ZIMBOCASH – Privacy Policy

By accessing and using the ZIMBOCASH website (the “Website”), the ZIMBOCASH platform and any associated services, and the ZIMBOPAY platform and associated services (the ZIMBOCASH Services”), you agree to our privacy policy.  If you do not agree with our privacy policy, please do not use the ZIMBOCASH Services.

The purpose of our privacy policy is to inform you how we use your personal data that we receive from ZIMBOCASH Services.  This privacy policy may be changed, supplemented or updated by the ZIMBOCASH team and/or the ZIMBOPAY team (combined, referred to collectively as the “ZIMBOCASH Team”) at its sole discretion without prior warning. You should check the Website regularly to keep abreast of changes. You confirm your acceptance of this privacy policy as modified, changed, supplemented or updated by us, if you continue to use the ZIMBOCASH Services. If you do not agree to such revised privacy policy you must stop using the ZIMBOCASH Services, links or content contained on the Website.

What is personal data?

Personal data is any information that is associated with an individual person.  By providing us with your personal data, you also consent for us to collect, retain, use and disclose your personal data in accordance with this privacy policy. This privacy policy also applies to any personal data received through correspondence via e-mail or through the “contact” section of the Website.

Why we need your personal data?

We will need certain personal data in order to register you for the ZIMBOCASH Services and in order for you to be able to access and use the ZIMBOCASH Services. If you are registered with us, you give us consent to use your personal data and agree with this privacy policy.  This consent legally allows us to process your personal data. If you do not agree to our use of your personal data in line with this privacy policy, please do not use the ZIMBOCASH Services.

Changes to your personal data

Your personal data may occasionally change.  If it does, you commit to updating the ZIMBOCASH records such that the personal data we hold about you is accurate and up-to-date.  Please use your registration profile, electronic wallet or account to ensure that we have your latest personal data.

What data do we collect?

We may keep a record of your personal data which we will acquire in various ways.  Below are some common ways of how we may come across your personal data.

Information you give us

You may provide us with your personal data any time you use the ZIMBOCASH Services. This includes:

  • Your name and surname
  • Your identity number
  • Your cellphone number
  • Any information that you may provide during any correspondence or feedback with you and the ZIMBOCASH team. This may include any personal data contained in your responses to any surveys in which you may have participated, any market research, reporting of any problems, any complaints that you may have made, personal data provided during correspondence with our customer support or any other correspondence with the ZIMBOCASH team.
  • Personal data that we gather from the use of ZIMBOCASH Services including your usage habit relating to the ZIMBOCASH Services, your method of interaction with the ZIMBOCASH team.
  • Occasionally we may have a presence on certain social media and networking sites. Any personal data you disclose while visiting and interacting with those sites.
  • Any personal data you provide in any correspondence with us, including emails, telephone calls and web queries.
  • Any time you access an electronic wallet, payments service or transfer related to ZIMBOCASH tokens.
  • Transaction information, such as details about purchases you make through the ZIMBOCASH Services, electronic wallet addresses that you use, registrations you make through the Website, and any billing details;
  • Any other personal data that you choose to provide.

Information we get from others.

  • We may obtain your personal data that is publicly available. These could include business networking sites, from organization where you currently work or past employment, any other databases, and any other public platforms.
  • We may from time to time acquire personal data from information brokers in order to understand the profile of the ZIMBOCASH users better, so that we can better understand how to provide a great service to you. You consent to such information being acquired.

Information automatically collected

When you make use of ZIMBOCASH Services, your personal data is automatically collected.  The typical information that we collect includes:

  • Server Log Information:  This includes information such as your login details, your IP address, the date and time that you made use of the ZIMBOCASH Services, the amount of time you spent on the Website, the pages viewed, the time you spent on each of the pages on the Website, websites you visited before and after your visit of the Website and other comparable server log information.
  • Device Information: This would include information about the device you used when accessing the ZIMBOCASH Services, including hardware and software models and versions, the specific operating system, type of browser and other device information.
  • Device Characteristics: Data such as storage space available on your device, upload and download speeds and other key statistics relating to your device.
  • Device Identities: such as device identity numbers, any unique information such as from applications or accounts you may have used, etc.
  • Usage Information: If you use the Website, we may collect metadata about the transactions you make, any files you upload in any way and we will record instances in which you have used your private key to access your electronic profile/wallet and to authenticate transactions.
  • Information obtained from your device settings (if turned on): such as access to your GPS location, camera and photos.
  • Device signals: Data about nearby connection signals such as Wi-Fi points, beacons, cellular phone masts and Bluetooth signals.
  • Networks: Data such as your connection speed, and information of other nearby devices or devices in your network, your cellular operator, your internet service provider, your time zone, your preferred language.
  • Social Media log in: When you log in to your account using your social media profile, we may collect information about the social media account in accordance with their authorisation procedures and information sharing policies.
  • Information Collected by Cookies and other similar technologies: We and our service providers may use various technologies to collect information when you interact with the various ZIMBOCASH interfaces, including cookies and web beacons. Cookies are small data files that are stored on your device when you visit a website, enabling us to collect key data. Web beacons are graphic images placed on a website or email used to monitor behavior of website/email users often used in conjunction with cookies.

How do we use your personal data?

Your personal data may be used in the following way:

  • to operate, maintain, and improve ZIMBOCASH Services;
  • If you use ZIMBOCASH Services, we use your personal data to manage your account, including to communicate with you regarding your account, your preferences and any offers that may be applicable to you;
  • to operate and administer promotions;
  • to respond to any of your queries comments and suggestions and to provide customer service;
  • to send information including any updates, security alerts, notices and support and administrative messages;
  • to send you marketing information and any other communication, including information about products and services offered by us and our partners;
  • to protect the rights, privacy, safety and property of the ZIMBOCASH team and others;
  • to process payments you make via the Website;
  • to detect, investigate and prevent fraudulent transactions or unauthorized or illegal activities;
  • If necessary:
  • to comply with legal requirement,
  • to comply with legal requests and processes, including to respond to requests from public and government authorities,
  • to enforce our privacy policy;
  • to link, connect or combine information about you with other information;
  • for monitoring, analyzing and study services; and
  • carrying out any other purpose or reason for which the personal data was collected.

Sharing of information

We may share your personal data in the following manner:

  • with third-parties or service providers who work withus;
  • any information you share publicly, such as username and content that you post when using interactive parts of the ZIMBOCASH Services such as online forums, social networking or media sites if applicable;
  • in connection with any corporate finance activity such as an internal restructuring, merger, acquisition, sale of business, capital raising, or any other instance where we need to share your personal data as a part of a due diligence or review exercise;
  • in response to a request for information if we become persuaded that we have an unavoidable obligation to provide information in terms of applicable laws, regulations or legal processes;
  • for advertising purposes where we use third-party providers. These providers may require your personal data to better understand their audience;
  • if we discover any anomalies related to your account which requires investigation by a third-party;
  • if we believe you are acting contrary to our Terms and Conditions or this privacy policy, or to protect rights, property and safety of anyone in the ZIMBOCASH team or others; and
  • with third-parties where aggregate personal data is disclosed.

Information you provide publicly

We may make available as part of the ZIMBOCASH Services, information sharing facilities online, such as message boards, chat rooms, key events, etc. When you voluntarily disclose information online, that information becomes publicly available and can be collected and used by others. The ZIMBOCASH team have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal data. By posting your personal data on public online forums, you could be the recipient of unsolicited messages from other parties.

Public blockchain

Blockchain technologies are public databases that cannot be erased. These blockchain technologies use different anonymising processes to conceal the details of transactions. The ZIMBOCASH blockchain will be a public ledger with anonymising hash functions. By using the ZIMBOCASH Services, you acknowledge and accept that:

  1. The ZIMBOCASH blockchain will record transactions using a hash function to anonymise the transaction and once these transactions are recorded by decentralised network nodess, the blockchain transactions cannot be erased. Neither we nor you will be able to delete data relating to the blockchain transactions.
  2. ZIMBOCASH provide no guarantees, express or implied, as to the immutability of the blockchain or the security of the hashing function.

International transfer of data

We may transfer, store or process your personal data that we have collected from you, outside your country of residence, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. You agree to this transfer, storing or processing outside of your country of residence.

Third-party sites and hyperlinks

The ZIMBOCASH Services may contain hyperlinks to third-party websites and domains that may collect personal data about you, including through cookies and/or other technologies. If you access another website through these hyperlinks, you will leave the Website and this privacy policy will no longer be applicable on those third-party websites. You should check the privacy policies of these other websites' and make your own assessment as to whether you are comfortable with their terms. We have no control over their activities and are not responsible for any information that you submit to or is collected by these third-parties.

Email communications with us

As part of our ZIMBOCASH Services, you may occasionally receive email or other communications from us, relating to your use of ZIMBOCASH Services. Communications relating to ZIMBOCASH Services will only be sent for purposes such as service updates, customers service, notifications, and password recovery.

Security of your personal data

Although our intention is to protect your personal data, we cannot guarantee that it will be kept private.  The security of the personal data may be compromised as a result of unauthorised use of ZIMBOCASH Services, hardware or software failure, unauthorised access, disclosure, and other factors. Compromisation in security of personal data may be in the form of loss of personal data, unauthorised access, misuse, disclosure and altercation.

We use various technical and administrative methods to keep the security of your personal data such as firewalls, data encryption, information access authorisation controls.  We cannot ensure that the above safeguards will prohibit unauthorised access to your personal data.

The access to your personal data is restricted to the ZIMBOCASH team, third-party contractors or agents and other third-parties who would require the information to perform various duties.  These parties are bound by their duty of confidentiality and may only access your personal data upon our instructions.

You are accountable for the accuracy of your personal data and the safe-keeping of your password(s), account registration information, private keys and other information related to the security of your private information.  This information should not be shared with third-party.  We cannot assist with any monetary loss suffered by you or the recovery of your private keys.

 EEA Residents legal rights

The data protection law provides the following rights for EEA residents (“Residents”):

  • Data subject access request – Residents may request a copy of personal data that we hold and inspect the personal data to ensure that they are processed lawfully.
  • Residents may request the correction of personal data that we hold about you. This information will be updated once the verification of the new information has been satisfied.
  • If the Resident has successfully objected to the processing of the personal data held by us, if we have processed the personal data unlawfully or in order to comply with the law, the Resident may request for the personal data be erased.  The Resident would no longer be able to make use of ZIMBOCASH Services.
  • When we are relying on a legitimate interest (or those of a third-party) which impacts your fundamental rights and freedoms or your personal data is used for direct marketing purposes, a Resident may object to the processing of their personal data.  Your objection may be overridden if we demonstrate that we have compelling, legitimate grounds to process your information.
  • Residents may request the suspension on us processing of your personal data if
    • Resident wants to ascertain the accuracy of the personal data,
    • Residents do not request the personal data to be erased due to unlawful processing,
    • Where the Resident requires the data held by us to establish, exercise or defend legal claims,
    • Where we are in the process of verifying whether we can override your objection of processing their personal data.
  • Residents may request for their automated personal data to be transferred to a third-party.
  • Residents are able to withdraw their consent at any time.  To the extent possible, we will cease to process your personal data.  Any data that has already been processed before the withdrawal of the consent will be lawful.  Please do not use any of ZIMBOCASH Services once you have withdrawn your consent.
  • The first request to access your personal data will be free of charge.  Any additional requests will incur a reasonable fee.  We could refuse your request should they be excessive and unfounded.

For all requests received, we would perform our verification checks to ensure that your personal data is not disclosed to unauthorised parties.  We may request additional information to fulfil your request.

We will attempt to respond to any genuine requests within two months.  Should we encounter a large volume of requests, this process could take longer.

What personal data is accessible by me?

You can access and delete the cookies via the browser settings.

You may email info@zimbocash.com in order to request a copy of the personal data that we may have collected and retained about you.

Registered members may access their personal data at any time by accessing their account on the Website.  We encourage you to update your personal data so that they are up to date at all times.

Some personal data about you main be retained in order for us to comply with the law, prevent fraud, resolve disputes, analyse information, assist with investigations, troubleshoot and other such functions, as well as, to enforce our Term and Conditions.  As such, if your account is terminated or suspended, we reserve the right to maintain some personal data to prevent re-registration.