Privacy Policy
We (also referred to as “we”, “us” or “our”) are committed to protecting your Personal Data and respecting your privacy.
This Privacy Policy explains how we collect and store the information you provide through the website https://dawnvermogrove.net (the Dawn Vermogrove).
We uphold the following principles:
We want you to be able to make informed decisions about how your Personal Data is used and processed. To support this, we use various methods and procedures to provide clear and relevant information. Where we consider that specific details are needed, we will share them with you at the appropriate time. We are also available to answer any questions you may have, subject to any limitations required by law.
1. The Scope?
This Policy explains the types of Personal Data Dawn Vermogrove collects about natural persons, as well as how we process it, share it with third parties, protect it, and manage related procedures.
This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or through additional information that we hold or can reasonably access.
In this Policy, “processing” refers to any operation involving the use or collection of Personal Data, including its management, organisation, structuring, and storage.
Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly request or collect information from persons under 18, and we do not knowingly allow them to use our services. If we become aware that we have collected information relating to a child, we will delete it as soon as reasonably possible.
2. What Personal Data Do We Hold About You?
When you use our services and channels, or visit our website, we collect Personal Data. In some cases, we may ask you to provide your Personal Data. In others, we collect it by analysing how our Services or service channels are used, or by receiving information about you from our third-party partners.
3. You are not required to provide the company with your personal information, and there are no consequences if you choose not to.
You are under no obligation to provide Us with any Personal Data. However, in some circumstances, if you choose not to provide it, We may be unable to deliver the Services or users may be unable to access the website.
4. What types of personal data do we collect? When you visit our website, we may collect the following personal information:
This includes details of your online activity log, traffic data such as your IP address, access date and time, the language you used, software crash logs, browser type, and information about the device you used. This information is not personal data and cannot be used to identify you.
Personal Data we receive from you: any personal data you choose to provide to us when you access a third-party online trading platform through us.
Personal information you provide directly to third-party platforms to facilitate trading: this may include your full name, address, phone number, and email address.
5. Legal basis and reasons for processing personal data
The Company processes your Personal Data for the purposes set out in this section, and only where there is an applicable legal basis for doing so.
The Company cannot use your Personal Data without a valid legal basis. The legal grounds that allow the Company to process your Personal Data are:
- You have consented to the processing of your Personal Data for one or more specific purposes. This applies where you provide personal information through the Website so that we may share it with a third-party trading platform.
- The Company, or a third party, may need to process personal data to pursue legitimate interests. This may include improving Our Services or defending legal claims.
- Processing must be necessary to comply with a legal obligation.
Please email us if you would like more information about the processing we carry out to protect legitimate interests.
Below, we set out the reasons and legal grounds on which we may use the Personal Data you provide to us.
Scope, Legal Basis
1. Where you request access to digital trading services, we may collect your Personal Data and share it with third-party providers as necessary to process your request.
You have given consent for your Personal Data to be processed for one or more purposes.
2. To respond to your requests, questions, or concerns. Personal Data is required to address any queries you may have about the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
3. Personal Data may be processed where necessary to comply with legal obligations or with administrative, judicial, or other lawful requirements.
Processing is necessary to comply with legal obligations.
4. To improve Our Services. We may use Personal Data to improve Our Services, including, among other things, crash reports and malfunction reports collected in connection with the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
5. To help prevent fraud and misuse of Our Services
Processing is necessary for the legitimate interests of the Company or a third party.
6. To carry out and manage activities necessary for the delivery of Our Services, including back-office operations, business development, strategic decision-making, oversight processes, and related functions.
Processing is necessary for the legitimate interests of the Company or a third party.
7. To carry out analysis, including statistical analysis, and to make decisions on various matters using a range of analytical methods.
Processing is necessary for the legitimate interests of the Company or a third party.
8.
To protect our assets, rights and interests, as well as those of third parties, and to establish or defend legal claims
We may process Personal Data where necessary to protect our rights, interests and assets, or those of third parties, in line with applicable laws, regulations, agreements, terms, conditions or policies.
Processing is necessary to pursue the legitimate interests of the Company or a third party.
6. Sharing Personal Data with Third Parties
The Company may share Personal Data with third-party service providers that support our operations, including hosting and storage providers, IP address information services, and providers that help us analyse user experience.
You may also request that we disclose specific Personal Data about you to third-party trading platforms. In those circumstances, we will share the Personal Data you provide to us with the relevant third-party trading platforms. Their use of your Personal Data will be governed by their own privacy policies. Your Personal Data may be shared with more than one trading platform.
The Company may share Personal Data with related entities or business partners where this helps provide the resources needed to develop, maintain, and improve the products and services offered to customers.
Where it is necessary to protect the rights or property of third parties, the Company may disclose Personal Data to regulatory bodies, local authorities, or other competent public authorities.
We may also share Personal Data about you with prospective investors, buyers, or lenders of the Company or any other company within the group if a relevant transaction takes place, including the sale or transfer of assets of the Company or another group company, or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or another business within the group.
7. Third-party cookies and services
We may use third-party service providers, including advertising partners and analytics companies, on our website. These providers may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit or use the website. They help collect information about your preferences and browsing activity so that we can improve your user experience, remember your settings, and personalise the products and services that may be relevant to you. Cookies may also be used for statistical and analytical purposes.
Some cookies we use may be session cookies. These are stored temporarily on your device and remain only for a short time, usually until you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for a set period after you close your browser. They help the Website recognise you when you return and make it easier for you to continue using the website.
Types of Cookies:
We may use them for the following purposes:
1. Strictly necessary cookies
These cookies are essential for accessing the features you request and for moving around our website. They help us provide the information, products and services you have requested.
They are also needed for your device to download and stream data, allowing you to browse the website, use its features, and return to pages you have visited before.
Cookies may collect Personal Data, including your username and the date of your last login, to verify that you are signed in to the site. Session Cookies are deleted when you close your web browser.
2. Functionality Cookies
Cookies help us recognise you whenever you visit our site and remember your preferences.
Cookies may collect Personal Data, such as your username and last login date, to verify that you are signed in to the site. Session Cookies are deleted when you close your web browser.
3. Cookies for performance
We use cookies to collect statistical information about the site’s performance and to help us improve it. They also allow us to analyse how our website is used.
Cookies store anonymous data that cannot be linked to an identified or identifiable natural person. Some cookies are deleted when you close your browser, while others remain valid indefinitely.
Cookies have been blocked or deleted
To block or delete cookies, adjust your browser settings. The links below explain how to do this in some of the most commonly used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note that some or all of the Website’s functions and features may not work as expected if this happens.
ONLINE TRACKING NOTICE
This service does not currently recognise Do Not Track signals.
8. Retention of your personal data
The Company will retain Personal Data about you only for as long as reasonably necessary to meet the purposes for which it is processed, as set out in this Policy, or for any longer period allowed under applicable law, regulations, policies or lawful orders.
We will share your information with third-party trading platforms for 12 months. If you consent, we may continue sharing your data for a further 12 months.
We review the Personal Data we hold on a regular basis to confirm whether it is still required.
9. Transfers of personal information outside Zimbabwe or to an international organisation
Your personal information may be transferred outside the country where you live, including to another jurisdiction or to an international organisation. The Company takes the necessary steps to protect the Personal Data you provide and to ensure that individuals can exercise their rights and access effective legal remedies.
These safeguards are available where required under applicable data protection laws.
- Transfer to another country or an international organisation where the relevant competent authority has recognised that an adequate level of protection is provided for the Personal Data being transferred.
- The transfer is carried out under a legally binding and enforceable agreement between the relevant public bodies or authorities, as permitted by applicable data protection law.
- The transfer was carried out in accordance with recognised contractual safeguards for cross-border personal data transfers, as required under applicable data protection law. Details of these safeguards are available from the relevant data protection authority.
The Company can provide details of the security measures used to protect your Personal Data when it is transferred to third countries or international organisations. Please email us at info@dawnvermogrove.net.
10. Protection of Personal Information
We have put in place appropriate organisational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, alteration, or unauthorised disclosure.
However, we cannot guarantee that your Personal Data will remain completely secure at all times. We are not liable for any indirect, incidental, or consequential loss arising from the use or disclosure of Personal Data, including where disclosure results from transmission errors, unauthorised access by a third party, or any other cause beyond our reasonable control.
Where required by law or by obligations outside our control, we may need to provide Personal Data relating to you to third parties, including public authorities. In such circumstances, we cannot control the security measures applied by those third parties to your Personal Data.
Personal Data cannot be transmitted over the internet in a fully secure manner. The Company cannot guarantee the security of any Personal Data you send to Us online.
11. Links to third-party websites
The website may include links to third-party websites and applications. These websites and applications are not under the Company’s control, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to any activity carried out on those third-party websites or applications.
Before visiting or using any third-party website or application, we recommend that you review its privacy policy. You should also take care before sharing any Personal Data with them.
12. Changes to this Policy
When accessing any third-party websites or apps, we recommend that you review their privacy policies before using them or sharing any Personal Data with them.
13. Your rights regarding your personal information
You have the right to ask Us to confirm whether Personal Data relating to you is being processed, to correct any inaccuracies, and to delete any Personal Data that We are not required to keep. You may also ask Us to restrict certain types of processing of your personal information.
If you are resident in a jurisdiction that grants additional privacy rights, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. You may request to exercise your rights by sending an email to the address below.
Access rights
The Company may confirm whether Personal Data relating to you is being processed and whether it is accurate. Where such processing is taking place, you may request access to your Personal Data.
The Company will provide an electronic copy of the Personal Data being processed and may charge a reasonable fee for any additional copies requested. Where you ask for the information electronically, it will be provided in electronic form.
Your right to access Personal Data must not adversely affect the rights and freedoms of others. If a request would prejudice another person’s rights or freedoms, the Company may refuse the request or limit the extent to which it is fulfilled.
Right to rectification
The Company will correct inaccurate Personal Data where required. You may also request the completion of any incomplete Personal Data relating to you, taking into account the purpose for which it is processed.
Right to Erasure
This right may apply where: (a) the Personal Data is no longer needed for the purpose for which it was collected or processed; (b) you withdraw consent and there is no other lawful basis for processing; (c) you object, on grounds relating to your particular situation, to the processing of Personal Data based on legitimate interests pursued by Us or by a third party; (e) the Personal Data has been processed unlawfully; or f) the Personal Data must be deleted to comply with a legal obligation of the company.
This right does not apply where processing is necessary (a) to comply with a legal obligation under applicable law; or (b) to establish, exercise or defend legal rights.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data.
Where you request restriction of Personal Data, it may only be stored and processed with your consent, for the establishment, exercise or defence of legal rights, for the protection of the rights of another natural person, or for reasons of substantial public interest under applicable law.
Right to data portability
Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the right to receive the Personal Data you provided to the Company.
You may ask for your Personal Data to be transferred directly from the Company to another controller, where this is technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to transfer data must not adversely affect the rights or freedoms of any other person.
Right to challenge
You have the right to object at any time to the processing of Personal Data relating to you where the processing is based on legitimate interests pursued by the Company or by a third party. This includes profiling based on those legitimate interests. If we demonstrate compelling legitimate grounds for processing that override your rights, freedoms or interests, or where processing is required for the establishment, exercise or defence of legal rights, we may continue to process the Personal Data.
For direct marketing, you have the right to object at any time to the processing of Personal Data relating to you.
Right to refuse consent
You may withdraw your consent for Us to process Personal Data relating to you at any time. This will not affect the lawfulness of any processing carried out on the basis of your consent before it was withdrawn.
You have the right to lodge a complaint with the authority that supervises you.
You may submit a complaint to the relevant data protection or supervisory authority responsible for protecting individuals’ rights in relation to the processing of Personal Data.
Applicable laws may limit your rights in relation to Personal Data concerning you, as described in this section 13.
We will provide the information requested under your rights in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature of the request and the number of requests received. We will inform you of any extension and the reasons for it within one month of receiving your request.
Unless this is contrary to section 13 of this agreement, information requested under your rights in section 13 will be provided free of charge. Where a request is unfounded or excessive, particularly if repeated, We may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act on the request.
If we have reasonable doubts about the identity of the person making the request, the Company may ask for additional information.