Privacy Policy

Last Updated: August 12, 2025

This Privacy Policy describes how City Cloud, a company registered in Zimbabwe, collects, uses, and discloses your personal information. We are committed to protecting your privacy in compliance with Zimbabwe’s Cyber and Data Protection Act [Chapter 12:07] and its associated regulations, including Statutory Instrument 155 of 2024.

By using City Cloud’s services, you accept and consent to the practices described in this Privacy Policy.

1. Information We Collect

We collect personal information that you provide to us directly when you register for an account, use our services, or communicate with us. The types of personal information we collect are:

  • Phone Number: We collect your phone number for essential purposes, including account verification, multi-factor authentication, and to provide service-related communications as required by our terms of service.
  • Email Address: We collect your email address for account registration, to send you important notifications regarding your account and our services, and to communicate with you about updates, offers, and promotions.

2. Lawful Basis for Processing Your Information

We process your personal information based on the following lawful grounds as provided in the Cyber and Data Protection Act:

  • Consent: We process your data with your explicit consent, which you provide when you agree to this Privacy Policy and our Terms of Service.
  • Contractual Necessity: The processing of your phone number and email address is necessary for the performance of a contract to which you are a party (i.e., providing you with our services).
  • Legitimate Interests: We have a legitimate interest in processing your data to ensure the security of our services, prevent fraud, and improve the user experience. Where we rely on legitimate interests, we ensure your rights and freedoms are not overridden by our interests.

3. How We Use Your Information

 

We use the personal information we collect for the following specified, explicit, and legitimate purposes:

  • Service Provision: To provide, operate, and maintain your City Cloud account and our services.
  • Communication: To communicate with you about your account, security updates, changes to our policies, and promotional information (with your consent).
  • Security: To verify your identity, protect your account from unauthorized access, and detect and prevent fraudulent activities.
  • Customer Support: To respond to your inquiries, provide technical support, and resolve issues related to your use of our services.

 

4. Your Data Protection Rights

 

Under the Cyber and Data Protection Act, you have the following rights concerning your personal data:

  • Right to Access: You have the right to request a copy of the personal data we hold about you.
  • Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
  • Right to Erasure (Right to Be Forgotten): You have the right to request the deletion of your personal data from our servers. Upon a valid request, we will take all reasonable steps to delete your data, subject to any legal obligations to retain certain records for a specified period (e.g., for financial, tax, or legal compliance purposes).
  • Right to Object: You have the right to object to our processing of your personal data for direct marketing purposes.
  • Right to Withdraw Consent: Where we rely on your consent to process your data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact our Data Protection Officer at [Insert DPO’s email address here].

 

5. How We Share Your Information

 

We do not sell, rent, or trade your personal information to third parties. We may share your information with trusted third-party service providers who assist us in operating our business and delivering our services, such as:

  • Cloud Hosting Providers: To securely store your data.
  • Communication Services: To send emails and SMS notifications.

These third-party providers are contractually bound to protect your information and are only permitted to use it for the specific purposes we have authorized. We will also disclose your information if required by Zimbabwean law or a court order, or to protect our rights, safety, or the safety of others.

 

6. Security of Your Information

 

We are committed to the security of your personal data. We implement appropriate technical and organizational measures to protect your information from unauthorized access, disclosure, alteration, and destruction, in line with the Cyber and Data Protection Act. These measures include data encryption, access controls, and regular security audits.

In the unlikely event of a data breach, we will notify the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ), as the designated Data Protection Authority, within 24 hours of becoming aware of the breach. We will also notify you if the breach poses a high risk to your rights and freedoms.

 

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. When your data is no longer needed, we will securely destroy or anonymize it.

8. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new policy on our website and updating the “Last Updated” date.

9. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact our Data Protection Officer:

Email:mmakumucha@citycloud.co.zw