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Privacy PolicyTerms Of Service

Privacy Policy

 1. Introduction

This Privacy Policy governs the collection, processing, and storage of personal data by Curverid Tobacco ("we", "us", "our") through our internal WhatsApp integration tool. This policy is issued in compliance with the Cyber and Data Protection Act (Chapter 12:07) of Zimbabwe, 2021.

This application is intended strictly for authorized internal use by our employees and team members.

2. What Data We Collect

We collect and process the following personal data:

  • WhatsApp phone numbers — to identify and route communications
  • Message content — to facilitate operational communications, document delivery, and system alerts
  • Timestamps — to log when messages were sent or received

We do not collect sensitive personal data (such as financial, health, or biometric data) through this application.

3. Purpose and Lawful Basis for Processing

We process your data for the following purposes:

PurposeLawful Basis
Internal operational communicationsLegitimate interest
Automated delivery of daily documents and alertsPerformance of employment contract
User support and troubleshootingLegitimate interest

Processing is conducted in accordance with Section 18 of the Cyber and Data Protection Act, which requires data to be collected for specified, explicit, and legitimate purposes.

5. Data Retention

We retain personal data only for as long as necessary:

  • Message content: Retained for [3 months], then permanently deleted
  • Phone numbers: Retained for the duration of your employment or until access is revoked
  • System logs: Retained for [90 days] for security and audit purposes

After the applicable retention period, data is securely deleted or anonymized.

6. Data Sharing and Disclosure

We do not sell, rent, or share personal data with external third parties for commercial purposes. Data may be shared with:

  • Meta Platforms (WhatsApp) — as a required transmission infrastructure provider. Meta acts as a data processor under its WhatsApp Business Platform terms.
  • Internal IT/management personnel — on a strict need-to-know basis for support and administration
  • Regulatory or law enforcement authorities — where required by Zimbabwean law


7. Your Rights as a Data Subject

Under the Cyber and Data Protection Act, you have the right to:

  • Access — Request a copy of personal data we hold about you
  • Correction — Request correction of inaccurate or incomplete data
  • Deletion — Request deletion of your personal data, subject to legal retention requirements
  • Object — Object to certain types of processing
  • Withdraw consent — Where processing is based on consent

To exercise any of these rights, contact the System Administrator at [IT/Support Email]. We will respond within 21 days of receiving your request.

8. Data Security

We implement appropriate technical and organizational measures to protect personal data, including:

  • Access controls limiting system access to authorized personnel only
  • Encrypted transmission channels
  • Regular security reviews of the application

In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected individuals and the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ) in accordance with the Act.

9. Cross-Border Data Transfers

Message transmission occurs through Meta's global infrastructure. By using this system, you acknowledge that your data may be processed in data centers outside Zimbabwe. We ensure that any such transfers comply with Section 22 of the Cyber and Data Protection Act, which governs cross-border transfers.

10. Changes to This Policy

We may update this policy periodically. Material changes will be communicated to users via internal notice. Continued use of the system constitutes acceptance of the updated policy.

Terms Of Service

 1. Acceptance of Terms

By accessing or using the Curverid Tobacco internal WhatsApp integration tool ("the System"), you agree to be bound by these Terms of Service. If you do not agree, you must immediately cease using the System and notify your line manager.

These terms are issued under and governed by the laws of Zimbabwe, including the Cyber and Data Protection Act (Chapter 12:07), 2021 and the Computer Crime and Cyber Crime Act (Chapter 9:23), 2017.

2. Authorized Use Only

The System is provided exclusively for:

  • Authorized employees and contractors of Curverid Tobacco
  • Internal business communications, document delivery, and operational alerts
  • Purposes expressly permitted by your role and your line manager

You must not:

  • Share your access credentials with any unauthorized person
  • Use the System for personal, commercial, or non-business purposes
  • Circumvent, disable, or interfere with any security features of the System
  • Use the System to transmit unlawful, defamatory, abusive, or inappropriate content
  • Attempt to access data belonging to other users or system components

3. Acceptable Use

All use of the System must comply with:

  • Curverid Tobacco's internal IT and communications policies
  • The Computer Crime and Cyber Crime Act (Chapter 9:23) of Zimbabwe
  • WhatsApp's Business Platform Terms of Service
  • Applicable employment agreements and codes of conduct

Violations may result in disciplinary action, including termination of employment, and may constitute criminal offences under Zimbabwean law.

4. Intellectual Property

All content, configurations, workflows, and automated outputs generated through the System remain the property of Curverid Tobacco. Users are granted a limited, non-transferable licence to use the System solely for authorized internal purposes.

5. Data and Privacy

Your use of the System is subject to our Privacy Policy (above), which forms part of these Terms. You acknowledge that:

  • Message content transmitted through the System is subject to company monitoring for security, compliance, and operational purposes
  • You have no reasonable expectation of privacy in communications made through company-owned systems
  • You are responsible for the accuracy and appropriateness of content you transmit

6. System Availability

We will endeavour to maintain reasonable System availability but do not guarantee uninterrupted service. The System may be taken offline for maintenance, security updates, or other operational reasons without notice.

7. Limitation of Liability

To the fullest extent permitted by Zimbabwean law, Curverid Tobacco shall not be liable for:

  • Loss or corruption of messages or data
  • Interruptions to the System's availability
  • Consequences arising from unauthorized use of your credentials
  • Third-party platform (Meta/WhatsApp) outages or policy changes

8. Termination of Access

Access to the System will be revoked:

  • Upon termination or resignation of employment
  • If you are found to have violated these Terms or company policy
  • At the discretion of the IT/System Administrator for security or operational reasons

Upon termination, all personal data associated with your account will be handled in accordance with our Privacy Policy and data retention schedule.

9. Changes to These Terms

We reserve the right to amend these Terms at any time. Updated terms will be communicated via internal channels. Continued use of the System after notification constitutes acceptance of the revised Terms.

10. Governing Law and Disputes

These Terms are governed by the laws of Zimbabwe. Any disputes arising from these Terms or use of the System shall be subject to the exclusive jurisdiction of the courts of Zimbabwe.