1. Who We Are
Your personal information is collected by THUNDERLINES, Lda., trading as luum. digital, Portuguese tax number 516424939, with its registered office at Rua Jaime Moniz, n.º 12, Edifício Krypton III, Bloco 1, R/C A, 9060-343 Funchal, Portugal ("luum. digital", "we", "us").
luum. digital collects your information as an operator on behalf of ROUTE 53 VENTURES (Pty) Ltd, trading as stolencars.co.za, email: [email protected], website: stolencars.co.za (the "Company").
The Company is the responsible party for your personal information. It decides why and how your information is processed, is responsible for complying with the law, and will contact you about your car insurance request. Your information is shared by luum. digital only with the Company.
To give you a quote, the Company may pass your request on to the licensed insurance providers it works with, such as King Price, MiWay, Santam, Dial Direct and Budget Insurance, under its own privacy policy. luum. digital does not sell, share or pass on your information to anyone else.
2. Applicable Law
Your personal information is processed in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA"). Because luum. digital is based in the European Union, our processing is also subject to the General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR").
We process your personal information lawfully and reasonably, only for the specific purposes described in this Policy, limited to what is necessary, kept accurate and up to date, kept secure, and retained only for as long as needed.
3. Information We Collect
With your consent, we collect:
- Identity and contact details: first name and surname, mobile phone number and email address.
- Information about your request: whether you own a car, your car's brand, model and year, whether you currently have car insurance and your current insurer.
- Profile information: your age range and income range, so that you can be offered suitable quotes.
- Technical information: IP address, browser and device type, operating system, pages visited, and the date and time of your visit.
- Consent record: the date, time, IP address, page and version of the consent text you accepted, as described in section 8.
If you complete a Meta (Facebook or Instagram) lead form, we receive from Meta the information you entered in that form.
4. Why We Use Your Information
We use your information to:
- pass your request to the Company so that it, or the licensed insurance providers it works with, can contact you by phone, SMS or email with car insurance quotes and information about their products and services;
- automatically check, before passing on your request, that your phone number and email address are valid;
- record and prove your consent;
- prevent fraud, fake submissions and misuse of the form.
We process your information on the basis of your consent (POPIA section 11(1)(a) and section 69; GDPR article 6(1)(a)). Recording your consent and preventing fraud are also based on our legitimate interest in demonstrating compliance and protecting the form against misuse.
The automatic check of your phone number and email only confirms that they exist. No decision that has legal or similarly significant effects on you is made solely by automated means.
5. Who We Share Your Information With
- The Company, identified in section 1, as the responsible party.
- Licensed insurance providers that the Company works with, to give you a quote, under the Company's privacy policy.
- Service providers acting as our operators, such as hosting, phone and email verification, consent recording, CRM and lead delivery providers. They are contractually bound to process your information only on our instructions and to keep it secure.
- Meta Platforms Ireland Limited, when you use Meta lead forms or accept Meta cookies, under Meta's privacy policy.
- Regulators and authorities, where required by law.
Access to your information is limited to authorised staff of these parties.
6. Cross-Border Transfers
luum. digital is based in Portugal, so your information is transferred to and processed in the European Union before it is delivered to the Company in South Africa. The European Union has data protection laws, including the GDPR, that provide an adequate level of protection as required by section 72 of POPIA. Some platforms we use, such as Meta, may process information in other countries under their own legal safeguards.
7. How Long We Keep Your Information
luum. digital keeps your information for 6 months after it is collected. Once delivered, the Company keeps quote request data for 12 months, in accordance with its own privacy policy.
If you withdraw your consent, your information is deleted sooner, except for the record of your consent and your opt-out, which we keep for as long as needed to demonstrate compliance and to respect your opt-out.
8. Record of Your Consent
To prove that you gave your consent, we record the date and time you submitted the form, your IP address, the page, and the version of the consent text and this Policy that you accepted. This record may be shared with the Company to show that it was allowed to contact you.
9. Cookies
This site uses cookies that are necessary for it to work. With your consent, it also uses analytics and advertising cookies, including the Meta Pixel, to measure and improve our campaigns. These may record your IP address, browser type, pages visited, and the date and time of your visit. You can accept, refuse or withdraw consent to non-essential cookies at any time through the cookie banner or your browser settings.
10. Minimum Age
By accepting this Policy, you confirm that you are 18 years of age or older. We do not knowingly collect information from children. If we learn that we have, we will delete it.
11. Your Rights
Under POPIA, you have the right to:
- ask whether we hold personal information about you and request access to it;
- ask for your information to be corrected or deleted if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained;
- object to the processing of your information, including at any time to direct marketing;
- withdraw your consent at any time, without affecting processing that took place before you withdrew it;
- be notified if your information has been accessed or acquired by an unauthorised person;
- lodge a complaint with the Information Regulator (South Africa), at www.inforegulator.org.za.
To exercise these rights, contact the Company's Information Officer at [email protected], or luum. digital at [email protected]. We may ask you for information to confirm your identity.
12. How to Stop Being Contacted
You can stop being contacted at any time by telling the person who contacts you, replying STOP to an SMS, using the unsubscribe link in any email, or emailing [email protected] or [email protected]. Every marketing message from the Company will include a way to opt out.
13. Security
We use appropriate technical and organisational measures to protect your information against loss, damage, unauthorised destruction and unlawful access or processing. If your information is compromised, you and the Information Regulator will be notified as required by section 22 of POPIA.
14. Changes to This Policy
We may update this Policy from time to time, for example because of changes in the law. The current version is always available on this page.
15. Contact Details
Responsible party
ROUTE 53 VENTURES (Pty) Ltd (stolencars.co.za)
Information Officer email: [email protected]
Website: stolencars.co.za
Privacy policy: stolencars.co.za/privacy-policy-2/
Operator
THUNDERLINES, Lda. (luum. digital)
Tax number (Portugal): 516424939
Address: Rua Jaime Moniz, n.º 12, Edifício Krypton III, Bloco 1, R/C A, 9060-343 Funchal, Portugal
Email: [email protected]