Privacy Policy

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Commitment to Privacy

  •, Zambia, Africa, and/or its subsidiaries and affiliates in Zambia, Africa (collectively referred to as "") are committed to managing personal information in accordance with the Zambia Information and Communications Technology Authority ('ZICTA') under the ECT Act and in accordance with other applicable privacy laws.
  • provides services that allow you to sell or purchase goods and services (including on behalf of third-party merchants) via our website ( or app (collectively, the “Sites”) (collectively, the “Services”).
  • This document explains how we collect, use, disclose and protect your personal information (“Your Information”) and is referred to as our Privacy Policy.
  • In this Privacy Policy, “we”, “our” and “us” refers to and “you” or “your” refers to any individual about whom we collect personal information. This Privacy Policy applies to all personal information collected by us, including personal information collected or submitted through our Sites.
  • We take privacy very seriously and are committed to the protection of your privacy. By providing Your Information to us, you understand we will handle and treat Your Information in accordance with the practices described in this Privacy Policy. If you do not agree with any of the terms of this Privacy Policy, please do not submit any personal information to us. Other terms may also apply to you and the personal information we hold about you (for example where we provide you with a specific privacy collection notice).

What information do we collect about you?

The type of personal information we collect will vary depending on the nature of your dealings with us. We have outlined this in more detail below:

Customer and prospective customers

When you enquire about our Services or when you become a customer of, a record is made which includes Your Information. The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:

  • your name;
  • Contact details including your phone number, email address and mailing/delivery address;
  • your date of birth;
  • your professional details (such as your job title);
  • information about your employer or an organization you represent (i.e., the relevant supplier/merchant whom you are associated with);
  • any other information you provide to us through our Services; and
  • any additional information relating to you that you provide to us directly or indirectly through the use of our Sites or online presence.

To provide some of our Services, you may provide us with personal information which relates to another person (for example, name and business contact details of a person who is the contact in a company or government agency with whom we deal). If you provide us with information about any other person, you must obtain that person’s permission to give us the information and inform them of our privacy policy.

Prospective employees/applicants

We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history (including references and other information included in a CV or cover letter as part of the application process). Generally, we will collect this information directly from you.

Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions.


We (or a share registry provider we may engage) may also collect information to maintain shareholder information in accordance with Zambian Securities Exchange requirements, such as:

  • the name of the individual shareholder and any trustee (if applicable);
  • Personal details relating to any Power of Attorney (e.g., the attorney’s name, address, occupation, date of birth and phone number);
  • Bank account details; and
  • Your Securityholder Reference Number or Holder Identification Number.

When we collect personal information from shareholders, we may also use and disclose it for other reasons related to your shareholding, such as identity verification, providing shareholder services, sending you correspondence and documents and responding to complaints or inquiries. We may also use Your Information to market our products and services, such as exclusive shareholder offers, to you.

Visitors to our Sites

The way in which we handle the personal information of visitors to our Sites is discussed below.

What happens if you don’t provide Your Information?

You can always decline to give any of Your Information we request, but that may mean we cannot provide you with some or all of the Services you have requested, and may not be able to do business with you effectively or meet the expectations of customers or shareholders. If you have concerns about the personal information we have requested, please let us know.

How does collect Your Information?

Generally, we collect Your Information directly from you where possible. We may collect and update Your Information over the phone, by email, or over the internet or social media such as when you provide Your Information to us by:

  • Accessing our Sites;
  • Using our Services;
  • Completing any forms on the Sites; or
  • Making any requests or transactions through the Sites.

We may also collect Your Information from other sources, for example:

  • Our affiliated and related companies;
  • Third party suppliers and contractors who assist us to operate our business; and
  • In respect of prospective employees / job applicants, from recruitment agencies or referees you have nominated.

Where personal information is collected from a third party, will treat Your Information in accordance with the practices described in this Privacy Policy. cannot guarantee the accuracy of personal information provided by a third party.

How do we interact with you via the Internet?

Website and cookies

You may visit our Sites without identifying yourself. If you identify yourself (for example, by logging in as member or registering for membership), Your Information you provide to will be managed in accordance with this Privacy Policy.

If you visit our Sites, we may collect certain information, such as the type of device or browser you’re using, IP address, your device ID (a numeric identifier for your mobile device, if you access our Sites using a mobile device), the time of your visit, the duration and the pages you accessed on our Sites. This is to, amongst other things, help us to provide a positive user experience on our Sites, including optimizing our marketing activities to help us ensure that advertisements on the Sites are most directly relevant to your interests and to personalize your browsing experience (for example, by remembering your preferences and recognizing you as a repeat visitor to our Sites).

To do so, we use cookies to help us collect information about visitors to our Sites. Cookies are small data files sent by a website or application that are stored by the web browser on your device that enable our system to recognize a returning visitor to our Sites. You are not identifiable from such information.

Most browsers can be set to detect cookies and you can control how your browser deals with cookies by changing your browser settings (for example by rejecting cookies). However, in doing so, you may not be able to use certain content on our Sites and may not have the same user experience.

Third party links

Our Sites may contain links to third party websites, platforms or applications. We are not responsible for content or the privacy practices of those websites, platforms, or applications that are linked to our Sites. We recommend that you read the privacy policy and terms and conditions of any third-party website, platform or application that you intend to use.

Why does collect and use Your Information?

In summary, only collects Your Information where it is reasonably necessary for us to carry out our business functions or activities, including to assess and manage our customer’s needs and provide Services to our customers. We may also collect information to fulfil administrative functions associated with the Services, for example, billing and managing customer and other business relationships.

We also collect personal information to administer and manage relationships with our shareholders. may allow shareholders and other visitors to our website to sign up for alerts and otherwise communicate with us.

The purposes for which we collect and use Your Information depends on the nature of your interaction with us, but may include:

  • enabling you to access and use the Services;
  • researching, developing, expanding and improving our products and the Services;
  • administering your account with us;
  • providing you with our Services;
  • analysing your interactions and use of our Sites to understand and improve the effectiveness of our marketing initiatives;
  • keeping and updating records and databases to ensure the smooth operation of our business and Services;
  • communicating with you about changes or developments to our Services and business or in the normal course of business dealings, including via email to SMS;
  • to send you communications and notices in connection with your account on our Sites;
  • responding to your enquiries or requests for information, including about our Services;
  • maintaining and improving our customer service by monitoring our Services for quality and training purposes;
  • managing our relationship with you, for example if you are a supplier, business partner or shareholder; and
  • managing, planning, advertising and administering programs and events which may be of interest to you.

How do we use or disclose Your Information?

For customers and business partners

The purposes for which we may use and disclose Your Information will depend on the Services we are providing to you. For example, if you have engaged us to provide our Services to you, we may disclose Your Information as follows:

  • to our third-party service partners to permit them to provide products and services on our behalf, including fraud prevention;
  • to our third-party merchants to either: (i) deliver/provide goods or services ordered; or (ii) redeem vouchers you have purchased; and
  • to ensure the protection of Your rights, property or personal safety, any member of the public, or to protect our interests. will also use and disclose Your Information for a range of administrative, management and operational purposes. This includes:

  • planning, managing, monitoring and evaluating our Services;
  • quality improvement activities;
  • statistical analysis and reporting;
  • training staff, contractors and other workers;
  • risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
  • responding to enquiries and complaints regarding our Services;
  • obtaining advice from consultants and other professional advisers; and

Disclosure to contractors and other service providers

We may disclose Your Information to third parties we engage in order to assist us in providing our Services to you or to administer our relationships with shareholders, including suppliers, merchants, distributors and service providers such as those providing the payment gateway, website engagement, marketing, fraud prevention, data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, and market research.

For prospective employees / job applicants

To assist us with our recruitment process, we may disclose Your Information to those employees who it is necessary for Your Information to be disclosed to as part of the recruitment process as well as recruitment agents and other advisers who assist with recruitment.

Other uses and disclosures

Personal information may also be shared between related or affiliated companies of, where necessary.

We may use and disclose Your Information for other purposes explained at the time of collection (such as in a specific privacy collection statement or notice) or otherwise as set out in this Privacy Policy.

Third parties to whom we have disclosed Your Information may contact you directly to let you know they have collected Your Information and to give you information about their privacy policies.

You may receive push notifications through the mobile app device (currently only available for android devices) or your browser where you have consented to being sent such notifications.

We may share certain non-personally identifiable information such as activity on the Site, purchase history, survey responses and other information with third parties to assist with their own marketing programs. We may also obtain similar data from third parties for the same reasons, namely to improve the Services and offering we provide.

Does disclose Your Information overseas? may use third party contractors or service providers who are based overseas or perform services provided outside of Zambia. Further, or its third-party providers may store Your Information in the cloud or other types of network systems, where it can be accessed from and transferred between various countries over the internet.

Unless we have your consent, or an exception under the Zambian Privacy Principles applies, we will only disclose Your Information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Zambian Privacy Principles in relation to Your Information.

Can you deal with us anonymously or use a pseudonym?

We will, if practicable and lawful, provide you with opportunities to use a pseudonym or to remain anonymous in your dealings with us.

Generally, it is not practicable for us to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect Your Information, you may be unable to utilize our Services or we may not be able to provide you with the relevant service, product or information.

Does use or disclose Your Information for direct marketing? may use or disclose Your Information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you, or as otherwise permitted under applicable privacy laws.

If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below or using the opt-out functionality contained in the electronic message.

If you opt-out of receiving marketing material from us, may still contact you in relation to its ongoing relationship with you.

How does hold Your Information securely?

We will take all reasonable steps to keep Your Information secure and to ensure it is protected against misuse, interference, loss, unauthorized access, modification or inappropriate disclosure. We require our staff to maintain the confidentiality of Your Information. We may hold Your Information in electronic form and will store it in secure systems accessible only to authorized personnel who have logins and passwords to gain access.

We host Your Information that we collect in secure server environments that are protected by firewalls and other industry-standard technology in an effort to prevent interference or access from unauthorized persons.

Online Transactions

If you purchase Product(s) or Voucher(s) (as defined in our terms and conditions through our Sites, we process your credit card details securely over the internet using a third-party provider’s tier-one PCI-DSS compliant payment gateway. Our sites are also protected by a 256 Bit SSL Certificate to ensure that your credit card and anonymity are protected when you purchase online. If you opt-in to save your credit card details, our third-party provider will retain your credit card details on its servers for future purchases on our Sites. We do not store your credit card details on our servers.

While we take reasonable steps to protect Your Information, no website, internet connection or transmission, computer system or wireless connection is completely secure and we cannot guarantee or provide assurances regarding the security of transmission of information you communicate to us online or the integrity of transmission over the internet. Any information which you transmit to us online is at your own risk.

Retention period and Disposal of Personal Information

We will only retain Your Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

If we no longer need Your Information, we will take reasonable steps to securely destroy or permanently de-identify Your Information.

Changes to our Privacy Policy

We may amend this privacy policy from time to time, with or without notice to you. The changes will be effective immediately upon being made public on our Sites. We also try to let you know about major changes to our Privacy Policy (for example by putting up a notice on our Sites). We recommend that you visit our Sites regularly to keep up to date with any changes.

How to access or seek correction of Your Information

Access to Your Information

You may request to access Your Information we hold about you at any time by contacting us (see below for details), including by asking us to provide you with a summary of Your Information that we hold.

For your protection, we may require you to confirm your identity before access to Your Information is granted.

You will not be charged for making a request to access Your Information, however, in some circumstances, you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

Correction of Personal Information

We will take reasonable steps to ensure that Your Information we collect, use or disclose is accurate, complete and up-to-date. However, the accuracy of that information largely depends on the information you provide. We recommend that you:

  • let us know if there are any errors in Your Information; and
  • keep us up to date with changes to Your Information such as your name, address and telephone number.

If you believe that any of Your Information, we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct Your Information in certain circumstances in accordance with the Zambian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with Your Information about the requested correction.

Queries and complaints

If you have a question or want to make a complaint about how we handle Your Information, please contact us at any time using the details below and provide details of the incident so we can investigate it.

Where we receive a question or complaint regarding’s use of Your Information, we will first review any question or complaint you may have to determine whether there are simple or immediate steps which can be taken to resolve the question or complaint. We will generally respond to your complaint within a week.

If your question or complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint or query within a week and endeavor to complete our investigation into your complaint promptly. We may require further information from you in order to resolve your complaint or question and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved.

We will, where reasonably possible, take steps to investigate and resolve complaints within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will notify you.