Privacy Policy

1. Who is responsible for your information

[COMPANY LEGAL NAME] (registration number [REGISTRATION NUMBER]), of [REGISTERED ADDRESS], decides how and why your personal information is processed. In South Africa we are the "responsible party" under the Protection of Personal Information Act 4 of 2013 (POPIA). In Zimbabwe we are the "data controller" under the Cyber and Data Protection Act [Chapter 12:07].

Our Information Officer / Data Protection Officer is [INFORMATION OFFICER], who can be reached at [CONTACT EMAIL].

2. Information we collect

• Account details: your name, email address, phone number and password (stored only in protected form).
• Order details: what you buy, delivery and billing addresses, and the status of your orders, refunds and returns.
• Payment details: payments are handled by our payment providers. We receive confirmation of payment and a reference, but we do not receive or store your full card number.
• Network details, if you join the referral network: your referral code, who referred you, your position in the network, the sales volume counted on each side of your network, and the commission you earn, are owed, or have been paid.
• Payout details, if you are paid commission: the bank or mobile money details and identity information needed to pay you and to meet tax and anti-fraud obligations.
• Records of agreement: which version of each of our legal documents you accepted, when, and the internet address and browser you used.
• Technical information: internet address, browser type, pages visited, and the cookies described in section 8.
• Messages you send us.

3. Why we use it and our legal grounds

• To create and run your account and to deliver your orders: this is necessary to perform our contract with you.
• To run the referral network, calculate commission and pay it: this is necessary to perform the Distributor Agreement.
• To take payment, prevent fraud, keep accounting and tax records, and respond to lawful requests: we are required to by law, or it is in our legitimate interests.
• To keep the website secure and improve it: this is in our legitimate interests.
• To send you marketing: only with your consent, or as the law otherwise allows, and you can opt out at any time.

4. What other network members can see

If you join the referral network, the people above you see only totals: how many people are on each side of their network and the combined sales volume. They are not shown your name, contact details, or what you bought.

If you buy as a guest or customer using someone's referral link, that person's network is credited with the value of your order. They are not shown who you are.

5. Who we share information with

We do not sell your personal information.

• Payment providers, to take payment and process refunds.
• Delivery companies, to deliver your order.
• Companies that host and support our systems, under contracts that require them to protect your information and use it only on our instructions.
• Banks or payout providers, to pay commission.
• Professional advisers, auditors, and regulators or law enforcement where the law requires or permits it.
• A buyer of our business, if the business is sold, on the same terms as this policy.

6. Transfers to other countries

Some of our service providers store information outside your country. We transfer information only where the recipient is bound by law or by contract to protect it to a standard substantially similar to the law of your country, or where you have consented, or where the transfer is otherwise permitted by law.

7. How long we keep it

We keep account information for as long as your account is open. We keep order, payment, commission and payout records, and records of the legal documents you accepted, for as long as tax, company and consumer law require, which is generally at least five years after the transaction. After that we delete the information or make it anonymous.

8. Cookies

We use only the cookies needed to run the store:

You can block or delete cookies in your browser, but the store will not work fully without the first three.

• a sign-in cookie, so that you stay signed in;
• a cart cookie, so that your cart is remembered;
• a country cookie, so that we show the right store and currency;
• a referral cookie, kept for 30 days when you arrive through someone's referral link, so that their code can be filled in if you join and so that their network can be credited if you buy.

9. Security

We use appropriate technical and organisational measures to protect personal information against loss, damage and unauthorised access. If a breach is likely to affect you, we will notify you and the regulator as the law requires.

10. Your rights

Subject to the law of your country, you may:

To exercise a right, contact [INFORMATION OFFICER] at [CONTACT EMAIL]. We may need to confirm your identity first. Some records must be kept by law even if you ask us to delete them.

In South Africa the regulator is the Information Regulator. In Zimbabwe the Data Protection Authority is the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ).

• ask whether we hold information about you and ask for a copy;
• ask us to correct or delete information that is inaccurate, out of date or no longer needed;
• object to our processing your information, including for direct marketing;
• withdraw consent where we rely on it;
• lodge a complaint with the regulator.

11. Children

This website is not intended for anyone under 18 and we do not knowingly collect their information.

12. Changes to this policy

We publish each update as a new numbered version with an effective date, and will ask you to accept a new version before you continue to use your account.

13. Additional information for South Africa

This section applies if you use the South African store, and is given as section 18 of POPIA requires.

Giving us your account, order and delivery details is voluntary, but without them we cannot create your account, deliver your order or pay commission. Information needed for tax, accounting and anti-fraud purposes is required by law.

We process your personal information only on a ground POPIA allows: your consent; to conclude or perform a contract with you; to comply with a legal obligation; to protect your legitimate interest; or to pursue our own or a third party's legitimate interest.

We send direct marketing by electronic communication only as section 69 of POPIA allows, and you may opt out at any time free of charge.

Where your information is sent outside South Africa, we comply with section 72 of POPIA.

If your personal information is accessed or acquired by an unauthorised person, we will notify you and the Information Regulator as section 22 of POPIA requires.

You may ask for access to records we hold under the Promotion of Access to Information Act 2 of 2000. Our manual under that Act, which explains how, is available from our Information Officer at [CONTACT EMAIL].

You may lodge a complaint with the Information Regulator (South Africa): https://inforegulator.org.za.

14. Additional information for Zimbabwe

This section applies if you use the Zimbabwean store.

We process your personal information in accordance with the Cyber and Data Protection Act [Chapter 12:07] and its regulations: fairly and lawfully, for the purposes described in section 3, and no more than those purposes require.

Where we rely on your consent you may withdraw it at any time. Withdrawing consent does not affect processing that the law requires or that is needed to perform a contract with you.

We transfer your information outside Zimbabwe only as that Act permits.

If a security breach affects your personal information, we will notify the Data Protection Authority and you as that Act requires.

You may lodge a complaint with the Data Protection Authority, the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ): https://www.potraz.gov.zw.