DOLPHIN TELECOMS PRIVACY POLICY

Dolphin Telecoms ("we," "us," "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you access our website, www.dolphintelecoms.com (the "Website") and fill out our online forms. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the Website or use our services.

1. Personal Information We Collect

"Personal data" means any information or set of information that directly or indirectly identifies any individual. We may process: your names; identification numbers; contact details (telephone numbers, email addresses, physical addresses), employment and financial information.

2. Why We Process Your Personal Data

We may process your personal data for the purposes below.

Purpose	Description
Responding to Your Queries	When you contact us via our website, social media, or other channels, we process your personal data to respond to your inquiries or requests.
Marketing and Surveys	With your consent, we send marketing materials, offers, or surveys about our products and services, and may analyse your preferences to personalize these communications.
Product and service improvement	We use aggregated or individual data to enhance our products, Websites, and services, identify trends, and improve customer experience.
Service delivery	If you sign up for our services, we will use your personal information for service delivery.
Order Processing and Delivery	When you purchase products, we use your data to process orders, deliver products, and manage the transaction.
Compliance and Legal Obligations	To comply with applicable laws (including Zimbabwe's Cyber and Data Protection Act) and to protect our assets, rights, and legal interests.
Employment Onboarding	If you apply for a job, we interact with you about opportunities and assess suitability.

3. Lawful Basis For Processing Your Personal Information

Your consent (e.g., for marketing purposes).
The performance of a contract (e.g., to deliver internet services).
Compliance with legal obligations.
Legitimate interests pursued by Dolphin Telecoms, such as fraud prevention.

4. Data Sharing

To provide you with mobile and internet services, we share your personal information with our partners.

This sharing is strictly limited to what is necessary to:

Provision Services: Activating your SIM card and assigning your mobile number.
Roaming: Facilitating connectivity when you travel outside our primary coverage areas.
Billing & Usage: Reconciling data usage and airtime consumption to ensure accurate billing.
Sharing for Legal & Regulatory Purposes: In accordance with the Cyber and Data Protection Act we may be required to share your personal data with, POTRAZ: For regulatory reporting and compliance audits.
Law Enforcement: When presented with a valid legal warrant or order for the prevention or detection of crime.

We do not sell your personal and financial information to third parties. Our partners are contractually bound by strict Data Sharing Agreements to ensure your data is kept confidential, stored securely within Zimbabwe, and processed only according to our specific instructions.

5. Data Retention

We will hold your personal information on our systems for as long as is necessary for the relevant activity, or if is set out in any relevant contract you hold with us. Thereafter we may keep it for longer to respond to any questions or complaints and to maintain necessary records to satisfy legal, accounting or reporting requirements.

6. Data Subject's Rights

Under Section 14 of the Cyber and Data Protection Act [Chapter 12:07] (CDPA), you have the following rights:

Access: Request copies of your personal data we hold.
Correction: Rectify inaccurate or incomplete personal data.
Deletion: Request deletion of your personal data, subject to legal retention requirements.
Objection: Object to personal data processing for specific purposes.
Right to be informed: To be informed of the use to which your personal information is to be put (what information is being collected, why it's being collected, how it will be used, where it will be stored).
Consent management: To give and withdraw consent, empowering you to control the processing of your personal information.
Right to complain: You have a right to lodge a complaint with the Data Protection Authority (DPA) if you believe that any of your protection rights have been infringed.
Right not to be subjected to automated processing: You have the right not to be subjected to solely automated decisions, including profiling, that produce legal effects concerning you or significantly affect you.

7. Security of Your Information

We implement robust security protocols to protect your data, including:

Encryption standards.
Secure access controls.
Regular system audits and penetration testing.

8. Updates to this Policy

We may update this policy periodically to reflect changes in our practices or regulatory requirements. The latest version will always be available on our website.

9. Contact Us

Data Protection Officer

Email: privacy@dolphintelecoms.com
Phone: +263 86 772 10754
Office Address: 77 Jason Moyo Avenue, Harare, Zimbabwe