Privacy Statement

The purpose of this page ('Privacy Statement') is to inform the reader of how Southern African Power Pool (SAPP) manages and process (any operation or set of operations performed on data by any means such as collecting, recording, organisation, storage, adaptation or alteration of personal information, etc.) personal information. The manner in which SAPP manages Personal Information (personal data, as defined in The Cyber and Data Protection Act [Chapter 12:07], includes, but is not limited to, names, postal address, e-mail address, telephone number).

When users (individuals who make use of any SAPP websites and/or applications) interact with SAPP, submit information to SAPP, or sign up for any products and/or services offered by SAPP, all personal information, which may be collected through our website or other channels, is treated as confidential and private. SAPP manages the user’s personal information in the following ways:

• By collecting personal information;
• Using such personal information;
• Sharing (amongst ourselves) the user's personal information; and
• Disclosing such personal information to SAPP authorised service providers as well as relevant third parties in the manner set forth in this Privacy Statement.

SAPP may from time to time update this document to ensure that it is consistent with latest developments, industry trends and/or any changes in legal or regulatory requirements.

1. Collection of Personal Information

1. Generally, SAPP collects user Personal Information in the following ways:

   1. Upon submission of an application form or other forms relating to any of SAPP products and services;
   2. When interacting with SAPP customer service officers (via telephone calls, letters, face-to-face meetings and emails);
   3. When making use of any SAPP service i.e. Websites and/or applications;
   4. Upon submission of a request for SAPP to contact them, or request to be included in an email or other mailing lists;
   5. When there is a response to SAPP adverts, initiatives or to any request for additional Personal Data;
   6. When contacted by or respond to SAPP marketing representatives and customer service officers;
   7. When SAPP receives references from business partners and third parties;
   8. When SAPP seeks information from third parties in connection with the products and services applied for; and
   9. Upon submitting Personal Information to SAPP for any other reason.

2. When a user browses SAPP Websites, it is generally done anonymously. SAPP does not automatically collect Personal Information unless such information is provided or login credentials are used.

3. If SAPP is provided with any Personal Information relating to a third party (e.g. information about a spouse, children, parents and/or employees), by submitting such information, a user confirms that the consent of the third party to provide SAPP with such personal information has been obtained.

4. Users must ensure that all Personal information submitted to SAPP is complete, accurate, true and correct. Failure to do so may result in SAPP inability to provide users with the products and services requested.

2. Purposes for the Collection, Use and Disclosure of Personal Information

2. Generally, SAPP collects, uses and discloses Personal Information of users for the following purposes:

   1. To respond to queries and requests;
   2. To manage the administrative and business operations of SAPP and comply with internal policies and procedures;
   3. To facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
   4. To match any Personal Information held, relating to any of the purposes listed herein;
   5. To resolve complaints and handle requests and/or enquiries;
   6. To prevent, detect, investigate a crime, analyze and manage commercial risks;
   7. To provide media announcements and responses;
   8. To monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
   9. For legal purposes (including but not limited to obtaining legal advice and dispute resolution);
   10. To conduct investigations relating to disputes, billing, suspected illegal activities or fraud;
   11. To meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on SAPP (including but not limited to responding to regulatory complaints, reporting to regulatory bodies and conducting audit checks, due diligence and investigations);
   12. For purposes which are reasonably related to the aforementioned.

3. In addition to the above, SAPP collects, uses and discloses Personal Information of users for the following purposes:

   As a customer or an employee of an organization which is a customer of SAPP:

   1. Opening or continuation of accounts and establishing or providing users with the products and services subscribed to;
   2. Facilitating the continuation or termination of user subscription to SAPP products and services;
   3. Facilitating the daily operation of the products and services (including but not limited to trading);
   4. Facilitating third party services if purchased, obtained, administered or processed through SAPP;
   5. Managing and executing SAPP service level agreements with suppliers;
   6. Processing of payment instructions, direct debit facilities and/or credit facilities requested by users/suppliers;
   7. Enforcement of repayment obligations (including but not limited to debt collection, filing of claims and retrieval of payments from losses made by service partners);
   8. Administering and processing any insurance claims and payments arising under the respective policies;
   9. Credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
   10. Generation of internal reports (including but not limited to annual, operational and management reports);
   11. Processing referral payments and commission fees to SAPP external partners;
   12. Administering fee adjustments, refunds and waivers;
   13. Notifying users of their entitlements under loyalty and reward programs with SAPP;
   14. Analysing user experience with SAPP products and services so as to help us improve, review, develop and efficiently manage the products and services offered; and
   15. For purposes which are reasonably related to the aforementioned.

4. Furthermore, where permitted under the Data Protection Act:

   SAPP may also collect, use and disclose Personal Information of users for the following additional purposes:

   1. To match Personal Information with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services by SAPP;
   2. For purposes which are reasonably related to the aforementioned.

5. In relation to particular products and services or user interactions, SAPP may also specifically notify users of other purposes for which personal information is collected, used, or disclosed.

6. Users have a choice to withdraw consent for receiving marketing or promotional materials/communication. Users may contact SAPP using the contact details found on the main website www.sapp.co.zw.

7. Once SAPP receives confirmation that a user wishes to withdraw consent for marketing or promotional materials/communication, it may take up to 30 (thirty) working days for the withdrawal to be reflected on the system. Therefore, users may continue to receive marketing or promotional materials/communication during that period of time. It may be noted that even upon withdrawal of consent for the receipt of marketing or promotional materials, SAPP may still contact users for other purposes in relation to the products and services held by users or subscriptions to SAPP.

3. Processing of Personal Information

3. By providing Personal Information to SAPP, users acknowledge that the information has been collected from them directly and there is consent for SAPP to process such information.

4. Where users submit Personal Information (such as name, address, telephone number and email address) via the SAPP Website (e.g. through completing any online form) the following principles are observed in the processing of such information:

   1. SAPP will only collect Personal Information for a purpose consistent with the purpose for which it is required. The specific purpose for which information is collected will be apparent from the context in which it is requested.
   2. SAPP will only process Personal Information in a manner that is adequate, relevant and not excessive in the context of the purpose for which it is processed.
   3. Personal Information will only be processed for a purpose compatible with that for which it was collected, unless the user has agreed to an alternative purpose in writing or SAPP is permitted in terms of national legislation of general application dealing primarily with the protection of Personal Information.
   4. SAPP will keep a record of all Personal Information collected and the specific purpose for which it was collected for a period of 1 (one) year from the date on which it was last used.
   5. SAPP will not disclose user Personal Information relating to any third party, unless prior written consent from the user is obtained, or where SAPP is required to do so by law.
   6. If Personal Information is released with consent of the user, SAPP will retain a record of the information released, the third party to which it was released, the reason for the release and the date of release, for a period of 1 (one) year from the date on which it was last used.
   7. SAPP will destroy or delete any Personal Information that is no longer needed by SAPP for the purpose it was initially collected, or subsequently processed.

4. Disclosure of Personal Information

4. SAPP will take reasonable steps to protect Personal Information of users against unauthorized disclosures. Subject to the provisions of any applicable law, Personal Information may be disclosed for the purposes listed above (where applicable), to the following:

   1. SAPP related corporations and employees to provide content, products and services to address user questions and requests in relation to customer accounts, subscription and billing arrangements with SAPP as well as products and services;
   2. Companies providing services relating to insurance and consultancy to SAPP;
   3. Agents, contractors or third-party service providers who provide operational services to SAPP, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call center, security or other services to SAPP;
   4. Vendors or third-party service providers in connection with marketing promotions and services offered by SAPP;
   5. Other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;
   6. Collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
   7. Credit bureaux for the purpose of preparing credit reports or evaluation of creditworthiness;
   8. External banks, credit card companies and their respective service providers;
   9. SAPP professional advisers such as auditors and lawyers;
   10. Relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;
   11. Any other party to whom users authorise SAPP to disclose Personal Information to.

5. Use of Cookies

5. SAPP uses cookies (a small piece of information that is placed on a user’s computer when visiting certain websites) for the following purposes:

   1. To enable certain features and functions on websites, e.g. remembering user ID, favourite channel selections, browsing and other service preferences;
   2. To build up a profile of how users experience the website;
   3. To improve the efficiency of SAPP website;
   4. To administer services to users and advertisers;
   5. To establish usage statistics.

6. Most internet browsers provide users with the option of turning off the processing of cookies (please see the Help section of the browser), but this may result in the loss of functionality, restrict use of the website and/or delay or affect the way in which it operates.

7. Advertisements on the SAPP website may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. SAPP does not control these third parties and their cookie policies. Should users have any questions about SAPP Data Privacy Policy, they may contact SAPP.

8. SAPP is not responsible for the Personal Information policies (including Personal Information protection and cookies), content or security of any third-party websites linked to the Website.

6. Queries

6. If a user:

   1. Would like to withdraw consent to any use of their Personal Information as set out in this Privacy Statement, they may contact the business unit executive that manages their account.
   2. Would like to obtain access and make corrections to their Personal Information records, they may contact the business unit executive that manages their account.

7. If your Personal Information has been provided to SAPP by a third party (e.g. a referrer), users should contact that organisation or individual to make such queries, complaints, and access correction requests to SAPP on their behalf.

8. If a user withdraws their consent to any or all use of Personal Information, depending on the nature of such a request, SAPP may not be in a position to continue to provide its products and services to users. In addition, SAPP may not administer any contractual relationship in place, which in turn may also result in the termination of any agreements with SAPP, and may result in the user being in breach of contractual obligations or undertakings. SAPP legal rights and remedies in such event are expressly reserved.

7. Governing Law

7. This Privacy Statement and use of the website shall be governed in all respects by the laws of Zimbabwe.