Privacy Policy

1. Introduction

At Syrup ("we", "us", "our"), we are committed to protecting your privacy in compliance with the Data Protection Act [Chapter 11:22] of Zimbabwe (No. 5/2021). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our web hosting, web design, graphic design, and email hosting services.

By using our services, you ("data subject") consent to the collection and use of your personal information as described in this policy. We are registered with ZISPA.

2. Information We Collect (Section 3 of the Act)

We collect the following types of information as required by ZISPA:

• Personal Information: Name, email address, phone number, physical address (for domain registration as required by ZISPA), and payment details (Section 3: "personal information" definition).
• Service Data: Domain registration details, website content, email configurations, and hosting parameters.
• Technical Data: IP addresses, browser type, device information, and usage patterns collected via cookies (Section 3: "data" definition).
• Communication Data: Records of correspondence via email, WhatsApp, or contact forms.

We do not collect sensitive personal information (as defined in Section 11 of the Act) unless absolutely necessary for service provision, in which case we obtain explicit written consent.

3. Legal Basis and Purpose of Processing (Sections 7-12)

We process your personal information lawfully and fairly (Section 8) for specified purposes (Section 9):

• To fulfill contractual obligations for the services you request (domain registration, hosting, design services).
• To comply with legal requirements (e.g., ZISPA domain registration rules, tax laws).
• For our legitimate business interests (service improvement, fraud prevention), balanced against your rights (Section 10(3)(e)).
• With your consent for marketing communications (which you may withdraw at any time - Section 11(2)).

4. Data Subject Rights (Sections 14, 25-27)

Under the Data Protection Act, you have the right to:

• Access: Request a copy of your personal data we hold (Section 14(b)).
• Rectification: Correct inaccurate or incomplete information (Section 14(d)).
• Erasure: Request deletion of your data when no longer necessary (Section 14(e)).
• Object: Object to processing for direct marketing (Section 14(c)).
• Restriction: Limit processing in certain circumstances.
• Automated Decisions: Not be subject to solely automated decision-making (Section 25).

To exercise these rights, contact our Data Protection Dept at [email protected] or +263716112377. We will respond within 30 days as required by law.

For children under 18 (Section 26), rights may be exercised by parents/guardians.

5. Data Sharing and Transfers (Sections 28-29)

We may share your information with:

• Service Providers: Carefully vetted third parties (payment processors, ZISPA for domain registration) under contractual data protection obligations.
• Legal Requirements: When required by Zimbabwean law or to protect vital interests.

6. Data Security (Section 18)

We implement appropriate technical and organizational measures to protect your data against unauthorized access, alteration, or destruction, including:

• Encryption of sensitive data in transit and at rest
• Regular security audits and vulnerability testing
• Access controls and staff training
• Secure destruction of data no longer needed

7. Data Retention (Section 7(1)(c))

We retain personal data only as long as necessary for the purposes collected and as required by Zimbabwean Law:

• Active customer data: For duration of service plus 1 month
• Financial records: For tax compliance
• Domain registration data: As required by ZISPA regulations

Data is securely deleted or anonymized when no longer needed.

8. Cookies and Tracking Technologies

We use cookies for essential website functions, analytics, and service improvement. You may manage preferences via browser settings.

9. Changes to This Policy

We may update this policy to reflect legal or operational changes. Significant changes will be notified via email or website notice. The "Last Updated" date below indicates the latest revision.

10. Complaints and Contact

For privacy concerns or complaints:

• Our Data Protection Dept: [email protected] / +263716112377

Last Updated: 25 July 2025