1. Introduction
1.1 EcoCash Holdings Limited Zimbabwe (hereafter referred to as ‘ EcoCash’ , ‘ We’ , ‘ Us’ , ‘ Our’ and ‘ Ours’ ) acknowledges that information technology should be at the service of every stakeholder. Information technology development shall take place in the context of international co-operation. Information technology shall not violate human identity, human rights, privacy, individual or public rights.
1.2 EcoCash is therefore committed to protecting your privacy, keeping your information safe and ensuring the security of your personal information. In our efforts to provide you with the most effective products and services, your personal information will be collected, processed lawfully, stored securely and not disclosed unlawfully to any third party.
1.3 Data Protection and Privacy is implemented compliant to requirements listed in List of statutory, regulatory, contractual, and other requirements, and within the framework defined by the following documents:
1.3.1 Zimbabwe National Payment System
1.3.2 International Best Practice frameworks
2. Purpose of the data protection policy.
2.1 We believe that you should always know the data we collect from you and how we use it, as well as maintain adequate control over both. We want to empower you to make the best decisions about the information that is shared with us.
2.2 This Data Protection and Privacy Policy applies worldwide to EcoCash, is based on globally accepted, basic principles on data protection and privacy and ensures adequate level of data protection as prescribed by relevant legal frameworks, including in countries that do not yet have adequate data protection laws.
2.3 Therefore, the purpose Data Protection and Privacy Policy is to give you and our stakeholders guidance and information on how we collect, use, and protect personal information. The privacy notice will tell you:
2.3.1 Why we collect your personal information and how we may process it.
2.3.2 How and when we share your information with third parties.
2.3.3 How we protect your information.
2.3.4 How long we hold onto your information.
2.3.5 Information on your rights.
3. To whom does the policy apply?
3.1 Eco Cash’ s Data Protection and Privacy Policy applies to ‘ You’ , meaning:
3.1.1 All Customers and/or users who are natural persons or living individuals; and
3.1.2 All Customers and/or users who are organizations.
3.1.3 who is or can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to physical, physiological, mental, economic, cultural, or social identity?
3.1.4 All Ecocash employees and job applicants or prospective employees.
3.1.5 All Ecocash suppliers, partners, and service providers.
4. Why do we collect and process your personal information?
4.1 Processing of personal data means any operation or set of operations in relation to such data, whatever the mechanism used, especially the obtaining, recording, organization, retention, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, deletion, or destruction.
4.2 EcoCash collects and processes your personal information for a variety of business purposes. These include, but are not limited to:
4.2.1 Verifying your identity information through publicly available and/or restricted government databases in order to comply with applicable regulatory requirements.
4.2.2 Completing transactions or the processing of products and services that you have accessed from EcoCash or from third parties on our ecommerce platforms.
4.2.3 Responding to your request for service or assistance.
4.2.4 Performing market analysis and research as well as business and operational analysis.
4.2.5 Providing, maintaining, and improving our products and services.
4.2.6 Anticipating and resolving issues and concerns related to our products and services.
4.2.7 Promoting and marketing our products and services which may benefit you and be related to products and services you are currently enjoying; and
4.2.8 Ensuring adherence to legal and regulatory requirements for prevention and detection of fraud and crime.
4.2.9 Carrying out credit checks and credit scoring where you are applying for specific products and/or services with us, and to assess your application and/or eligibility.
4.2.10 Complying with any legal, governmental, or regulatory requirement or for use by our lawyers in connection with any legal proceedings.
4.2.11 Administering any of our access channels including but not limited USSD, mobile applications, chatbots, and websites or web portals
4.3 EcoCash may keep a log of the activities performed by you on our systems, applications, and websites by using various internet techniques such as web cookies, web beacons, server log files, etc. for analytical purposes, for analysis of the agreeableness of various features in accordance with requisite legal requirements. This information may be used to provide you with a better experience on our platforms.
4.4 At any time while you are browsing our websites or accessing our applications, if you do not wish to share information, you may opt out of receiving the cookies from our site by making appropriate changes to your browser privacy or mobile application settings.
4.5 If we do not provide your consent for usage of personal information or you later withdraw your consent for use of the personal information so collected, EcoCash will not be able to provide certain products and services to you.
5. What personal information do we collect?
5.1 EcoCash and its authorized third parties may collect, store and process Personal Information while providing our products, services and while accessing our website and mobile applications.
5.2 Personal data and/or sensitive information collected and held by us may include:
5.2.1 Names of individuals
5.2.2 Postal or living addresses.
5.2.3 Email addresses.
5.2.4 Mobile Phone numbers
5.2.5 Identity card and passport
5.2.6 Date and place of birth.
5.2.7 Identification of relatives
5.2.8 Business reference
5.2.9 Geo-referencing
5.2.10 Occupation
5.2.11 Biometric Data
5.2.12 Racial or Ethnic Origin
5.2.13 Financial information which may include your bank account or debit and credit card details; financial history or other banking information (including information to determine your creditworthiness).
5.2.14 Information contained in supporting documents such as proof of identity or proof of address.
5.3 We may also collect your information from other organizations including credit-reference bureaus, fraud prevention agencies and business directories.
6. Principles we adhere to when managing your personal data.
6.1 The EcoCash Data Protection and Privacy Policy comprises the internationally accepted data privacy principles without replacing the existing national laws. It supplements the national data privacy laws. We rely on the following principles in processing your data:
6.2 Fairness and Lawfulness
6.2.1 When processing personal data, the individual rights of the data subjects are protected. Personal data will be collected and processed in a legal and fair manner.
6.2.2 Collected data shall be adequate, relevant, and not excessive in relation to the purposes for which it is obtained and further processed.
6.2.3 Individual data should be processed upon voluntary consent of the person concerned.
6.3 Restriction to a specific purpose
6.3.1 Personal data will be processed only for the purpose that was defined before the data was collected. Personal data shall be obtained for specified, explicit and legitimate purposes, and shall not subsequently be processed in a manner that is incompatible with those purposes.
6.4 Transparency
6.4.1 Customers will be informed of how his/her data handled. When the data is collected, the customer will be made aware of, or informed of the purpose of data processing and any third parties to whom the data might be transmitted.
6.4.2 Processing of personal data is done after receiving the consent of the customer.
6.5 Confidentiality and Data Security
6.5.1 Personal data is subject to data secrecy. It will be treated as confidential on a personal level and secured with suitable organizational and technical measures to prevent unauthorized access, illegal processing, or distribution, as well as accidental loss, modification, or destruction.
6.6 Data Retention
6.6.1 Personal data shall be retained in a form that allows the identification of the data subjects for a period no longer than is necessary for the purposes for which it was obtained and processed. When we dispose of your personal information, we use reasonable procedures to erase it or render it unreadable/anonymized.
6.7 Data Integrity
6.7.1 Personal data on file must be correct, complete, and up to date. Suitable steps are taken to ensure that inaccurate or incomplete data is updated.
6.8 Consent to Data Processing
6.8.1 Individual data will be processed upon consent of the person concerned. Declarations of consent must be submitted voluntarily. Transmission of personal data to recipients outside or inside EcoCash is subject to the authorization requirements for processing personal data and requires customer consent.
6.9 Processing Security
6.9.1 Personal data will be safeguarded from unauthorized access and unlawful processing or disclosure, as well as accidental loss, modification, or destruction.
7. Processing information of children.
7.1 We will only collect and process the personal information of a child with the consent of the parent/s or legal guardian.
7.2 We may also need to process the information of a child where it is necessary to exercise or defend a right or obligation in law, or where the personal information has been made public by the child with the consent of consent of the parent/s or legal guardian.
8. What are your rights?
8.1 Right to be informed that we are collecting personal data about you.
8.2 Right to access your personal information
8.2.1 You have the right to make a request for a copy of the personal information that EcoCash holds about you (including advertising audience categories and inferred information) as permitted by law.
8.3 Right to correct personal information
8.3.1 You have the right to correct information held about you to ensure it is accurate, relevant, complete, and not excessive.
8.4 Right to object to use of personal information
8.4.1 You have the right to request that we erase your personal data in certain circumstances as permitted by law. However, in instances where the basis for retaining the data is Legal Obligation, you may not be able exercise your right to request deletion.
8.4.2 You have the right to withdraw consent, object to EcoCash processing your personal information, in certain circumstances as permitted by law. However, in instances where the basis for processing is a Legal Obligation, you may not be able exercise your right to object.
8.5 Right to opt-out of marketing messages
8.5.1 EcoCash will not issue targeted marketing to you unless you consent for us to do so. If you no longer want to receive marketing messages from EcoCash, you can choose to opt out at any time using the means made available to you. If you have previously opted in to receive personalized content based on how and where you use our services, you can also opt out at any time.
9. Disclosure of information.
9.1 Any disclosure of your information shall be in accordance with applicable law and regulations. EcoCash shall assess and review each application for information and may decline to grant such information to the requesting party.
9.2 We may share information about you with:
9.2.1 Banks and financial institutions.
9.2.2 Law enforcement agencies, regulatory organizations, courts or other public authorities if we have to, or are authorized to by law.
9.2.3 Law firms, auditors, and insurers.
9.2.4 Third parties as may be required either contractually, by law, or legitimate interest for the processing of products and services from third parties on our platforms.
9.2.5 Where applicable, Anti money laundering agencies, credit bureaus, debt collection agencies or other debt recovery organizations, fraud prevention or business scoring agencies, or other credit scoring agencies
9.3 When sharing your information with recipients in other jurisdictions, we will ensure that they adhere to similar privacy protection requirements as we do – either by law or by legal agreement. We will not sell your information to third parties and will only market to you in line with our legal obligations and your marketing preference, using the communication method you chose.
9.4 Some of your information may be passed on to any person whom you receive mobile money from or send or intend to send mobile money to. Your information may be available to any third party involved in the operation of the mobile money service including EcoCash merchants, channel partners, financial services switch providers and vendors of the EcoCash money transfer technology platform.
9.5 In the event of a merger/acquisition or company reorganization, your personal information may be part of the transferred assets and are likely to be disclosed to the new company.
10. How to contact us.
If you would like to contact us on any topics in this Privacy Policy, or you would want to exercise any of the rights mentioned above, you can contact our Data Protection Office and our privacy team will get back to you.
Ecocash Holdings Zimbabwe Limited
1906 Borrowdale Road
Borrowdale
Harare, Zimbabwe
Email: dpo@ecocashholdings.co.zw
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to expedite our response.
We try to respond to all legitimate requests within reasonable time. Occasionally it could take us longer if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
11 Changes to this policy.
11.1 We reserve the right to modify this Data Privacy Policy as and when required.
11.2 We will post any changes to our Data Protection and Privacy Policy on our website: https: //www.ecocashholdings.co.zw
11.3 We encourage you to check frequently to see the current Data Protection and Privacy Policy to be informed of how EcoCash is committed to protecting your information and providing you with improved products and services to enhance your experience.
11.4 Any amendment or modification to this policy will take effect from the date of notification on the Ecocash website.
12. Statement Effective Date
26thApril 2022