What Are Cookies?

Cookies are small data text files that are used to identify your computer or device online. When you visit a website, a cookie is created and stored on your hard drive so that that website can recognize you while you are on that website. Some cookies are “session-based,” which means they disappear once you leave the website. Others are “persistent,” which means they are stored on your device until you delete them and they allow a website to recognize you each time you visit the website. Cookies are just one technology used to collect information online. A “web beacon,” also known as a tag, pixel tag, or clear GIF, is also used to transmit information back to a web server. When you interact with our mobile apps we may use SDKs, which act like cookies, or we may use other identifiers to help us identify your device. When we talk about “Cookies” in this Privacy Policy, we mean not just cookies, but web beacons, SDKs and similar technologies.

What Types of Cookies are on the Services?

  • First Party Cookies. Our Services use our own cookies to recognize you and remember you as a unique user.
  • Session Cookies remember you during your session on our Services. They are deleted when you log out of the Services and when you close your web browser. We use session Cookies to ensure content is displayed correctly on the Services, to balance and monitor load on our servers, and for other technical matters essential to the operation of our Services. You can configure your device to reject these cookies, but our Services will probably not work correctly, or at all, if you do.
  • Consent cookies are used by our consent management platform we employ to record your preferences about third party cookies described below, and to store and share your preference with those third parties. These cookies are essential for compliance with the legal obligations imposed on us and on third parties with whom we have a business relationship to ensure we request your consent, record your consent preferences, and act on such consent preferences.
  • Analytics cookies. Analytics cookies are used by us and by third parties who process data for us for data analytics purposes (for example Google Analytics) so that we can manage and improve the performance and design of our Services and for monitoring, auditing, research and reporting. We have activated Google’s IP anonymisation function on our Sites. This will cause your IP address to be cut by Google within Member States of the European Union or in other countries party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Sites, to compile reports on Site activity and to provide us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. With respect to Google Analytics, you can read about how Google uses data at their website.
  • Third party cookies: advertising and affiliate links. Our Advertising Partners and our affiliate links partners collect personal data from you for the purposes they disclose through our cookie consent management platform.
    • Advertising Partners include ad networks such as third party ad servers, ad agencies, ad technology vendors and research firms.
    • Affiliate links partners pay us when you buy things from them or another third party after clicking on an affiliate link in our content.

Our Advertising Partners use third party cookies to serve ads to you and to target you with tailored (or personalised) ads when you are using the Services and when you visit Third-Party Sites. They also use cookies to measure traffic on the Services (for example to track ad views, clicks, interactions etc).

Advertising Partners and affiliate links partners may view, edit or set their own cookies on your mobile device or web browser when you interact with our Services. They use cookies to track your use of our Services and your activities elsewhere online. We provide links to their privacy policies in our consent management platform, which you can access by clicking here.

What Information do Cookies Collect?

Cookies and similar technologies allow us to collect the following types of personal data: a unique ID assigned to your device; IP address; device and browser type; operating system; referring URLs; content viewed or other actions taken through our Services; time and date of those actions; country and language selected.

What Choices Do You Have?

Browsers and devices have tools that allow you to disable Cookies. If you disable Cookies you may not be able to access all the features of our services. We suggest that you keep our essential cookies active for a better user experience and to help us keep improving and developing our products and services. You can decide who you will allow to set third party cookies on your browser or device by contacting us at hello@zimbabwe263.com. You can change your mind and revisit your consent choices at any time by returning there.

If you would like more information about this practice and to know your choices about having your information used in this manner by our partners, you may visit https://optout.networkadvertising.org/?c=1, https://optout.aboutads.info/?c=2&lang=EN or https://youradchoices.com/token.

Privacy information for EEA and UK users

Information for UK/EU Users (including legal bases)

We will use your personal data only for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for another purpose, we will explain the legal basis we rely on.

The table below shows what we use your personal data for and the lawful basis for processing it in each case.

PurposeType of dataLawful basis
Recognize you and analyze how you, and other users, navigate the Services and apps and what type of content you’re interested in, and to manage and improve the Services by testing new features of our sites and apps. We do this by using cookies or similar technology as explained in our “Cookie Policy” section.Data that indirectly identifies you such as your IP address, mobile device ID and location data. This data does not include anything that allows us to identify you by name or contact details.Legitimate interest.
Recognize you and analyze how you, and other users, interact with ads on our Services and what type of ads you’re interested in. We do this by using cookies or similar technology as explained in our “Cookie Policy” section.Data that indirectly identifies you such as your IP address, mobile device ID and location data. This data does not include anything that allows us to identify you by name or contact details.Consent.
Communicate legal information to you.Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information you include in your user profile).Legitimate interest.
Analyse comments and feedback you have given us including comments, feedback and reviews you have posted on our Services in order to use the information to carry out journalistic activities, to improve our services and content offerings, and to enforce our Terms of Service.Data that directly identifies you (such as your name, username, and email address) and data that indirectly identifies you (such as your IP address or mobile device ID and location data).Legitimate interest.
Provide you with communications and services you’ve signed up, for such as our newsletters.Data that directly identifies you such as your name, username, email address and location data.Consent.
Register you as a user of our Services and other products and services and administer your Account.Data that directly identifies you (such as your name, username, and email address and other information included in your user profile).Creation or performance of a contract.
Publish content on our Services including articles, feedback, reviews and user comments about our posts.Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information included in your user profile).Creation or performance of a contract.
Fulfil orders for subscriptions, products or services placed through our Services.Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data.Creation or performance of a contract.
Collect money you owe us.Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data.Legitimate interest.
Verify or obtain payments due to us when you buy something from a third party after clicking on an “affiliate” link in our content, measure the performance of affiliate links, analyse and develop this part of our business.Data that indirectly identifies you (such as your IP address or mobile device ID) or data that directly identifies you (such as your name, username, email address and location data).Legitimate interest.
Communicate our terms, notify you about changes to them and communicate with you about non-compliance.Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username and email address).Creation or performance of a contract.
Communicate our Privacy Policy and notify you of changes to themData that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username, and email address).Compliance with a legal obligation.
Conduct surveys or undertake similar types of research so that we can improve and develop our business, our Services.Data that directly identifies you (such as your name, username, name, email address and location data)Consent.
Allow you to take part in a prize draw, sweepstake, or other competition or other promotional activity.Data that directly identifies you such as your name, username, and email address.Creation or performance of a contract.
Administration and protection of our business including troubleshooting, data analysis, testing, system maintenance, user support, reporting and hosting data, administration and IT services, network security, fraud prevention, customer services and business reorganisation, including exchanging information with third parties for fraud protection and spam/malware prevention.Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address).Legitimate interest.
Send marketing communications to you if you subscribe to our newsletters or other products and services. We explain how we comply with the law and how you can manage your preferences in our “Marketing choices” section.Data that directly identifies you such as your name and email address.Consent
Communicate with you about our services that you sign up to receive when you create an Account and transactions that you conduct using our services, including published content you visit, content you submit for publication on zimbabwe263.com, and content posted by you on zimbabwe263.com (including your comments on content, feedback and reviews).Data that directly identifies you such as your name and email address.Creation or performance of a contract
Comply with applicable laws, regulations and legal and regulatory processes.Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and/or data that directly identifies you (such as your name, username, and email address).Creation or performance of a contract

Legal rights for EEA and UK users

If you are an EU or UK resident, you have certain rights in respect of the information that we hold about you. Below is a short overview of those rights:

  • Access. With some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you. Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish.
  • Correction. You have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend to matters of opinion, such as views expressed in editorial content.
  • Deletion. In some limited circumstances, you have the right to have personal data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law).
  • Objection. You have the right to object to our processing of your personal data where we rely on “legitimate interests” as our legal basis for processing, but we may be able to continue processing if our interest outweighs your objection.
  • Withdrawing consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.

How to exercise your rights

To exercise your rights, please complete the form on our Request Portal which can be accessed here. In order to protect your privacy and that of others, we will ask you to prove your identity before we take any steps in response to a request you have made. If a third party is making a request on your behalf, we will ask them to prove that they have your permission to act for you.

We may contact you to ask you for further information to help you exercise your legal rights or to speed up our response. We will try to respond to requests within one month and we will let you know if we need to take longer, for example because your request is complicated. We may have an overriding lawful basis for processing your personal data, or certain exceptions may apply. If we refuse your request, we will explain why. You may also reach us at hello@zimbabwe263.com.

Complaints

You have the right to complain about data privacy matters to the Information Commissioner’s Office (www.ico.org.uk), or the relevant data protection regulator in your country of residence. You can contact the ICO on 0303 123 1113. We invite you to raise your concerns with us first, so that we can try to resolve them.

EU Representative

We have appointed IT Governance Europe Limited to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR) or have any queries in relation to your rights or general privacy matters, please email our Representative at simba@zimbabwe263.com. Please ensure to include our company name in any correspondence you send to our Representative.

Privacy Information for United States Residents

Residents of certain states have additional rights and choices beyond what is described in Sections 1-13 of this Privacy Policy. This section addresses those additional rights.

United States Privacy Rights

  • Right to Deletion. You have the right to request that we delete certain personal data we have about you.
  • Right to Access. You have the right to request that we inform you about the categories of personal data we collect or disclose about you; the categories of sources of such data; the business or commercial purpose for collecting your personal data; and the categories of third parties with whom we share/disclose personal data. Such information is also set forth above in this Privacy Policy. You may also request that we provide you access to and/or a copy of the specific pieces of personal data we collected about you (also called a data portability request).
  • Right to Correction. If you feel that any of the records of personal data we have about you are incorrect, you have a right to request that we correct those inaccuracies. This right does not extend to matters of opinion, such as views expressed in editorial content.
  • No Discrimination. You have the right to not be discriminated against (as provided for in the applicable US Privacy Law) for exercising your rights.
  • Right to Opt-Out. You have the right to opt-out of the “sale” of your personal data, or the “sharing” of your personal data for interest-based or other targeted advertising on third party websites. Note that “sale” is defined broadly and may include allowing third parties to receive certain data, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on our Services or other sites and apps. We engage in these activities because advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you content relevant to you.

How to Exercise Your Rights

Opt-out of Sale/Share/Targeted Advertising.

If you would like to opt out of the sale or sharing of your personal data for targeted advertising, please visit this page:  “Do Not Sell or Share My Personal Information” or contact us at  hello@zimbabwe263.com.

Please note that because these activities are based on Cookies, you will need to opt out again if you visit one of our Services from a different device or browser or if you clear your Cookies. Your selections are specific to the device, website, and browser you are using, and are deleted whenever you clear your browser’s cache. We do not knowingly sell or share the personal data of minors under 16 years of age without legally-required affirmative authorisation.

Exercising Your Other Privacy Rights

If you have a registered account with us, you can submit your access or deletion request by signing into your account. 

You may also reach us at hello@zimbabwe263.com.

Please note that the verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorised representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an Account with us. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Only you or a person that you authorise to act on your behalf may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or deletion twice within a 12-month period.

Please note that certain data may be exempt from such access, data portability, correction, and deletion requests under US Privacy Law. For example, we need to retain certain data in order to provide the Services to you or to comply with our legal obligations.

If we are unable to honour your request or you are not satisfied with the outcome of your request, you have the right, within a reasonable period of time, to appeal our decision. Please send your appeal by email to data-privacy@zimbabwe263.com with “Privacy Appeal” in the subject line

Notice for California Users

This section provides you with our practices regarding the collection, use, and disclosure of your personal data in the 12 months prior to our last update to this Policy (see the date at the top). It also explains your rights regarding your personal data that we collect pursuant to applicable U.S. state privacy laws.

Categories of Information We Collect:

  • Your contact details (e.g. your name, address, email address, telephone number and username).
  • Payment information (e.g. bank account number, credit card number, debit card number, or any other financial information).
  • Demographic information (e.g. race, ethnic origin, religion, or sexual orientation).
  • Purchase history & preferences (e.g. records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).
  • Internet activity information (e.g., browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, or questions and other messages you address to us directly through online forms or by email).
  • Inferences (e.g. inferences about your personal preferences and attributes drawn from profiling).
  • Online identifiers (e.g., IP address, ADID/IDFA, cookie IDs, internal identification numbers).
  • Location data (e.g. your city, state or country information).
  • Application information (for job applicants) (e.g. your passport number, driver’s licence or other state identification card number, education, and employment information)

Categories of Sources:

  • You
  • Your device
  • Data partners.

Purpose of Collection

  • To communicate with you, including to process your requests for products/services and/or information.
  • To register your Account.
  • To improve our Service, including to better understand our customer base, meet our diversity and inclusion goals; and to help our business partners do the same.
  • To enforce our User Agreement, and for the administration and protection of our business.
  • To comply with applicable law, regulations, and legal and regulatory processes.
  • To advertise and market our Services, and the products and services of our advertisers.

If you opt-in to do so, we may use your name and email address for our marketing purposes and to help our business partners with their marketing.

When Do We Sell or Share Personal Data?

Categories of data sold or sharedCategories of Vendors or Other Entities We sell/Share data With:
Your contact detailsSocial network partners and our business partners.
Internet activity information, inferences and online identifiersAdvertising networks, data analytics vendors, social networks, and other Advertising Partners.

When Do We Disclose Personal Data to Third Parties for Business Purposes

Categories of data Disclosed:Categories of Vendors or Other Entities We disclose data to?
Your contact detailsOur email service vendors, sweepstakes/promotions partners, social network partners, other vendors who assist in providing services on our behalf, and our business partners.
Payment informationOur payment processing vendors.
Demographic informationOur research and survey vendors, and our advertisers and other business partners.
Purchase history & preferencesOur affiliate partners and other vendors who assist in providing services on our behalf.
Internet activity information, inferences and online identifiersAdvertising networks, internet service providers, data analytics vendors, operating systems and platforms, and social networks.
Location dataInternet service providers, data analytics vendors, operating systems, and platforms.

We may share your personal data with government entities when required to do so by law.

Financial Incentives

From time to time, we may offer financial incentives in connection with the collection or use of personal information. The material terms of the financial incentive will generally be presented to you at the time you sign up. You may withdraw from any financial incentive at any time by emailing us at hello@zimbabwe263.com.

Statistics on California Consumer Requests We Receive

The CCPA requires us to provide metrics on the number of requests we have received each year from California consumers and how they have been fulfilled. This information can be found in the chart below.

Privacy Table

*Note: The numbers above reflect requests received from all individuals, rather than requests received from California consumers only.

California Shine the Light Disclosure

Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to ask for a notice identifying the categories of personal customer data which we share with our affiliates and/or third parties for their own direct marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Esquavi Pvt Ltd, 26 Creswick Road, Hillside, Harare, Zimbabwe