Privacy Policy
DOLPHIN TELECOMS PRIVACY POLICY
This Privacy Policy explains how Dolphin Telecoms collects, uses, stores, and protects your personal data in compliance with the Zimbabwe Cyber and Data Protection Act [Chapter 12:07] and POTRAZ regulations. We are registered as a Data Controller with POTRAZ.
1. Who We Are
Dolphin Telecoms is the Data Controller responsible for your personal information collected through our website www.dolphintelecoms.com. We are regulated by POTRAZ (Postal and Telecommunications Regulatory Authority of Zimbabwe) as the Data Protection Authority under the Cyber and Data Protection Act [Chapter 12:07].
2. Personal Information We Collect
Personal data means any information or set of information that directly or indirectly identifies any individual.
We may collect:
- Identity data: Full name, date of birth, national ID number (for KYC verification)
- Contact data: Email address, phone number, physical address
- Account data: Username, encrypted password, account preferences
- Transaction data: Purchase history, payment records and order details
- KYC documentation: Government-issued ID, proof of address and passport (where required)
- Communications: Messages, emails and enquiries sent to us
3. Why We Process Your Personal Data
We process your personal data for the following purposes:
| Purpose | Description |
|---|---|
| Responding to Your Queries | Responding to enquiries received through our website, social media or other communication channels. |
| Marketing and Surveys | With your consent, sending offers, surveys and marketing communications, and personalising them. |
| Product & Service Improvement | Improving our products, website and services, identifying trends and enhancing customer experience. |
| Service Delivery | Providing the services you have signed up for. |
| Order Processing & Delivery | Processing purchases, delivering products and managing transactions. |
| Compliance & Legal Obligations | Meeting legal and regulatory obligations and protecting our legal interests. |
| Employment Onboarding | Assessing applicants and managing recruitment opportunities. |
4. Lawful Basis for Processing Your Personal Information
| Purpose | Legal Basis | Personal Data Used |
|---|---|---|
| Processing your order | Contractual obligation | Identity, contact, transaction |
| Account management | Contractual obligation | Identity, contact, account |
| KYC verification | Legal obligation | Identity, KYC documents |
| Marketing | Consent | Contact, preferences |
| Fraud prevention | Legitimate interest | Identity, technical, transaction |
| Analytics & Improvement | Legitimate interest | Usage, technical |
| Legal compliance | Legal obligation | All relevant data |
5. Payments
- We do not store, process or transmit full payment card numbers on our own systems.
- All card payments are processed through PCI-DSS compliant third-party payment processors.
- Payment transactions are encrypted and processed through PCI-DSS Level 1 compliant gateways.
- We retain only transaction reference numbers, amounts and dates.
- For mobile money and EcoCash payments, only transaction IDs and confirmation references are retained.
- Billing information is securely stored for invoicing and refund purposes.
- We will never ask for your card details via email, phone or social media.
6. Data Sharing
We share personal information only where necessary to provide our services.
- Provision of services including SIM activation and mobile number assignment.
- Roaming services.
- Billing and usage reconciliation.
- Regulatory reporting to POTRAZ where legally required.
- Law enforcement requests supported by valid legal authority.
We do not sell your personal or financial information. All partners operate under strict Data Sharing Agreements.
7. Data Retention
Personal information is retained only for as long as necessary to provide services, meet legal obligations and fulfil the purposes described in this policy. When no longer required, information is securely deleted or anonymised.
8. Your Rights
Under Section 14 of the Cyber and Data Protection Act [Chapter 12:07], you have the right to:
- Access your personal data.
- Correct inaccurate or incomplete information.
- Request deletion where legally permitted.
- Object to certain processing activities.
- Be informed how your data is collected and used.
- Give or withdraw consent.
- Lodge a complaint with the Data Protection Authority.
- Not be subject solely to automated decision-making or profiling.
9. Security of Your Personal Information
- SSL/TLS encryption for data in transit.
- AES-256 encryption for stored personal data.
- Role-based access controls and multi-factor authentication.
- Regular penetration testing.
- Internal and third-party security audits.
- Mandatory cybersecurity training for staff.
- Documented incident response procedures.
10. Children's Privacy
Our website is intended for individuals aged 18 years and above. We do not knowingly collect personal information from children under 18.
- Persons under 18 should not create accounts or submit personal information.
- Parents or guardians who believe a child has submitted information should contact us immediately at privacy@dolphintelecoms.com.
- We do not direct marketing or targeted advertising to minors.
11. Updates to this Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The latest version will always be published on our website.
12. Contact Us
Data Protection Officer
Email: privacy@dolphintelecoms.com
Phone: +263 867 721 0754
Office Address:
77 Jason Moyo Avenue,
Harare, Zimbabwe
