Privacy Policy

Last Updated: 08/09/2025

Introduction
This policy outlines our organization’s approach to the collection, use, storage, and protection of personal data. It provides guidance on how we ensure that personal information is handled in a lawful, transparent and secure manner in line with applicable data protection laws and best practices.

Objectives
The specific objectives of this Privacy Policy / Privacy Notice are to:

  • Define the types of personal data we collect from data subjects (e.g. customers, partners and other stakeholders);
  • Ensure transparency in how personal data is collected, processed, stored, shared and retained;
  • Communicate the lawful basis for processing personal data in our organization;
  • Inform data subjects of their data protection rights and the mechanisms available to exercise those rights;
  • Promote responsible and ethical handling of personal information by all employees and third parties acting on our behalf;
  • Demonstrate our commitment to respecting privacy and upholding data protection principles in all our business activities.

Definitions
For the purposes of this policy:

  • Personal Data means any information relating to an identified or identifiable individual (data subject).
  • Data Processing refers to any operation performed on personal data, including collection, recording, storage, use, sharing or deletion.
  • Data Subject is any individual whose personal data is being processed by the organization.
  • Data Controller means the organization that determines the purposes and means of processing personal data.
  • Third Party means any individual or entity acting outside the organization, including service providers and business partners.

Categories of Personal Data Collected
We may collect and process the following categories of personal data (as relevant to the nature of our services and operations):

  • Identification data (e.g. name, national ID, passport number);
  • Contact information (e.g. address, phone number, email address);
  • Employment and professional information (e.g. job title, employer, CV information);
  • Financial and transactional information (e.g. bank account details, payment history);
  • Technical information (e.g. IP address, device information, website usage data);
  • Any other information relevant to the purpose for which it was collected.

Lawful Basis for Processing
We process personal data only where at least one of the following legal bases applies:

  • The data subject has given consent;
  • The processing is necessary for the performance of a contract or to take steps prior to entering into a contract;
  • The processing is necessary to comply with a legal obligation;
  • The processing is necessary to protect the vital interests of the data subject or another person;
  • The processing is necessary for the performance of a task carried out in the public interest;
  • The processing is necessary for the purposes of the organization’s legitimate interests.

How We Collect Personal Data
Personal data may be collected through the following channels:

  • Direct interactions with individuals (in person, via email, telephone or online forms);
  • Automated means (e.g. website cookies, access logs, monitoring tools);
  • Third-party service providers and business partners (where lawfully shared).

Purpose of Data Processing / Use of Personal Data
We process personal data for the following purposes (as applicable):

  • Provision and administration of our services and products;
  • Customer relationship management and communication;
  • Compliance with legal and regulatory requirements;
  • Management of contracts and business operations;
  • Security and fraud prevention;
  • Marketing and promotional communication (where consent has been obtained).

Data Sharing and Disclosure
Personal data may be shared internally within the organization on a need-to-know basis.
We may also share personal data with authorized third-parties such as service providers, regulatory authorities and business partners, but only where it is lawful, necessary and subject to appropriate data protection safeguards.

Data Retention
Personal data will be retained only for as long as it is necessary to fulfil the purpose for which it was collected, or as required by applicable laws and regulations. When personal data is no longer required, it will be securely deleted.

Data Subject Rights
Data subjects have the following rights (subject to the applicable legal requirements):

  • The right to access their personal data;
  • The right to request rectification of inaccurate or incomplete data;
  • The right to request erasure of personal data (“right to be forgotten”);
  • The right to restrict or object to data processing;
  • The right to withdraw consent (where consent is the lawful basis for processing).

Data Security
We implement appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. These measures include access controls, encryption, secure storage, regular audits and employee awareness training.

Data Breach Notification
In the event of a confirmed data breach, the organization will investigate the incident and implement containment measures. Where required by law, affected data subjects and the relevant supervisory authority will be notified without undue delay.

Contact Information
If you have any questions, concerns or requests regarding this Privacy Policy / Privacy Notice or the way your personal data is processed, please contact us on:

Email: privacy@adept.co.zw

Phone: 263-242-257324/5