Effective Date: 12 September 2025
Last Updated: 12 September 2025
1. Introduction
ACR Solutions (“we,” “our,” or “us”) respects your privacy and is committed to protecting the personal data of our clients, employees, and all individuals who interact with us. This Privacy Policy explains how we collect, use, store, and protect your information in compliance with Zimbabwe’s Cyber and Data Protection Act 12:07.
2. Scope of this Policy
This Privacy Policy applies to:
- All personal data collected, processed, and stored by ACR Solutions through our website, mobile applications, services, and any other interactions with you.
- Data collected from clients, employees, suppliers, contractors, and other relevant parties.
By using our services or providing your personal data, you agree to the terms of this Privacy Policy.
3. Legal Basis for Processing Personal Data
We process your personal data in compliance with the Cyber and Data Protection Act, 12:07, based on the following lawful grounds:
- Consent: Where you have explicitly granted permission for us to process your data.
- Contractual Necessity: To fulfil our contractual obligations with you.
- Legal Obligations: To comply with applicable laws and regulations.
- Legitimate Interests: For purposes such as enhancing user experience, fraud prevention, and business operations, provided these interests do not override your rights.
4. Personal Data We Collect
We may collect the following types of personal data depending on your interaction with us:
4.1. Data You Provide Directly
- Name, address, email, and phone number.
- National Identity Number, Passport Number, or other government-issued ID.
- Payment details (e.g., bank account or credit card information).
- Client Case details
- Other Client Confidential Information
- Employment details (for employees or job applicants).
4.2. Data We Collect Automatically
- IP addresses and device identifiers.
- Browser type and operating system.
- Cookies and similar tracking technologies (see Section 10 for details).
4.3. Special Categories of Data
We may process sensitive personal data (e.g., Financial, biometric data) only with your explicit consent or as required by law.
5. How We Use Your Personal Data
We process your personal data for the following purposes:
- Service Delivery: To provide and manage the services you request.
- Communication: To send updates, newsletters, or respond to inquiries.
- Compliance: To fulfil legal obligations, including fraud detection and prevention.
- Employment Purposes: For recruitment, payroll, and human resource management.
6. Data Sharing and Disclosure
We may share your personal data with third parties only under the following circumstances.
6.1. With Your Consent
We will share data with third parties if you have explicitly authorized us to do so.
6.2. Legal and Regulatory Obligations
We may disclose personal data to comply with legal requirements, court orders, or government requests.
6.3. Service Providers
We may share data with trusted third-party service providers who assist us in delivering our services, such as payment processors, IT providers, and marketing agencies.
6.4. Business Transfers
If we undergo a merger, acquisition, or sale of assets, your personal data may be transferred to the new entity, subject to the same privacy protections.
7. Data Transfers
If we transfer your personal data outside Zimbabwe:
- We ensure that the recipient country provides adequate data protection standards.
- We implement safeguards such as data transfer agreements or seek your explicit consent.
8. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy or to comply with legal obligations. Retention periods may vary depending on:
- Legal and regulatory requirements.
- Contractual obligations.
- Your specific consent or instructions.
When your data is no longer required, we will securely delete or anonymize it.
9. Your Rights
Under the Cyber and Data Protection Act, 12:07, you have the following rights:
- Access: Request a copy of your personal data.
- Correction: Rectify any inaccuracies in your data.
- Erasure: Request deletion of your data, subject to legal and contractual obligations.
- Objection: Object to the processing of your data for specific purposes.
- Portability: Request a copy of your data in a structured, machine-readable format.
- Withdraw Consent: Revoke your consent for data processing at any time.
To exercise your rights, contact us using the information in Section 13.
10. Cookies and Tracking Technologies
We use cookies to improve your experience on our website. These cookies may include:
- Essential Cookies: Required for the site to function.
- Performance Cookies: Track website usage and improve functionality.
- Targeting Cookies: Deliver tailored advertisements.
You can manage your cookie preferences through your browser settings.
11. Data Security
We are committed to protecting your data. Measures we use include:
- Encryption of sensitive data.
- Access controls to prevent unauthorized access.
- Regular security audits and employee training.
While we take reasonable steps to secure your data, no system is completely secure.
12. Data Breach Notification Procedures
We take data breaches seriously and have established procedures to respond promptly and effectively. In the event of a data breach involving your personal data:
12.1. Notification to the Data Protection Authority
We will notify the relevant regulatory authority (e.g., the Cybersecurity and Data Protection Authority) within 24 hours of becoming aware of a breach, as required by the Cyber and Data Protection Act, 12:07.
12.2. Notification to Affected Individuals
If the breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay. This notification will include:
- A description of the nature of the breach.
- The categories and approximate number of affected individuals and data records.
- Contact details for the individual or team handling the incident.
- Recommendations for you to mitigate potential risks (e.g., password changes).
12.3. Mitigation and Remediation
We will take immediate steps to contain the breach, investigate its root cause, and implement corrective actions to prevent future occurrences.
12.4. Record-Keeping
We will document all breaches, including the facts, effects, and remedial actions taken, even if notification to the regulatory authority or individuals is not required.
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. Changes will be communicated via our website or other appropriate channels. The “Last Updated” date at the top of this document reflects the most recent changes.
14. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy, please contact our Data Protection Officer:
Chenai Makoko – Data Protection Officer
Email: cmakoko@acr4solutions.com
Phone: +263777489701
You may also lodge complaints with POTRAZ which is the designated Data Protection Authority of Zimbabwe if you believe we have violated your rights.
15. Acknowledgment and Agreement
By using our services or providing us with your personal data, you acknowledge that you have read, understood, and agree to this Privacy Policy.