ZiTenga Privacy & Cookie Policy

Introduction

By accessing and using the ZiTenga website (the “Website”) the ZiTenga platform and any associated services, and signing up for ZiTenga, (the ZiTenga Services”), you agree to our Privacy and Cookie Policy (“Policy”). If you do not agree with our Privacy Policy, please do not use the ZiTenga Services.

This Policy has been prepared in accordance with the strictest privacy and data protections laws, such as the EU General Data Protection Regulation 2018, the South African Protection on personal information Act 2020, Zimbabwe Data Protection Bill and the California Consumer Privacy Act. ZiTenga works with third party ID verification companies and shares your personal information with them.  ZiTenga obtains commitment from the third parties that they will abide by ZiTenga’s privacy policy.  For the purposes of our data collection and processing activities, ZiTenga is deemed the controller of the personal data we collect and process and the Access to Information and Protection of Privacy Act in Zimbabwe.

The purpose of our privacy policy is to inform you that we collect personal data from you, and how we use your personal data. This Policy may be changed, supplemented or updated by the ZiTenga team (referred to as the “ZiTenga Team”) at its sole discretion without prior notice. You should check the ZiTenga 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 ZiTenga Services. If you do not agree to such revised privacy policy you must stop using the ZiTenga Services, links or content contained on the website.

 

What is personal data?

Personal data is any information or different types of data that potentially could identify a person. By providing us with your personal data, you also give consent to us to collect, retain, use and disclose your personal data in accordance with this Policy.

 

Where we collect personal data?

We collect your personal data when you register on our website; this includes when you sign-up and when you verify your account.  We collect further personal data during any correspondence; for example, your personal data received through correspondence via e-mail, the “contact” section on our website, social media, during any support interaction between yourself and the ZiTenga team or during an ‘scam’ investigations

 

Why we process and collect personal data?

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

 

Changes to your personal data

Your personal data may occasionally change.  If it does, you commit to updating the ZiTenga 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. You may also contact us to update your personal data.

 

What (personal) data do we collect?

We may collect and process personal data including

• your full name, e-mail address, cell phone number, contacts, ID card details, IP address, geo-location, biometrics, cryptocurrency addresses, and passwords.

 

• Any information that you may provide during any interaction, correspondence or feedback between you and the ZiTenga 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, complaints that you have made, personal data provided during correspondence with our customer support or any other correspondence with the ZiTenga team.
• Personal data we collect from the use of ZiTenga Services, including your usage habit relating to the ZiTenga Services, your method of interaction with the ZiTenga 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 e-mails, telephone calls and web queries.
• Any time you access your electronic wallet, payments service or transfer related to ZiTenga tokens.
• Transactional information, such as details about purchases you make through the ZiTenga 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 automatically collected

When you make use of ZiTenga Services, your personal data is automatically collected.  The information that we automatically 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 ZiTenga 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 you visited the website and other comparable server log information.
• Device Information: This would include information about the device you used when accessing the ZiTenga 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 login credentials: 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 tracking technologies: We, and our service providers may use various technologies to collect information when you interact with the various ZiTenga 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 the behaviour 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 verify you and others on the network – we use several data points to verify that each of our users are unique Zimbabweans, including but not limited to ID information, biometric information, phone numbers, phone contact lists, device information, social media information and IP addresses. This is in order to protect you, the user, to ensure that other users on the network are valid individuals.
• to operate, maintain, and improve ZiTenga Services;
• If you use ZiTenga 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 apply 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 our partners and us;
• to protect the rights, privacy, safety and property of the ZiTenga team and others parties involved;
• to process payments you make via the Website;
• to detect, investigate and prevent fraudulent transactions or unauthorized or illegal activities;
• for your protection – to confirm that you are who you say you are and that you are a unique user.

 

If necessary, your personal data may also be used in the following way:

• to comply with a legal requirement;
• to comply with legal requests and processes, including governmental and enforcement authorities;
• to enforce our privacy policy;
• to link, connect or combine information about you with other information;
• for monitoring, analysing and study services; and
• carrying out any other purpose or reason for which the personal data was collected.

 

We may share your personal data in the following manner:

• with third-parties or service providers who work with us;
• any information you share publicly, such as username and content that you post when using interactive parts of the ZiTenga Services such as online forums, social networking or media sites if applicable;
• your email address and or phone number with the individual you indicated as a referee when you signed up, for the purposes of them contacting you to remind you to log in and transact on the platform;
• 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 ZiTenga team or others; and
• with third-parties where aggregate personal data is disclosed.
• ZiTenga obtains commitment from the third parties that they will abide by ZiTenga’s privacy policy when working with your personal data.
• If we deem that any user is inappropriately approaching users or gaining access to users accounts, and we deem it appropriate to disclose the identity of the hacker/scammer to users, we reserve the right to do so at our sole discretion. This is to protect you from nefarious users.

 

Information you provide publicly

We may make available as part of the ZiTenga Services, information sharing facilities online, such as message boards, chat rooms, key events, support chat, etc. When you voluntarily disclose information publicly online to us or anyone else, that information becomes publicly available and can be collected and used by others. The ZiTenga 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.

 

Data cleansing

We periodically delete data on our database. Do not rely on us to store your information for you. Further, while we make our best attempts to keep our data up to date, the nature of a viral network is that some of our data becomes out of date. Do not rely on the quality of our user information.

 

Public blockchain

Blockchain technologies are public databases that cannot be erased. These blockchain technologies use different anonymising processes to conceal the details of transactions. ZiTenga currently uses the Tron blockchain.

 

The ZiTenga system relies on payments on the blockchain that can be publicly scrutinized. This is the nature of the blockchain. It is public and if people know your account number on the blockchain, they can see your transaction history and your balance. You should not use our system if you are not comfortable with this as a fundamental principle.

 

Should ZiTenga create its own blockchain, the ZiTenga blockchain will potentially be a public ledger with anonymising hash functions.

 

By using the ZiTenga Services, you acknowledge and agree that:

The ZiTenga blockchain will record transactions using a hash function that anonymises the transaction and once these transactions are recorded by decentralised network nodes, the blockchain transactions cannot be erased. You nor we will be able to delete data relating to the blockchain transactions.

ZiTenga provides 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 adequate level of protection as in other parts of the world. You agree to this transfer, storing or processing outside of your country of residence. We use the proper legal arrangement, such as data processing agreements before we conduct an international data protection transfer.

 

Third-party sites and hyperlinks

 The ZiTenga Services may contain hyperlinks to third-party websites and domains that may collect personal data about you, including through cookies and/or other tracking technologies. If you access other websites 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 respective websites' and must make your 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.

 

E-mail communications with us

 As part of our ZiTenga Services, you may occasionally receive e-mails or other communications from us, relating to your use of ZiTenga Services. Communications relating to ZiTenga Services will be sent for purposes such as service updates, customer’s service, notifications, promotions and password recovery.

 

Security of your personal data

We take the privacy of your personal data very seriously.  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. Although we intend to protect your personal data, the security of the personal data may be compromised as a result of unauthorised use of ZiTenga Services, hardware or software failure, unauthorised access, disclosure, and other factors. Compromising in security of personal data may be in the form of loss of personal data, unauthorised access, misuse, disclosure and alteration. While we are applying our reasonable efforts to protect your information, there is still a chance that hackers may get access. This requires both us and you to remain vigilant.

 

The access to your personal data is restricted to the ZiTenga 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 solely responsible 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.

 

Legal rights individuals European Economic Area (“EEA”)

The data protection law provides the following rights for EEA Data Subjects (“Data Subjects”):

Data subject access request – Data Subjects may request a copy of personal data that we hold and inspect the personal data to ensure that they are processed lawfully.

• Data Subjects 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 his/her 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 to be erased.  The Data Subject would no longer be able to make use of ZiTenga 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.
• Data Subjects may request the suspension on our processing of your personal data if Resident wants to ascertain the accuracy of the personal data, Data Subjects will not request the personal data to be erased due to unlawful processing,
• Data Subjects may request for their automated personal data to be transferred to a third-party service-provider.
• Data Subjects can 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 ZiTenga 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@zitenga.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 may be retained in order for us to comply with the applicable law or after receiving a judicial order, 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.

 

 

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