Privacy
Policy
Effective Date: 3 January 2023
Steel Partner Pvt Ltd ( “we”, “us”, or
“our”) is committed to protecting the personal information that you provide to
us, and in accordance with the provisions of the Cyber and Data Protection Act [Chapter
12:07] [No 5 of 2021], and recognise the importance of being clear about how we
intend to use it.
We know that you care about how your
information is used and shared, and we take your privacy seriously. Our Privacy
Policy describes our practices and policies regarding information that you may
provide to us or that we may collect from you, and how we may use and store
this information.
We collect certain information through
our websites, located at www.steelpartner.co.zw (“Website”), and from
our products or related services. This Privacy Policy is incorporated into and
considered part of any of our agreements that references this Privacy Policy (“Agreement”).
1. Personal Information
When used in this Privacy Policy,
“personal information” is any information that identifies or can be used to
personally identify you. This includes such things as your name, address,
telephone number, and email address.
2. What Information We May
Collect from You
2.1. We
collect personal information to provide services, solutions, and to improve our
products, services for our client and in terms of managing our business,
complying with legislation, and for other purposes explained below. The
type of information we collect will depend on the purpose for which it is
collected and used. We will only collect information to the extent that
is reasonably necessary for that purpose.
2.2. If
your organisation is our client and you do not agree to provide us with your
personal information, this may limit our ability to provide our services and
solutions to your organisation.
We collect certain categories of
information:
2.3. “Personal
Information” is information that could be used to identify you
individually or that could be used to contact or locate you, including but not
limited to, your name, email address and company information.
2.4. “Anonymous
Information” is information about you that is not associated with or
linked to your Personal Information; Anonymous Information generally cannot be
used to identify you absent accompanying Personal Information. We may collect
Personal Information and/or Anonymous Information in the following ways:
2.4.1. Information
you voluntarily provide to us:
We may collect Personal Information
through forms that you complete on our Website, by subscribing to our services
(such as newsletters or white papers), using discussion forums on our Website,
attending training sessions, following us on social media, by attending our
events or by corresponding with us by phone, email, social media or otherwise.
This includes, but is not limited to, information you provide when you purchase
products from us, submit a query or complaint, participate in forums or other
social media functions on our Website, enter a competition, promotion or
survey, and/or when you report a problem with our Website.
2.4.2. Information
from our Website (collected automatically):
Each time you interact with our
Website, we may automatically collect the following Personal Information and/or
Anonymous Information:
2.4.2.1. Technical
information including, but not limited to, browser type, operating system,
device information, IP address, domain name, referral URL, time zone setting,
and/or a time-stamp for your visit.
2.4.2.2. Usage
information including, but not limited to, geographic location information
(such as your country or province), the numbers and frequency of visitors to
our site, page views, unique page views, video views, form conversions, and
your clickstream behaviour (e.g. clicking links to, through and from our
Website).
2.4.2.3. We and our
third-party suppliers may use various technologies such as cookies, web beacons
(also referred to as clear gifs), and e-tags to collect Personal Information
and/or Anonymous Information, to analyse trends, and to provide you with a more
personalized customer experience.
Cookies are small pieces of information
that are placed on your computer to enable our system to recognize your
computer when you return to our Website and to collect various technical and
usage information about your visits. Cookies may be used by us and our third-party
suppliers who help us provide our Website. We may link information stored
in cookies to Personal Information we have in our systems.
In addition, we and our third-party
partners and suppliers may use cookies and other similar technologies to enhance
the quality of your interactions with our Website, provide you with targeted
advertising, and to analyse the effectiveness of any such advertising (such as
user engagement and interaction). We may also receive reports based on the use
of certain technologies by these companies on an individual and anonymized
basis.
Most browsers have options for
deleting, blocking or otherwise disabling the use of cookies. For more
information on how to do so, please refer to the documentation accompanying
your browser. If you choose to disable cookies, some areas of our Website may not
function properly.
To learn more about third party cookies
and other advertising networks and their opt out instructions, please
visit http://www.aboutads.info/choices or
http://preferences-mgr.truste.com
.
2.5. Information
collected from other sources:
We work closely with third-parties (for
example, associate companies, business partners, resellers, advertising
networks, analytics providers, and search engine providers) and may receive
Personal Information about you from them to the extent permitted by applicable
law, to enable us to establish accounts, fulfil orders and customize your
experience on our Website with personalized content. Where possible, we
will inform you what information you are required to provide to us and what
information is optional.
2.6. Employment
This clause will only be applicable to
the extent that you have applied for employment. If you apply for employment
with us, we also may collect personal information including details contained
in letters of application and CV/résumé, previous employment background,
education history, work-related licenses, certifications, or other professional
credentials, languages and other relevant skills. You may also voluntarily
choose to provide other relevant information as part of your application. If
you intend to provide us with personal information of a reference or any other
third party as part of your application for employment, it is your
responsibility to obtain consent from that third party prior to providing the
personal information to us.
3. How We Use Your Information
We may use the information held about
you to:
3.1. establish, manage, and
maintain our business relationships;
3.2. send communications;
3.3. respond to inquiries
and requests;
3.4. develop, provide, and
improve our products and services to you;
3.5. inform you about
special offers, new products and services and important notices;
3.6. obtain feedback from
you on our products and services;
3.7. provide you with a
personalised experience when you interact with us;
3.8. conduct administrative
and business functions to fulfil our contractual obligations with you;
3.9. enable you to
subscribe to our website, newsletters, mailing lists and to register for
events, competitions, workshops and seminars;
3.10. assess the performance of our
websites and to improve its operation;
3.11. process and respond to
complaints;
3.12. update our records and keep
contact details up to date;
3.13. process your application for
employment with us, evaluate whether your qualifications may suitable for other
employment positions, and for employment-related purposes if you are hired;
3.14. comply with any law, rule,
regulation, lawful and binding determination, decision or direction of a
regulator; industry codes to which we subscribe, or which apply to us, in
cooperation with any regulatory authority of any country; or as we otherwise
believe to be necessary or appropriate under applicable law.
4. Our Products and Services
You acknowledge that some of our
products and use of services may collect data that includes, but is not limited
to, one or more of the following where applicable: data (such as number of
bytes, number of packets, IP addresses, server name, and ports), process and
system metrics (such as CPU, memory usage, disk i/o, applications and/or
operating systems on which such products are used), performance data about
applications that are instrumented (such as classes, methods, parameters, URLs,
SQL statements, and IP addresses), user and administrative account information
(such as name, email address, and phone number), and/or any transactions
related to any of the foregoing (all such data collectively, “Data”).
Not all products collect Data; additional information about the Data that can
be collected by a product is set forth in the applicable documentation for such
product. You acknowledge that Data may contain Personal Information, and that some
Personal Information may be required to provide administrative access and
control of certain products and services to you. Some products may permit you
to specify what types of Data will be collected as described in the applicable
documentation for such product. You are solely responsible for the Data that
you choose to collect and monitor; you acknowledge that some of the services
and/or product functionality and features might not function if you do not
enable collection of certain Data.
We may use, reproduce, and/or transmit
the Data for your benefit as needed to provide you with products and related
services. Data we collect is primarily used to display product and
performance information back to the product user. Data is used for development,
diagnostic and/or corrective purposes, including providing you with technical
support regarding your use of our products and services.
5. Where We Store Your
Information
5.1. The
information we collect from you (including Data) may be transferred to, and stored
at, a destination other than the country in which the information was collected
(including but not limited to servers and data centres located locally and in
the add name/s of other countries). By using our Website, products and
services or providing any Data and/or Personal Information to us, where
applicable law permits, you consent to the transfer, processing and storage of
such information outside of the country where such information was originally
collected at another destination in which we do business (and where data
protection standards may be different).
We have concluded agreements with all
recipients of your personal information to ensure that they treat your personal
information with the same level of protection as we are required to do in the
Republic of Zimbabwe.
Notwithstanding the foregoing, you
acknowledge that we are not obligated to retain any Data.
5.2. You
represent and warrant that where you provide Data other than your own personal
data:
5.2.1. you are
competent to in terms of laws of the country;
5.2.2. you have the
necessary rights and licenses required to provide Data to us and our business
partners, and
5.2.3. the use,
reproduction, and transmission of the Data in accordance with the Agreement and
this Privacy Policy will not infringe or misappropriate any intellectual
property rights of any third parties or violate or breach any confidentiality
requirements, contractual obligations or any applicable laws (including any
applicable privacy laws). Without limiting the foregoing, you are responsible
for providing notice to, and obtaining consent from, all your users regarding
the collection, processing, storage and transfer of Data, including without
limitation with respect to any international transfers outside of your country,
and for responding to any queries from such users regarding the foregoing.
For the avoidance of doubt, you are solely responsible for ensuring that
any use of Data by us and/or you in connection with the products and or
services as contemplated by the Agreement and this Privacy Policy does not
violate any applicable laws.
6. Disclosure of Your
Information
We do not rent or sell your Personal
Information or Data to anyone. We share your Personal Information and
Data only with your consent, as well as in the following circumstances:
6.1. Contractors
and Agents: We may employ other companies and people to perform tasks
on our behalf and need to share your information with them to provide products
or services to you. Our contractors and agents do not have any right to use
Personal Information or Data we share with them beyond what is necessary to
assist us, and we require them to agree to maintain the confidentiality of such
Personal Information and Data.
6.2. Business
Partners We have an extensive network of channel partners and
suppliers who help us sell and deliver our products and services.
Additionally, certain of our products and services incorporate software
provided by third party suppliers.
6.2.1. We may share
your Personal Information with our business partners for purposes of:
6.2.1.1. selling and
providing products and services to you;
6.2.1.2. report on
sales of products.
6.2.2. We may also
obtain certain Personal Information about you from our business partners when
you purchase products and services from such business partners. We
require our business partners to maintain the confidentiality of your Personal
Information that we provide to them, provided, however, that you may have a
separate agreement with a business partner that will control that business
partner’s use of your Personal Information, in which case this Privacy Policy
does not apply to the information held by that business partner.
6.3. Business
Transfers: In some cases, we may choose to buy or sell assets or
become involved in a merger, acquisition or similar transaction. In these types
of transactions, customer information (that may include Personal Information
and Data) is typically one of the assets that is transferred. We and the
acquiring entity will retain the confidentiality of such information.
6.4. Protection
of the Company and Others: We may disclose or share Personal
Information, Data and other information, if we believe in good faith that such
disclosure or sharing is legally required or is necessary to protect our legal
rights (including, but not limited to, our intellectual property rights and
enforcement of our agreements), the legal rights of others, or the safety
and/or security of us, our employees, our customers, or other users.
You expressly consent to the sharing of
your Personal Information and Data as described in this Privacy Policy.
7. Security
7.1. The
security of your Personal Information and Data is important to us. We use
certain security measures, including, but not limited to, administrative,
physical, and technical safeguards to protect your Personal Data and Data from
unauthorised access, use, modification, or disclosure. Those safeguards may
include measures for preventing access, use, modification or disclosure of
Personal Information and Data by our personnel except as required by such
personnel:
7.1.1. to provide
products and services to you,
7.1.2. to provide
support, product development and related services, including to prevent or
address service or technical problems and make improvements,
7.1.3. as compelled
by applicable law or as required to protect our legal rights, or
7.1.4. as you
expressly permit or instruct in writing.
Any of our personnel that requires
access to Personal Information or Data will be bound by a confidentiality
agreement.
7.2.
Where applicable, please do not disclose your Website login credentials to
unauthorized people. You are responsible for the security of your login
credentials and for any activity that occurs under your account with us.
7.3.
Please be aware that no security measures can wholly eliminate security risks
associated with Personal Information and Data; keep this in mind when
disclosing any sensitive information to us.
7.4. If
we learn of a breach of our systems, we may notify you and others in a manner
that is consistent with applicable law and/or as agreed by us in writing.
8. Public Forums
We offer individuals the opportunity to
interact and publish content via discussion forums, blogs, and other means on
our Website (“Online Communication Tools”). If you use such Online
Communication Tools, any information that you disclose becomes publicly
available, and could be used to contact you, to send you unsolicited messages,
or for purposes neither we nor you have control over. Your use of certain
Online Communication Tools may be subject to additional terms and conditions.
We are not responsible for the Personal Information or any other
information you choose to submit or publish via these Online Communication
Tools.
9. Marketing
We may use information held about you
to provide you, or permit selected third parties to provide you, with information
about products or services we feel may interest you. If you do not want
to use your information in this way, or to pass along your details on to third
parties for marketing purposes, you can unsubscribe from such emails using the
link provided in the emails, tell our staff member you’re dealing with, email
us at add email address, or select the relevant opt-out option on the form
in which we are collecting your information.
10. Links to Third-Party
Websites
We may provide links to other
third-party websites and services that are outside our control and not covered
by our Privacy Policy. We are not responsible for the privacy
practices or the content of such websites. We encourage you to review the
privacy policies on any website you visit whether linked to or not.
11. Your Privacy Rights
11.1. To the extent
permitted by applicable law, we may communicate with you for direct marketing
purposes regarding information about our products, services and solutions that
we consider may be of interest to you. These communications may be in
various forms, in accordance with applicable laws.
11.2. Our Privacy Policy
provides you with details on how you may opt-out of the use of your Personal
Information by third parties for marketing purposes. Please be aware that
if you opt-out, you may continue to receive marketing communications during the
time it takes for us to process your request which will be done as soon as
reasonably practicable.
11.3. If you opt-out from
receiving marketing communications from us, you will continue to receive
administrative messages from us regarding our products and related services as
required in terms of our contractual obligations.
12. Access and Correction
12.1. We make all
reasonable efforts to ensure that information is stored securely both in
electronic and physical form.
12.2. You have a right to
ask us to update, correct or delete your personal information. If you wish to
access, correct, update, suppress, or delete your personal information that has
been previously provided to us, please send a written request to:
marketing@steelpartner.co.zw
13. How long will We retain
Your Personal Information?
We will retain your personal
information for the period necessary to fulfil the purposes outlined in this
Privacy Policy unless a longer retention period is required or permitted by
law.
14. Contact Us
Should you have questions or concerns
related to this Privacy Policy, please email:
marketing@steelpartner.co.zw
15. Updates
From time to time we may amend or
update this privacy policy. When this occurs, we will post the new version of
the privacy policy on our website. We encourage you to periodically review this
privacy policy so that you remain informed as to how we are protecting your
personal information. Your use of our Website, products and/or services
following these changes means that you accept and agree to the updated Privacy Policy.
Steel Partner Private Limited
Telephone:
+263 781 147 173
Physical Address:
4JJB Waterfalls Avenue, Ardbennie,
Harare
Postal Address:
4JJB Waterfalls Avenue, Ardbennie,
Harare
All Rights Reserved.