PRIVACY POLICY

FENOM TOWN PLANNING AND CONSTRUCTION (PRIVATE) LIMITED

Entity No: 17511A02102024

Incorporated 22 October 2024

Registered Office: 1883 Granary, Snake Park, Harare, Zimbabwe

“Building Sustainable Communities, One Plan at a Time.”

1. INTRODUCTION

FENOM Town Planning and Construction (Private) Limited (“FENOM”, “we”, “our”, “the Company”) is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us.

This Privacy Policy explains how we collect, use, store, and protect personal data in accordance with applicable Zimbabwean law.

By using our website or engaging our services, you consent to the practices described in this Policy.

2. LEGAL FRAMEWORK

This Policy is governed by:

• Cyber and Data Protection Act [Chapter 12:07] (Zimbabwe)
• Companies and Other Business Entities Act [Chapter 24:31]
• Electronic Transactions and Electronic Commerce Act [Chapter 12:23]
• Applicable common law principles of confidentiality

We process personal data lawfully, fairly, and transparently.

3. INFORMATION WE COLLECT

3.1 Personal Identification Information

• Full name
• National ID / Passport (where required for contracts)
• Contact details (phone, email, address)
• Company registration details

3.2 Project & Property Information

• Title deeds
• Survey diagrams
• Site coordinates
• Development proposals
• Building plans

3.3 Financial Information

• Payment records
• Banking details (for transactions)
• Invoices
• Investment data (for development projects)

3.4 Website Data

• IP address
• Browser type
• Cookies
• Usage analytics

4. PURPOSE OF DATA COLLECTION

We collect personal data for the following purposes:

• Providing town planning and construction services
• Preparing contracts and service agreements
• Submitting applications to local authorities
• Regulatory compliance
• Invoicing and financial management
• Communicating with clients
• Improving website functionality
• Risk management and legal compliance

We do not collect data beyond what is necessary for legitimate business purposes.

5. LAWFUL BASIS FOR PROCESSING

Under the Cyber and Data Protection Act, we process data based on:

• Performance of a contract
• Legal obligation
• Legitimate business interest
• Client consent

6. DATA SHARING

We may share information only where necessary with:

• Local Authorities
• Environmental Management Agency (EMA)
• Ministry departments
• Contractors and consultants engaged on a project
• Legal advisors
• Financial institutions
• Regulatory bodies

We do not sell personal data.

All third parties are required to maintain confidentiality.

7. DATA RETENTION

We retain personal data:

• For the duration of the contract
• For statutory compliance periods
• For tax and audit requirements
• For legal protection purposes

After this period, data is securely archived or destroyed.

8. DATA SECURITY

We implement appropriate safeguards including:

• Secure digital storage
• Password protection
• Access controls
• Restricted internal access
• Secure document handling procedures

However, no electronic system is 100% secure. We take reasonable steps to minimize risk.

9. CLIENT RIGHTS

In accordance with Zimbabwe’s Cyber and Data Protection Act, you have the right to:

• Request access to your personal data
• Request correction of inaccurate data
• Request deletion (subject to legal obligations)
• Withdraw consent where applicable
• Lodge a complaint with the Data Protection Authority

Requests may be submitted in writing to the Company.

10. COOKIES & WEBSITE ANALYTICS

Our website may use cookies to:

• Improve user experience
• Track usage patterns
• Enhance site performance

Users may disable cookies through browser settings.

11. CROSS-BORDER DATA TRANSFERS

Where projects involve international consultants or investors, data may be transferred outside Zimbabwe.

Such transfers will comply with applicable data protection safeguards.

12. CHILDREN’S DATA

Our services are not directed toward individuals under 18 years of age. We do not knowingly collect personal data from minors.

13. CONFIDENTIAL PROJECT INFORMATION

14. DATA BREACH PROCEDURE

In the event of a data breach:

• The Company will assess the risk
• Notify affected parties where required
• Take corrective measures
• Cooperate with regulatory authorities

15. CHANGES TO THIS POLICY

FENOM reserves the right to amend this Privacy Policy as required by law or operational updates.

The latest version will always be available on our website.

16. CONTACT INFORMATION

For privacy-related inquiries:

FENOM Town Planning and Construction (Pvt) Ltd
1883 Granary, Snake Park
Harare, Zimbabwe
Email: info@fenomtpc.com
Phone: +263 71 393 7162

This Privacy Policy is effective as of: January 2026