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PRIVACY POLICY

This privacy notice for The Friendship Bench ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you access our services. The friendship bench is committed to protecting and respecting your privacy. We work diligently to protect the privacy, confidentiality, and security of the Personal Information (also known as “personal data”) that we receive and to act in compliance with current data protection legislation as applicable to our offices, including the Zimbabwean Cyber and Data Protection Act [Chapter 12:07] and the EU General Data Protection Regulation 2016 (GDPR). This Act shall apply to matters relating to access to information, protection of privacy of information and processing and storage of data wholly or partly by automated means: and shall be interpreted as being in addition to and not in conflict or inconsistent with the Zimbabwean Protection of Personal Information Act [Chapter 10:27].

This Privacy Policy describes the principles and practices that apply to the Personal Information that we collect from individuals, online or offline, such as individuals who browse through our Sites, register on our Sites; use the Products and/ or Services provided on our Sites or otherwise, use of our Assessments; provide services to us; interact with our Sites; communicate with us through telephone, email, text, or other communications means; participate in our interviews, surveys, or promotions; read or receive our newsletters; or apply for employment with us. This Privacy Policy sets out how and why we collect, store, and use Personal Information; our legal bases for processing Personal Information; information on transfers to third parties and international transfers; as well as your rights as a data subject. This Privacy Policy covers Personal Information processed by The Friendship Bench.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. USE OF YOUR PERSONAL INFORMATION

3. WHY WE PROCESS YOUR INFORMATION?

4. LEGAL BASES WE RELY ON TO PROCESS YOUR INFORMATION?

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

6. COOKIES AND OTHER TRACKING TECHNOLOGIES?

7. HOW LONG WE KEEP YOUR INFORMATION?

8. KEEPING YOUR INFORMATION SAFE?

9. COLLECTION OF INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. UPDATES TO THIS POLICY?

12. CONTACT US ABOUT THIS POLICY?

13. REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT?

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when you register or consent to access our services, express an interest in obtaining information about us or when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names
  • phone numbers
  • email addresses
  • mailing addresses
  • job titles
  • usernames and passwords
  • contact preferences.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's calendar, sms messages, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
  • Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. USE OF YOUR PERSONAL INFORMATION

  • To provide and maintain our FB services, including to monitor the usage of our services.
  • To manage Your Account: to manage Your registration as a user of our services. The personal data you provide can give you access to different functionalities that are available to you as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the services you have subscribed to or of any other contract with us.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • For other purposes: We may use Your information for other purposes, such as research data analysis, identifying usage trends, determining the effectiveness of our services and improve our services, and your experience.

3. WHY WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To fulfil and manage your subscriptions. We may process your information to fulfil and manage your subscriptions, and payments made through the Services.
  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To protect our services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

4. LEGAL BASES WE RELY ON TO PROCESS YOUR INFORMATION?

 We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate interests.

5. WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION?

We may need to share your personal information in the following situations:

  • When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API).

6. COOKIES AND OTHER TRACKING TECHNOLOGIES?

We use cookies and similar tracking technologies to track the activity on our services and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our service. The technologies We use may include cookies and web beacons. For more information on this kindly refer to the cookies policy.

7. HOW LONG WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set our data retention and disposition policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period in which users have an account with us.

When we have no ongoing legitimate need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. KEEPING YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not attempt to improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. COLLECTION OF INFORMATION FROM MINORS?

Our Service does not address anyone under the age of 16. By using our services, you represent that you are at least 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that your child has provided us with personal data, please contact us. If we learn that personal information from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. In some instances our services can be offered to minors only if consent has been given by their parent or guardian in written form. If you become aware of any data we may have collected from children under age 16, please contact us at support@friendshipbench.io.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the contact section below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the contact section below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.
  • Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Will your information be shared with anyone else?

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

The Friendship Bench has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. The Friendship Bench will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Transfer of personal information outside Zimbabwe

  1. Subject to the provisions of the Zim Act, we may not transfer personal information about a data subject to a third party who is in a foreign country unless an adequate level of protection is ensured in the country of the recipient or within the recipient international organisation and the data is transferred solely to allow tasks covered by the competence of the controller to be carried out.
  2. The adequacy of the level of protection afforded by the third party or international organisation in question shall be assessed in the light of all the circumstances surrounding a data transfer operation or set of data transfer operations; with particular consideration being given to the nature of the data, the purpose and duration of the proposed processing operation or operations, the recipient third party or recipient international organisation, the laws relating to data protection in force in the third party or international organisation in question and the professional rules and security measures which are complied with in that third party or international organisation.
  3. The Authority shall lay down the categories of processing operations for which and the circumstances in which the transfer of data to countries outside the Republic of Zimbabwe is not authorised.

Transfer to country outside Zimbabwe which does not assure adequate level of protection.

A transfer or a set of transfers of data to a country outside Zimbabwe which does not assure an adequate level of protection may take place in one of the following cases:

  1. the data subject has unambiguously given his or her consent to the proposed transfer.
  2. the transfer is necessary for the performance of a contract between the data subject and the controller, or the implementation of pre-contractual measures taken in response to the data subject’s request.
  3. the transfer is necessary for the conclusion or performance of a contract concluded or to be concluded between the controller and a third party in the interest of the data subject.
  4. the transfer is necessary or legally required on important public interest grounds, or for the establishment, exercise, or defence of legal claims.
  5. the transfer is necessary to protect the vital interests of the data subject.
  6. the transfer is made from a register which, according to acts or regulations, is intended to provide information to the public and which is open to consultation either by the public in general or by any person who can demonstrate a legitimate interest, to the extent that the conditions laid down in law for consultation are fulfilled in the case at hand.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know.

  • whether we collect and use your personal information.
  • the categories of personal information that we collect.
  • the purposes for which the collected personal information is used.
  • whether we sell or share personal information to third parties.
  • the categories of personal information that we sold, shared, or disclosed for a business purpose.
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose.
  • the business or commercial purpose for collecting, selling, or sharing personal information; and
  • the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

If the business collects any of the following:

  • social security information, drivers' licenses, state ID cards, passport numbers
  • account login information
  • credit card numbers, financial account information, or credentials allowing access to such accounts.
  • precise geolocation
  • racial or ethnic origin, religious or philosophical beliefs, union membership
  • the contents of email and text, unless the business is the intended recipient of the communication.
  • genetic data, biometric data, and health data
  • data concerning sexual orientation and sex life

you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services.

Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.

Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.

To exercise your right to limit use and disclosure of sensitive personal information, please email support@friendshipbench.io.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

11. UPDATES TO THIS POLICY?

We will update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at support@friendshipbench.io or contact us by post at:

The Friendship Bench

4 Weale Road, Milton Park

Harare

Zimbabwe

13. REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us.