1. Definitions

In this Policy, the terms below have the following meanings:


City Technology Solutions Proprietary Limited, registration number 2018/251213/07, a private company duly registered in accordance with the laws of the Republic of South Africa, with its registered address at 350 Umhlangane Road, River Horse Valley, Durban 4001, together with any subsidiaries or related entities;

Personal Information

information relating to:

· the User, including the race, gender, sex, marital status, family status, national, ethnic or social origin, age, education, language and birth date;

· any identifying number, symbol, e-mail address, physical address, telephone number or other assignment to the User;

· credit card and debit card details (collected for the financial institution handling payments on CTS’s behalf;

· the User’s marketing preferences;

· data about how the User and its PC or device interacts with CTS’s webpages and software, including device, connectivity and configuration data;


this privacy policy between CTS and the User;


as defined in the Protection of Personal Information Act No. 4 of 2013 and “Processing” shall have a corresponding meaning;


means the software licensed by CTS to the Customer, accessed online, downloaded and/or installed onto any IOS, Android or other device, to enable the Customer to track any hardware device installed with the software;


the user of the Website and/or such user’s legal guardian; and


collectively CTS’s website/s, mobile or desktop applications.

2. The General Principles of the Privacy Policy
    • This Privacy Policy covers how CTS treats Personal Information collected electronically when the User uses the Website or the Software, communicates with CTS, registers or applies online for any CTS related products or services.
    • CTS takes issues concerning privacy, data protection, confidentiality and the protection of intellectual property very seriously. CTS understands that confidentiality and privilege are important to every User.
    • When dealing with Personal Information:
      • CTS will only Process Personal Information with consent of the User (acquired through this Policy, elsewhere on the Website or otherwise in relation to the Software), unless CTS is legally required to do so;
      • CTS takes reasonable care to prevent loss of, damage to or unauthorised destruction of Personal Information and unlawful access to or processing of Personal Information; and
      • CTS will use non-identifying/de-personalised data for statistical and research purposes.
    • By using the Website and the Software, registering or applying online for any CTS related products or services, or contacting CTS electronically, the User expressly consents to CTS processing Personal Information for the purposes set out herein, elsewhere on the Website or otherwise in relation to the Software and expressly consents to the further processing of Personal Information by CTS or by third parties (Personal Information will only be shared with third parties to the extent necessary for CTS to offer the services in relation to the Software).
3. Storage of Personal Information
    • Personal Information will be stored in CTS’s databases for as long as the User accesses the Website and/or the Software and for a reasonable time after the User has ceased accessing the Website and/or the Software. If the User chooses to delete its account, Personal Information will be permanently deleted, unless CTS or any third party is required to store such Personal Information in accordance with any law or regulation.
    • The User accepts that CTS may store Personal Information outside of the region or country that the User may submit or use it in.
4. Reasons for Processing Personal Information

The following are some of the reasons why CTS would collect Personal Information:

        • to process the User’s instructions or requests and to personalise and tailor services to meet the needs of the User;
        • to send personalised promotional material or details to the User;
        • to collect, analyse and combine Personal Information for market research, academic research and statistical purposes.
5. Disclosure of Personal Information
    • CTS is not in the business of selling personal information and therefore undertakes not to disclose the User’s Personal Information to anyone except as provided in this Policy.
    • CTS may, for marketing purposes, disclose or transfer a User’s Personal Information to a CTS agency.
    • It may be necessary for CTS to disclose or transfer a User’s Personal Information to suppliers, affiliates, partners or agents in order to provide the User with CTS’s services.
    • CTS shall disclose a User’s Personal Information to its employees, which employees are aware of their confidentiality obligations.
    • CTS will be obliged to disclose a User’s Personal Information in situations where the law requires such disclosure. CTS undertakes to notify the User when this situation occurs.
    • CTS will not sell, rent or provide Personal Information to unauthorised third parties for their use unrelated to the Software, without the User’s consent.
6. Email Inspection
      • CTS shall inspect all emails sent by a User to CTS via the email address(es) provided on the Website. This inspection is undertaken to check for viruses.
      • CTS reserves the right to monitor and inspect all material and information transmitted over its systems.
      • CTS may also monitor whether a User has read emails sent to him/her.
7. Correction and Status of Personal Information
    • If the User wants to update, delete or correct any Personal Information held by CTS, or withdraw its consent for CTS to use its Personal Information, the User may do so on the Website or e-mail CTS for assistance.
    • The User may, at any time, request:
      • CTS to confirm whether or not it holds Personal Information about the User;
      • the record or a description of the Personal Information about the User held by CTS; and
      • information about the identity of all third parties or categories of third parties, who have, or have had, access to the User’s Personal Information.
8. Changes to the Privacy Policy
    • CTS may amend the Privacy Policy from time to time. CTS will notify the User of any material changes within a reasonable time, however, the User should familiarise itself with this Privacy Policy regularly. What constitutes a material change will be determined at CTS’s sole discretion.
    • The current version of the Privacy Policy will govern the respective rights and obligations between the User and CTS each time that the User accesses and uses the Website.
9. Acknowledgement

The User hereby acknowledges that it is aware of the following:

      • the Personal Information being collected;
      • the name and address of CTS ;
      • the purpose for which the Personal Information is being collected;
      • that providing Personal Information is voluntary;
      • failure to provide Personal Information will prevent CTS from being able to offer the User access to the Software;
      • the fact that CTS may store Personal Information outside of the region or country in which the User may submit or use it;
      • the identity of CTS as the recipient of the Personal Information;
      • the nature or category of the Personal Information;
      • the existence of the User’s right of access to and the right to rectify the Personal Information provided by the User;
      • the existence of the right to object to the processing of Personal Information; and
      • the right to lodge a complaint to the Information Regulator at:

        Physical Address: 33 Hoofd Street, Forum lll, 3rd Floor Braampark, Braamfontein, Johannesburg