Privacy Policy
ZIMPLOW HOLDINGS LIMITED PRIVACY STATEMENT
1. Overview
This Privacy Statement (the “Statement”) is provided by ZIMPLOW HOLDINGS LIMITED for itself and on behalf of its subsidiaries and affiliates. ZIMPLOW HOLDINGS LIMITED is the ultimate controller of personal information or data that is placed on its website inclusive of that of its business units in line with their respective business operations. The General Statement is applicable in any jurisdiction, region, or location. The Region Statements address any additional requirements under the Cyber & Data Protection Act [Chapter 12:07]. In the event of any conflict between the provisions of this Statement and a Region Statement, the applicable terms of the Region Statement shall prevail.
2. Scope of this Statement
This Statement governs the manner in which ZIMPLOW HOLDINGS LIMITED will obtain and process Personal Information about all its external stakeholders. We encourage you to read this Statement carefully and to regularly check this page to review any amendments that may be done in relation to the terms of this Statement.
Please note that this Statement does not apply to the processing by ZIMPLOW HOLDINGS LIMITED of the Personal Information of ZIMPLOW HOLDINGS LIMITED relating to both fixed term contract and permanent employees, students on attachment, or other staff members under the employ of ZIMPLOW HOLDINGS LIMITED at any given time (collectively, “ZIMPLOW HOLDINGS LIMITED Staff”). Separate regional Privacy Statements governing such processing are available to ZIMPLOW HOLDINGS LIMITED Staff members for this purpose.
ZIMPLOW HOLDINGS LIMITED has a separate Statement governing the processing machine data ( information automatically generated by software, devices, or systems without human input) . Should there be any conflict between the terms of this Statement and the Machine Data Statement regarding the Processing of personal Information, then the terms of this Statement shall prevail in respect of any such conflicts.
3. Protection of your Personal Information
ZIMPLOW HOLDINGS LIMITED is committed to processing your Personal Information securely. The Group has put in place the requisite Personal Information processing practices and appropriate organisational security measures, in order to protect our valued external stakeholders against unauthorised access, alteration, disclosure or destruction of Personal Information. However, the internet is not a secure environment and we cannot provide an absolute assurance that any Personal Information transferred using the internet will be completely secure at all material times. Transmission of Personal Information over the internet is at your own risk, and you should only use secure systems to access Zimplow Holdings Limited Sites, Apps or Devices.
You shall be responsible for keeping your access credentials for each Zimplow Holdings Limited Site, App and Device safe and confidential and should frequently change them. You should immediately change your access credentials and notify ZIMPLOW HOLDINGS LIMITED promptly if you become aware of any misuse.
4. Contact details
If you have any questions about this Privacy Statement, our processing of your Personal Information, or your dealings with a Site, an App or a Device, please contact us at:
08677007183 / 0717606821 or alternatively
info@zimplow.co.zw
Once you contact us, we shall investigate and resolve each query or complaint within seventy – two (72) hours or such other period as may be required under the Cyber and Data Protection Act Chapter [12:07] or any other applicable laws.
5. ZIMPLOW HOLDINGS LIMITED may collect Personal Information from you
ZIMPLOW HOLDINGS LIMITED may collect Personal Information from you in the following circumstances:
• ZIMPLOW HOLDINGS LIMITED may collect or obtain Personal Information when you participate in activities such as: marketing events, fairs, product demonstrations, roadshows, product promotions and competitions.
• ZIMPLOW HOLDINGS LIMITED may collect or obtain Personal Information when you visit any ZIMPLOW HOLDINGS LIMITED website (each a “Site”) or use any features or online resources available on or through a Site. When you visit the Zimplow websiite, your device and browser will automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, volume of data transferred, dates and times of connecting to a Site and other technical communications information) some or all of which may constitute Personal Information.
• ZIMPLOW HOLDINGS LIMITED may collect or obtain Personal Information when you download or use a ZIMPLOW HOLDINGS LIMITED mobile app (each an “App”). ZIMPLOW HOLDINGS LIMITED Apps may record certain information (including App usage statistics, device type, operating system, App settings, IP address, language settings, dates and times of connecting to the App, location data, and other technical communications information), some or all of which may constitute Personal Information. An Application may have its own Privacy Statement, which includes more specific information, and you should review before using the relevant App.
• ZIMPLOW HOLDINGS LIMITED may collect or obtain Personal Information when you register to use any service provided by ZIMPLOW HOLDINGS LIMITED via a Site or an App or log in to a Site or an App, including the following: registration details, login name, email address, password, security question and, if applicable, payment details.
• ZIMPLOW HOLDINGS LIMITED may collect or obtain Personal Information when you use any ZIMPLOW HOLDINGS LIMITED telemetry devices or data recording devices (each a “Device”), including the following: (i) If you purchase a vehicle that is equipped with a Device, ZIMPLOW HOLDINGS LIMITED may collect Machine Data about the vehicle; and (ii) if you have enabled location-based functions, ZIMPLOW HOLDINGS LIMITED may collect location data. Furthermore, ZIMPLOW HOLDINGS LIMITED may collect Machine Data when performing inspections, warranties or other services.
• ZIMPLOW HOLDINGS LIMITED may collect or obtain Personal Information when you contact ZIMPLOW HOLDINGS LIMITED (whether in person, by mail, by phone, online, via electronic communication such as web forms, live chat, chatbots, vehicle configurators or other means).
• ZIMPLOW HOLDINGS LIMITED may collect or obtain Personal Information when you visit an ZIMPLOW HOLDINGS LIMITED site as part of ZIMPLOW HOLDINGS LIMITED ’s visitor management.
• ZIMPLOW HOLDINGS LIMITED may use video surveillance on its premises and facilities that may capture you if you visit our premises or facilities. We also may take pictures and videos from customer events.
• ZIMPLOW HOLDINGS LIMITED may use video surveillance on its test vehicles, in particular for testing and improving autonomous operation functionality.
• ZIMPLOW HOLDINGS LIMITED may collect or obtain Personal Information that you choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you post publicly about us).
6. ZIMPLOW HOLDINGS LIMITED may receive Personal Information about you from others
ZIMPLOW HOLDINGS LIMITED may receive Personal Information about you from third parties. For example:
• ZIMPLOW HOLDINGS LIMITED may receive Personal Information about you when you provide Personal Information to an ZIMPLOW HOLDINGS LIMITED authorized distributor, dealer or reseller (collectively, “Dealer”) (whether in person, by email, by phone, online, via any other electronic communication or by any other means).
• If you provide your information to a third-party supplier of services to ZIMPLOW HOLDINGS LIMITED, in accordance with that third-party suppliers’ applicable Privacy Statement.
• If you choose to make a payment directly to ZIMPLOW HOLDINGS LIMITED or through a Site, an App, or a Dealer, ZIMPLOW HOLDINGS LIMITED may receive Personal Information about you from third parties, such as payment services providers, for the purposes of that payment, including the following: purchase details, payment data, credit card data.
• To the extent that any credit reference checks/due diligence are carried out by ZIMPLOW HOLDINGS LIMITED or on its behalf in connection with an application for credit, in accordance with Applicable Laws, ZIMPLOW HOLDINGS LIMITED and/or the relevant Dealer may receive Personal Information about you from credit reference agencies and other third parties, for the purposes of that credit check or due diligence, including the following: confirmation of whether the reference agency was able to verify your personal details and the results of the reference check including your credit rating.
• In compliance with its obligations under applicable Laws, ZIMPLOW HOLDINGS LIMITED may receive and/or transmit Personal Information about you in relation to law enforcement agencies, various regulatory bodies and/or public authorities.
• ZIMPLOW HOLDINGS LIMITED may receive Personal Information about you from public sources (such as telephone directories, land ownership records, lien records -official document that shows a legal claim against property or assets , etc.).
• If you interact with any third-party content or advertising on a Site or in an App (including third-party plugins and cookies), ZIMPLOW HOLDINGS LIMITED may receive Personal Information about you from the relevant third-party provider of that content or advertising, in accordance with that third party’s applicable Privacy Statement.
• ZIMPLOW HOLDINGS LIMITED also purchases data from data resellers. The third-party data resellers may share your data with ZIMPLOW HOLDINGS LIMITED based on the permission you have given them, or they may also share any publicly available data that is collected by them.
7. Personal Information you provide about others
In some circumstances, you may provide ZIMPLOW HOLDINGS LIMITED with Personal Information about third parties. For example, you might mention another ZIMPLOW HOLDINGS LIMITED customer when commenting on an ZIMPLOW HOLDINGS LIMITED product. Whenever you provide any such Personal Information, you must ensure that this does not violate those third parties’ rights. If you are unsure whether the third party agrees with you providing its Personal Information, please refrain from communicating such Personal Information to ZIMPLOW HOLDINGS LIMITED.
8. Personal Information of children
We do not generally collect or further process Personal Information of children under 18 years of age. Parents or legal guardians of this category of children shall assist us by supervising the activities of children in relation to our Sites, Apps and Devices and by not allowing them to submit any Personal Information through our Site, App or Device.
When Personal Information of children is collected or processed, we seek the involvement and consent of parents or legal guardians in accordance with Applicable Laws in the processing of such personal information.
9. Disclosure of Your Personal Information
We will not sell, trade, or rent your Personal Information for monetary compensation. We may, however, share or disclose your Personal Information to third parties in the following circumstances:
• We may share or disclose your Personal Information with recipients within ZIMPLOW HOLDINGS LIMITED for the purposes of operating our business, Sites, Apps or Devices, providing you with products or services you have selected, or otherwise for the purposes set out in this Statement.
• We may share your Personal Information with recipients outside ZIMPLOW HOLDINGS LIMITED, including Dealers, for the purposes of operating our business, Sites, Apps or Devices, providing you with products or services you have selected, or otherwise for the purposes set out in this Statement.
• We may share your Personal Information with recipients outside ZIMPLOW HOLDINGS LIMITED, including with our joint venture partner, ZIMPLOW HOLDINGS LIMITED Finance, for the purposes of allowing those recipients to operate their business, Sites, Apps or Devices and provide you with products or services you have selected.
• We may use third-party service providers to help us operate our business, Sites, Apps or Devices, provide you with products or services you have selected, or administer activities on our behalf, such as sending out newsletters or surveys. We may share your Personal Information with such third parties for the purposes set out in this Statement.
• We may share aggregated demographic information with our business partners, trusted affiliates and advertisers for the purposes outlined in this Statement. While we make all reasonable efforts to ensure that such information is anonymized, it is possible that your Personal Information may be disclosed.
• Subject to providing prior notice, obtaining your consent, or using an appropriate legal ground as required under Applicable Laws, we may share your Personal Information with our third-party marketing partners, for direct marketing purposes. You may withdraw your consent at any time or object at any time to the Processing of your Personal Information for direct marketing purposes.
• If you make a payment via a Site or an App or directly to ZIMPLOW HOLDINGS LIMITED or a Dealer, your Personal Information may need to be provided to third parties (e.g., payment services providers) for the purposes of facilitating those payments.
• If we sell, merge or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or other restructuring), we may disclose your Personal Information to the prospective seller or buyer or their representatives. In these circumstances, we will take reasonable steps to ensure the security and confidentiality of your Personal Information.
• We also may disclose your Personal Information: (i) to the extent necessary to establish, exercise or defend legal claims; (ii) if required by Applicable Laws or regulations; (iii) in response to requests from government agencies and law enforcement authorities; (iv) when disclosure is necessary or appropriate to prevent physical harm or material financial loss; or (v) for the purposes of investigating unlawful activity.
10. International Transfers of Personal Information
We may make use of Processing facilities controlled or operated by members of our corporate group or our third-party service providers located in jurisdictions other than the jurisdiction in which your Personal Information was originally collected. In particular, the content and features of a Site, an App or a Device may be provided by means of servers located outside your jurisdiction (including, but not limited to, servers located outside Zimbabwe). Your Personal Information may be transferred to and Processed using those servers or other Processing facilities as part of the operation of a Site, an App or a Device, or in connection with any of the Processing purposes set out in this Statement, subject always to compliance with the provisions of Applicable Laws. These transfers are necessary to provide our products and services to you in an efficient and effective manner. By providing Personal Information to ZIMPLOW HOLDINGS LIMITED, you acknowledge that your Personal Information may be transferred to locations outside your jurisdiction.
Where Applicable Laws require an international transfer mechanism, we transfer your personal information on the basis of one or more of the following;
• Adequacy decisions as defined and maintained by the relevant Data Protection Authority.
• Standard Contractual Clauses as defined and maintained by the appropriate Data Protection Authority.
• Any other international transfer mechanisms available under Applicable Laws.
11. Third-party services
You may encounter advertising or other content on any Site, App or Device that may link to websites or services of ZIMPLOW HOLDINGS LIMITED ’s partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these third-party websites or services, and we are not responsible for the practices employed by third-party websites or services linked to or from any Site, App or Device. These websites and services may be subject to their own privacy policies and terms of use.
12. Direct marketing
As set out in this Statement and in accordance with requirements under Applicable Laws, we may contact you via email, text message, or other electronic means from time to time to provide you with information relating to products or services that may be of interest to you. If you wish to unsubscribe from these communications, we include detailed unsubscribe instructions in each such communication. Alternatively, you may use the unsubscribe features provided through our Sites and Apps.
Please note that, in the event that you unsubscribe from receiving communications relating to marketing or advertising, we may nevertheless continue to contact you directly for the purposes of carrying out your instructions, enabling you to make any purchases you request, administration of your account, or as required or permitted by Applicable Laws.
13. Data retention
We retain the Personal Information we collect for a period of seven (7) years.
When your Personal Information is no longer required for the purposes of the processing, your Personal Information is deleted in accordance with the applicable Laws.
We may be required to retain your Personal Information for additional periods of time, for example, where required to do so by Applicable Laws.
14. Cookies
A cookie is a small file that is placed on your device when you visit a website. It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Information through cookie technology in accordance with our cookie policy.
15. Re-Targeting
ZIMPLOW HOLDINGS LIMITED may engage and work with service providers and other third parties that also use your information to offer you tailored ads when you browse the internet or use various social media platforms. Some of these ads may be tailored to your interest based on your browsing of our Site and elsewhere on the internet, sometimes referred to as “interest-based advertising” and “online behavioural advertising” (“Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Site using re-targeting technologies. You can reject or disable Interest-based Advertising, tailored ads, or re-targeted ads by managing your browser settings. However, please note that if you disable cookies and/or meta pixels, you may be unable to access some customized features on the Sites.
16. Terms of use
Use of our Sites, Apps and Devices, and our products and services, is subject to the applicable Terms of Use.
17. Your Personal Rights
It is your responsibility to ensure that any Personal Information you provide to ZIMPLOW HOLDINGS LIMITED is complete, accurate and up to date.
Subject to Applicable Laws, you may have any of the following rights:
• the right to request access to, or copies of, your Personal Information that is processed by ZIMPLOW HOLDINGS LIMITED;
• the right to request correction of any inaccuracies in your Personal Information;
• the right to object, on legitimate grounds, to the Processing of your Personal Information;
• the right to object to the sale, renting, or sharing of your Personal Information;
• the right to request, on legitimate grounds:
• erasure of your Personal Information that is processed by ZIMPLOW HOLDINGS LIMITED; and
• restriction of Processing of your Personal Information is processed by ZIMPLOW HOLDINGS LIMITED;
• the right to have your Personal Information transferred to another Controller, to the extent applicable;
• where we Process your Personal Information on the basis of your consent, the right to withdraw that consent;
• the right to appeal a previous decision ZIMPLOW HOLDINGS LIMITED has made about your privacy rights; and
• the right to lodge complaints regarding the Processing of your Personal Information with an appropriate Data Protection Authority. Further information, including contact details for appropriate Data Protection Authorities and
Data Protection Officers, can be found on the websites and apps.
This does not affect your statutory rights. You may exercise any of these rights by using ZIMPLOW HOLDINGS LIMITED ’s contact details. ZIMPLOW HOLDINGS LIMITED will provide a response to your request within the time limits prescribed by the Cybersecurity and Data Protection Act Chapter [12:07]. For complex requests, ZIMPLOW HOLDINGS LIMITED may exercise its right to extend the time limit where applicable. In any case, ZIMPLOW HOLDINGS LIMITED will endeavour to provide a response without undue delay.
18. Complaints
All complaints shall be made in writing for purposes of ease of tracking thereof. All complaints shall be channelled to the platforms as outlined on this ZIMPLOW HOLDINGS LIMITED ’s website. Where necessary, ZIMPLOW HOLDINGS LIMITED shall conduct an investigation into the nature of the complaint and provide you with a written outcome.
If you are unsatisfied with the outcome, you may have the right to lodge a complaint with an appropriate Data Protection Authority.
19. Amendments to this Statement
ZIMPLOW HOLDINGS LIMITED may amend, revise or update this Privacy Statement at any time in line with the applicable legislative and regulatory guidelines without providing you with any specific notice. You are encouraged to frequently check this Statement for any changes and to stay informed about how we are helping to protect your Personal Information. Your continued use of any Site, App or Device is deemed to be acceptance of any amendments to this Statement.