1. Background

(1.1) Footprint Creative collects and uses certain Personal Data. Footprint Creative is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.

(1.2) At Footprint Creative, we respect your privacy and we are committed to keeping your Personal Data secure.

(1.3) This Privacy Policy is directed to individuals whose Personal Data we handle in the course of carrying on our commercial activities. Those individuals could be Clients or prospective Clients or their representatives, agents or appointees, or an employee, director, officer, or representative of another organization with which we have a business relationship. This Privacy Policy is also directed to visitors to our websites.

1. Overview of circumstances in which we handle your personal data

(2.1) This Privacy Policy explains how we handle Personal Data that we collect in the following ways:

(a) Information we receive through Footprint Creative Websites. Details of how we handle the information we receive through Footprint Creative Websites are set out in paragraph 10 of this Privacy Policy; and

(b) Information we receive as a result of Footprint Creative Products and Services.

1. The types of personal data we collect

(3.1) Many of the products or services offered by Footprint Creative require us to obtain Personal Data in order to provide the products and services we have been engaged to provide. We will collect and process the following Personal Data:

• Information that you provide to Footprint Creative. This includes information about you that you provide to us. The nature of our relationship with you will determine the kind of Personal Data we might ask for, though such information may include:
  • basic Personal Data such as first name; family name; national insurance number; email address; phone number; address (including city postcode and country); occupation and job title;
  • sensitive Personal Data, which may be included in information we handle about your nationality, health-related information, disability status, or details of political affiliations.

• Information that we collect or generate about you. This may include:
  • files that we may produce as a record of our relationship with our Clients and prospective Clients, including contact history; and
  • any Personal Data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements or any Personal Data that we obtain in relation to your use of Footprint Creative Websites.

• Information we obtain from other sources. This may include:
  • information from publicly available sources, including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers, records, and other publicly accessible sources;
  • – information obtained from independent financial advisors (IFAs), other professional advisers, product providers, events organisers, other agents and/or representatives, industry databases and other business intelligence tools Footprint Creative subscribes to; and
  • information obtained from sanctions checking and background screening providers.

1. How we use your information

(4.1)   Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• to allow Clients and prospective Clients to use and access Footprint Creative Products and Services;
• to assess Client and prospective Client applications or contracts for Footprint Creative Products and Services;
• to set up / on-board prospective Clients to use Footprint Creative Products and Services;
• to keep our records up to date;
• to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
• to administer or maintain IT systems in order to uphold standards of service;
• for ongoing review and improvement of the information provided on Footprint Creative Websites to make them user friendly and prevent potential disruptions or cyber attacks;
• to understand feedback on Footprint Creative Products and Services and to help provide more information on the use of those products and services quickly and easily;
• to communicate with Clients and prospective Clients in order to provide services or information about Footprint Creative and other Footprint Creative Products and Services;
• to effectively manage and strengthen Client and prospective Client relationships, understand Client and prospective Client needs and interests and learn more about our Clients and prospective Clients in order to develop, improve and manage the products and services we can offer;
• for the management and administration of our business;
• in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
• for the administration and maintenance of databases storing your Personal Data.

(4.2)  When we use your Personal Data, we comply with applicable law. The law allows or requires us to use your Personal Data for a variety of reasons. These include instances where:

• we are performing our contractual obligations;
• we have legal and regulatory obligations that we have to discharge;
• we may need to do so in order to establish, exercise or defend our legal rights or those of our Clients or for the purpose of legal proceedings;
• we have obtained your consent;
• the use of your Personal Data as described is necessary for our legitimate business interests, such as:
  • allowing us to effectively and efficiently manage and administer the operation of our business;
  • maintaining compliance with internal policies and procedures;
  • enabling quick and easy access to information on Footprint Creative Products and Services; and
  • offering effective, up-to-date security solutions for mobile devices and IT systems.

(4.3) Within Footprint Creative, your Personal Data is accessed only by employees of Footprint Creative that have a need to access it for the purposes described in this Privacy Policy.

1. Disclosure of your information to third parties

(5.1) We may share your Personal Data within Footprint Creative for the purposes described above.

(5.2) We may also share your Personal Data outside of Footprint Creative as further described below:

• with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;
• with representatives, agents, custodians, intermediaries and/or other third party product providers appointed by the Client or prospective Client (such as accountants, professional advisors, custody service providers and product providers);
• with third-party agents and contractors for the purposes of them providing services both to us (for example, Footprint Creative’ accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies, and debt collectors) and to Clients or prospective Clients. These third parties will be subject to appropriate data protection obligations;

1. How we safeguard your personal data

(6.1) Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value. We operate layers of safeguards and defenses designed to ensure that Footprint Creative is able to operate safely. We have extensive controls and mechanisms in place designed to detect, respond and recover in case of any adverse events that may arise.

1. How long we keep your personal data

(7.1) The length of time for which we hold your Personal Data will vary as determined by the following criteria:

• the purpose for which we are using it (as further described in this Privacy Policy at paragraph 4.1) – we will need to keep the data for as long as is necessary for that purpose; and
• our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

1. Your rights

(8.1) In all the above cases in which we collect, use or store your Personal Data, you may have the following rights. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;

• in some circumstances, the right to receive some Personal Data in a structured, commonly used, and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Footprint Creative;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are required or entitled to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

(8.2) You can exercise your rights by contacting us using the details provided in paragraph 10 below.

1. Changes to this Privacy Policy

(10.1)  Any changes we make to our Privacy Policy in the future will be posted on this website and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

1. Questions and concerns

(10.1)  If you have any questions or concerns about Footprint Creative’ handling of your Personal Data, or about this Privacy Policy, please contact us at:

Corner First Street and Jason Moyo, Anchor House 4th floor. Harare, Zimbabwe

info@footprintcreative.co.zw

+263774843620

+263784360344

We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.

Last updated: October 17, 2021