1. Introduction

Homelink is an integrated property development and financial services institution providing an array of services. Homelink is committed to protecting your personal information. This Privacy Notice describes the personal information we process (collect, use, store, and share). It also explains your privacy rights and how the law protects you. This is governed by the Cyber and Data Protection Act [Chapter 12:07], (hereinafter “the Act”). By using our services, you agree to the terms of this Privacy Notice. Please read it carefully before you give us your personal information so that you understand how we handle your personal information. You have the right to decline providing your Personal Information; however, doing so may restrict our ability to deliver the financial products and services you require. We will only request Personal Information that is necessary and relevant to the services or products we offer.

2. What is personal information?

Personal information is any natural person’s information by which they can be identified. This includes but is not limited to; names, addresses, phone numbers, email addresses, identity number, fingerprints, blood type, physical/mental disability, individuals’ personal views/opinions, correspondence pertaining to home and family life, age, gender, race, colour, religious beliefs/affiliations, political opinions, marital status, professional associations, trade union membership, health care history, physical/mental disability, educational/financial/criminal or employment history, and genetic information.

3. To whom does the Notice apply?

This Privacy Notice applies to natural persons whose personal information is held by Homelink.

4. What Personal Information do we collect?

The personal information we may collect about you includes name, age, gender, contact numbers, national identity numbers, address, citizenship, date of birth, marital or family status, fingerprints, educational, financial, criminal or employment history, online identifiers, inferences.

5. How do we collect your Personal Information?

We collect Personal Information directly from you or online when you engage with us or use our products and services. We also get your personal information from external third parties, such as when you provide us with the personal information of other people such as next of kin, dependents, beneficiaries, or business partners, you confirm that you have their permission, where applicable, to share this information with us for the purposes outlined in this Privacy Notice.

6. How do we use/process Personal Information?

We use personal information to provide you with our products and services by doing the following:

Verifying your identity
Credit searches and/or verification of personal information.
Fraud and money laundering prevention and detection.
Market research, customer satisfaction survey and statistical analysis.
Performing and providing advertising and marketing services including targeted advertising.
Audit & record keeping purposes.
Compliance with legal & regulatory requirements.
Sharing information with service providers that we engage to process such information on our behalf or who render services to us. These service providers may be abroad, but we will not share your information with them unless we are satisfied that they have adequate security measures in place to protect your personal information in compliance with data protection laws.

7. How do we share or disclose your personal information?

While processing personal information, Homelink may disclose certain personal information to both internal and external parties. Internally, personal information may be transferred between Homelink business units. Externally, personal information may be transferred to regulatory authorities, law enforcement agencies; service providers, and other third parties as may be required either contractually, by law, or by legitimate interest.

8. Transfer of personal information outside Zimbabwe:

Homelink may transfer your personal information to countries outside Zimbabwe, such as for backup or service provision. We will ensure that such transfers comply with the Act and that your personal information is adequately protected, for example, through ensuring that the companies that we share your information with comply with the data privacy laws.

9. Retention of your personal information

We will keep your personal information only for as long as we need it for lawful business purposes or as required by law. When the personal information is no longer required, we will dispose it in terms of our retention policy.

10. Measures in place to protect your personal information

We use appropriate technical, and organisational measures to safeguard your personal information from unauthorised access.

11. Data protection rights

Data protection is premised on the protection of the right to human dignity and privacy as enshrined in the Zimbabwean Constitution. Your data protection rights are:

11.1.1 Right to be informed: You have the right to be informed on the personal information that we collect, why we collect it, how it will be used and where it will be stored.

11.1.2 Right to give and withdraw consent: You have the right to agree to processing of your personal information and to withdraw the consent.

11.1.3 Right to access your personal information: You have the right to seek confirmation on the personal information that is being processed, to access the information and receive updates about the processing activities.

11.1.4 Right to object to processing of your personal information: You have the right to object to processing of your personal information for protecting your legitimate interest for pursuing our legitimate interest or that of a third party and we will no longer process your information

11.1.5 Right to correction/rectification of your personal information: You have the right to request rectification of inaccurate or incomplete personal information.

11.1.6 Right to deletion of your personal information: You have the right to request deletion of misleading information.

11.1.7 Rights related to automated processing: you have the right not to have automated decisions on your personal information.

11.1.8 Right to complain: You have the right to submit a complaint to the Data Protection Authority if you have any concerns on processing of your personal information.

12. How to exercise your rights

You can exercise any of your data protection rights to;

12.1 Access, correct, or delete your data unless the data is required by law.

12.2 Restrict processing or object to marketing.

12.3 Request data portability.

12.4 Withdraw consent.

Submit requests through the contact information indicated below and we will respond within 30 days.

13. How we use cookies.

Cookies are small pieces of text sent to your browser by a website you visit. They help our website remember information about your visit, which can both make it easier to visit the site again and make the site more useful to you.

13.1 Purposes of cookies

13.1.1 Functionality

Cookies and similar technologies used for functionality purposes allow you to access features that are fundamental to a service. These cookies are used in order to deliver and maintain site services.

13.1.2 Security

Our website uses cookies and similar technologies for security purposes to protect you as you interact with a service by authenticating users, protecting against spam, fraud and abuse, and tracking outages.

13.1.3 Analytics

Our website uses cookies and similar technologies for analytical purposes to understand how you interact with a particular service. These cookies and similar technologies help collect data that allows us to measure audience engagement and site statistics.

13.1.4 Advertising

Our website uses cookies for advertising purposes, including showing personalized advertisements (ads) , serving and rendering ads, and personalizing ads (depending on your chosen settings.

13.1.5 Personalization

Cookies and similar technologies are used for the purpose of showing personalized content. These cookies help enhance your experience on our website by providing personalized content and features, depending on your settings.

In order to protect the privacy of users or visitors to our website, the enabling or disabling of the said cookies is optional during the site visit.

14. Privacy Notice Changes

We regularly review the Policy Notice and in the event of changes, the update version will be put on our website and other communication channels.

15. Contact us

If you have any questions, concerns, requests or complaints on handling of your personal information by Homelink, please contact the Data Protection Officer on +2638677006071 / +263242792800 or send an email to dpo@homelink.co.zw. You can also visit our offices at 72 – 74 Samora Machel Avenue, 4th Floor Hardwicke House, Harare.If you are not satisfied with the way we handle your queries, concerns, requests or complaints you can contact the Data Protection Authority on their website at https://www.potraz.gov.zw; regulator@potraz.co.zw, or visit their offices at 1008 Performance Close, Mount Pleasant Business Park, Mount Pleasant, Harare.