Privacy Policy

1. Introduction

Kinsley Estate ("we," "our," or "us") is committed to protecting your privacy and personal data in accordance with the Cyber and Data Protection Act, 2021 (Chapter 12:07) of Zimbabwe and the Cyber and Data Protection (Licensing of Data Controllers and Appointment of Data Protection Officers) Regulations, 2024.

This Privacy Policy explains how we collect, use, store, and protect your personal information when you visit our website or interact with our services. By using our website or providing us with your personal information, you consent to the practices described in this policy.

2. Data Controller Information

Kinsley Estate
Corner Crowhill Road and Luna Road
Borrowdale Brooke, Harare, Zimbabwe
Email: [email protected]
Phone: +263 8612774775 / +263 775 577 746

Kinsley Estate is registered with the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ) as a data controller.

3. Personal Information We Collect

We collect personal information that you voluntarily provide to us when you:

• Submit an inquiry or contact form
• Request a site viewing or book an appointment
• Download our brochure or marketing materials
• Subscribe to our newsletter or updates
• Browse our website (through cookies and similar technologies)

The types of personal information we may collect include:

• Identity Data: Full name, title
• Contact Data: Email address, telephone number, postal address
• Technical Data: IP address, browser type, device information, operating system
• Usage Data: Information about how you use our website
• Marketing Data: Your preferences for receiving marketing communications
• Transaction Data: Details of inquiries, viewing appointments, and property interests

4. How We Use Your Personal Information

We process your personal information for the following specific, explicit, and legitimate purposes:

• To respond to your inquiries and provide information about our properties
• To schedule and coordinate site viewings and appointments
• To process your interest in purchasing a stand at Kinsley Estate
• To send you marketing communications about our properties (with your consent)
• To improve our website and services
• To comply with legal and regulatory obligations
• To protect our legitimate business interests and legal rights

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose.

5. Legal Basis for Processing

Under the Cyber and Data Protection Act, we process your personal information based on:

• Consent: You have given clear consent for us to process your personal data for a specific purpose
• Contract: Processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• Legal obligation: Processing is necessary for us to comply with the law
• Legitimate interests: Processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests

6. Data Sharing and Disclosure

We may share your personal information with:

• Service Providers: Third-party companies that provide services on our behalf (e.g., website hosting, email services, marketing platforms)
• Professional Advisors: Lawyers, accountants, and other professional advisors
• Government Authorities: When required by law or to comply with legal obligations
• Business Partners: Architects, developers, and financial institutions involved in property transactions

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes.

7. Cross-Border Data Transfers

Some of our service providers may be located outside Zimbabwe. When we transfer your personal data outside Zimbabwe, we ensure that:

• We have notified POTRAZ of the transfer as required by law
• The destination country provides adequate data protection
• We have appropriate safeguards in place to protect your data
• You have provided explicit consent for the transfer where required

8. Data Security

We have implemented appropriate technical and organizational security measures to protect your personal information from unauthorized access, loss, misuse, alteration, or destruction. These measures include:

• Secure servers and encrypted data transmission (SSL/TLS)
• Access controls and authentication procedures
• Regular security assessments and testing
• Staff training on data protection and security
• Incident response and breach notification procedures

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

9. Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including:

• Inquiry Data: 2 years from last contact
• Marketing Data: Until you withdraw consent or 3 years of inactivity
• Transaction Data: 7 years for legal and tax compliance
• Website Analytics: 26 months

When we no longer need your personal information, we will securely delete or anonymize it.

10. Your Rights Under Zimbabwean Law

Under the Cyber and Data Protection Act, you have the following rights:

• Right to Access: Request a copy of your personal data we hold
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Object: Object to processing of your personal data for direct marketing
• Right to Withdraw Consent: Withdraw your consent at any time where we rely on consent
• Right to Complain: Lodge a complaint with POTRAZ if you believe your rights have been violated

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

11. Children's Privacy

Our website and services are not directed at children under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to delete that information as soon as possible.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

12. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify POTRAZ within 24 hours of becoming aware of the breach
• Notify affected individuals within 72 hours if the breach poses a high risk
• Provide information about the nature of the breach and steps being taken
• Recommend measures you can take to protect yourself

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new Privacy Policy on our website and updating the "Last Updated" date.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Kinsley Estate
Corner Crowhill Road and Luna Road
Borrowdale Brooke, Harare, Zimbabwe
Email: [email protected]
Phone: +263 8612774775 / +263 775 577 746

15. Regulatory Authority

If you believe we have not handled your personal information in accordance with the law, you have the right to lodge a complaint with:

Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ)
Postal: P.O. Box CY 2502, Causeway, Harare, Zimbabwe
Website: www.potraz.gov.zw