security


BCZA is legally obliged to provide adequate systems, technical and operational protection for the PI that it holds and to prevent unauthorized access to as well as prohibited use of PI. BCZA will therefore on a regular basis review its security controls and related processes to ensure that the PI of data subjects remains secure.


BCZA has conducted an impact assessment across all of its functions and used the findings thereof to manage risk optimally as well as to provide iterative improvements on an ongoing basis.


BCZA policies and procedures cover the following aspects:

    Physical security;

    Computer and network security;

    Access to personal information;

    Secure communications;

    Security in contracting out activities or functions;

    Retention and disposal of information;

    Acceptable usage of personal information;

    Governance and regulatory issues;

    Monitoring access and usage of private information;

    Investigating and reacting to security incidents.


BCZA also ensures that it contracts with Operators as required by POPI and it requires appropriate security, privacy and confidentiality obligations of these operators in order to ensure that personal information is kept secure. The same protocols apply to any party to whom BCZA may pass PI on to for the purposes mentioned herein. Please click here to access our contact details.