Privacy Policy - Lifenity Zimbabwe

1. Purpose and Scope

Lifenity Zimbabwe ("we", "our" or "us") respects your privacy and is committed to protecting the personal data of visitors, supporters, volunteers, partners, beneficiaries, donors and other users of this website. This Privacy Policy explains how we collect, use, store, share, protect, retain and delete personal data, and the choices and rights available to you when you access or use https://lifenity.co.zw/ (the "Website").

This Policy applies only to personal data collected through this Website. It does not govern personal data collected through offline interactions, events, programmes, volunteer activities, beneficiary services, donations or other channels, which may be covered by separate notices presented when that data is collected.

This Policy is not itself a blanket consent. Where consent is required, we will request it through a clear affirmative action, for a specific purpose and for the specific data involved.

2. Identity of the Data Controller

Lifenity Zimbabwe determines the purposes and means of processing personal data collected through this Website. Where a service provider processes personal data on our behalf, it acts on our documented instructions and is subject to appropriate safeguards.

Organisation: Lifenity Zimbabwe

Registered office: Pan Africa Health and Wellness Pvt Ltd, Ground Floor, Stand No. 1819, 29 Mazowe Street, Avenues, Harare, Zimbabwe.

3. Applicable Legal Framework

This Policy is intended to support compliance with applicable Zimbabwean data-protection and privacy laws, including the Cyber and Data Protection Act [Chapter 12:07] and applicable regulations. Other applicable laws relating to tax, accounting, audit and business operations may also apply.

Where personal data is processed in another jurisdiction or another jurisdiction's laws apply, we will comply with the relevant legal requirements. If a legal requirement provides a higher standard of protection or requires longer retention of a particular record, that requirement will prevail for that record.

4. Personal Data We Collect

4.1 Information You Submit

When you submit a request through the Book an Appointment form on the Website, we may collect:

• First name;
• Last name;
• Mobile number;
• Email address;
• Appointment date; and
• Appointment time.

The appointment form may provide fields for first name, last name, mobile number, email address, appointment date and appointment time. Providing this information is voluntary; however, if you do not provide certain information, we may not be able to process your appointment request or respond to your enquiry.

4.2 Information Collected Automatically

When you visit the Website, certain technical information may be collected automatically, such as IP address, browser type, device information, date and time of access, pages visited, referring URLs and similar usage information needed for operation, security, performance monitoring and analytics.

4.3 Information About Another Person

If you give us personal data about another individual, you must have lawful authority to do so and must provide any notice or obtain any consent required by law.

5. How We Use Your Information

We use personal data and technical information collected through the Website to:

• Respond to enquiries, requests and communications submitted through the Website;
• Process and manage appointment requests;
• Communicate with visitors, supporters, volunteers, partners, beneficiaries and other stakeholders about the activities and initiatives of Lifenity Zimbabwe;
• Understand and address enquiries, feedback and requests;
• Administer, operate, maintain and improve the Website and its functionality;
• Monitor Website performance, security and user experience, and conduct analytics; and
• Maintain appropriate administrative, operational and organisational records.

We may also use aggregated or anonymised information for statistical, analytical, reporting and organisational purposes where it does not identify an individual.

6. Lawful Grounds and Consent

We process personal data on the basis of consent or another lawful ground available under applicable law. Depending on the circumstances, processing may be necessary to respond to your request, manage an appointment, provide a requested service, protect legitimate interests or comply with applicable law.

Where consent is used, the request will be presented in clear language and will identify the personal data and purpose. Consent will be obtained in the manner required by applicable law. Optional purposes, such as promotional communications or non-essential analytics, should not be bundled with consent required to provide a requested service.

You may withdraw consent using the same or a comparably easy method where applicable. Withdrawal does not affect processing lawfully performed before withdrawal. We and our service providers will cease consent-based processing within the period required by applicable law unless continued processing is otherwise authorised or required by law.

7. Cookies and Similar Technologies

The Website may use essential cookies for authentication, session continuity, security and user preferences. It may also use cookies, web beacons, pixels, analytics tools and similar technologies to improve Website functionality, analyse traffic, measure performance, detect suspicious activity and troubleshoot technical issues.

You may configure your browser to reject, block or restrict cookies. Disabling certain cookies may affect some Website features. Non-essential cookies will be used in accordance with applicable law and the consent choices made available to you.

The Website may use third-party technologies, including Google services such as Google Maps and Google Tag Manager, analytics tools and embedded content. These third parties may collect, process or store information under their own privacy policies and terms. We encourage you to review those policies.

8. Sharing and Disclosure

We do not sell, rent or trade personal data collected through the Website. We share personal data only where reasonably necessary for the purposes in this Policy, with:

• Authorised employees, representatives and personnel of Lifenity Zimbabwe;
• Technology partners, service providers, hosting providers and website maintenance providers;
• Analytics, communication and IT service providers;
• Contractors, consultants, auditors and other professional advisers;
• Government authorities, regulators or law enforcement agencies where required or permitted by law; and
• Other persons where disclosure is reasonably necessary to establish, exercise or defend legal rights, respond to legal process, or investigate suspected fraud or unlawful activity.

Where a service provider processes data on our behalf, we take reasonable steps, including contractual measures where appropriate, to ensure suitable confidentiality, security and data-protection safeguards. Access is limited to personnel with a legitimate operational or legal need.

We may disclose information to comply with legal, regulatory, governmental or administrative requirements, respond to legal processes, investigate suspected fraud or unlawful activity, or establish, exercise or defend legal rights.

We do not disclose personal information to third parties except as described in this Policy or as otherwise required or permitted by applicable law.

9. Cross-Border Processing

Personal data may be processed outside Zimbabwe where our approved service providers, including hosting, communication or Google service providers, operate. Where personal data is transferred across borders, we will comply with applicable legal restrictions and use appropriate contractual, technical and organisational safeguards as required by law.

10. Information Security

We implement reasonable administrative, technical, organisational and physical safeguards designed to protect personal information processed through the Website against unauthorised access, disclosure, alteration, misuse, loss, destruction or other unauthorised processing.

While we take reasonable steps to safeguard information, no website, internet transmission, electronic communication or information storage system can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of information transmitted to, through or stored on the Website.

Users should also take appropriate precautions to protect their own information when communicating with us electronically.

11. Personal Data Breach Management

We will investigate, contain, document and remediate suspected personal data breaches. Where required by applicable law, we will notify the relevant supervisory or regulatory authority and affected individuals within the prescribed timelines and in the required manner. Notifications may describe the nature and extent of the breach, its likely consequences, mitigation measures taken, protective steps you can take and a contact person.

12. Data Accuracy

We take reasonable steps to keep personal data complete, accurate and consistent where it is likely to be used to make a decision affecting you or to be disclosed to another organisation. Please provide accurate information and tell us promptly if your contact details change.

13. Data Retention and Erasure

We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including:

• Responding to enquiries, requests and communications;
• Processing and managing appointment requests;
• Providing requested information or assistance;
• Maintaining administrative, operational, financial and organisational records;
• Monitoring and improving Website performance and security;
• Complying with legal, regulatory, tax, audit, accounting or governmental requirements; and
• Establishing, exercising or defending legal rights, and resolving disputes, complaints or investigations.

When the purpose is no longer served, consent is withdrawn or a valid erasure request is accepted, we will erase or anonymise the relevant personal data and instruct our service providers to do the same where appropriate, unless retention is necessary for the specified purpose or required by law. Backup copies may remain until overwritten in the ordinary backup cycle.

14. Children's Privacy

Our Website is intended for individuals, supporters, volunteers, partners, beneficiaries, donors and other persons interested in the activities and initiatives of Lifenity Zimbabwe. The Website is not specifically directed towards children.

We do not knowingly collect personal information from children in a manner prohibited by applicable law.

If we become aware that personal information relating to a child has been collected through the Website in circumstances where such collection is not permitted, we may take reasonable steps to delete, anonymise or otherwise appropriately handle that information in accordance with applicable legal requirements.

Any person who believes that a child has provided personal information through the Website may contact us using the contact details in this Policy so that appropriate action may be taken.

15. Rights of Data Subjects

Subject to applicable law, exemptions and identity verification, you may have the right to:

• Request access to personal data we hold about you;
• Request information about how your personal data is processed;
• Request correction of inaccurate or incomplete personal data;
• Request deletion or erasure where permitted by law;
• Withdraw consent where consent is the basis for processing;
• Object to or restrict certain processing where applicable;
• Submit a complaint or grievance about our processing of your personal data; and
• Exercise any additional rights available under applicable data-protection law.

We may ask for information reasonably necessary to verify your identity and authority. We will not disclose information that would adversely affect another person's rights, compromise security or conflict with law. The availability and scope of these rights depend on applicable law.

16. How to Exercise Your Rights

You may submit a request by emailing Connectus.zim@lifenity.ae or writing to the address in Section 18. Please state your request clearly and provide enough detail for us to identify the personal data concerned. We may request additional information to verify your identity. If we process personal data only on behalf of another organisation, we may forward your request to that organisation or ask you to contact it directly.

17. Duties of Users

When using the Website, you must comply with applicable law; must not impersonate another person; must not provide false or misleading identity or contact details; must not submit false or frivolous grievances; and must provide authentic information when requesting correction or erasure. You must not submit another person's information without lawful authority.

18. Grievance Redressal and Contact Details

Privacy questions, consent withdrawal requests, security concerns and grievances may be submitted using the contact details below. We will acknowledge and address grievances within the period required by applicable law and our published grievance procedure.

You may first contact us through the grievance mechanism described above. Where a complaint remains unresolved, you may contact the relevant data-protection supervisory authority or seek other remedies available under applicable law in Zimbabwe.

19. Third-Party Websites and Services

The Website may contain links to or integrations with third-party websites, social media platforms, government websites, service providers, embedded content or other external services. We are not responsible for their privacy practices, security or content. Please review their privacy policies before providing personal data to them.

20. Changes to This Policy

We may update this Policy to reflect changes in Website functionality, data-processing practices, security requirements, applicable law or government policy. The revised Policy will be published on this page and will show its effective date and last-updated date. Where a material change affects the purpose of processing or your rights, we will give appropriate notice through the Website or by email and obtain fresh consent where required.

21. Governing Law

This Policy is governed by the applicable laws of Zimbabwe, without prejudice to any mandatory data-protection requirements that may apply in other relevant jurisdictions. Any complaint or dispute remains subject to the statutory rights and remedies available under applicable data-protection and other laws. The competent courts of Zimbabwe will have jurisdiction, subject to applicable law.