Privacy Policy

Introduction

Your privacy is important to Fidelity Gold Refinery (FGR), and we are dedicated to protecting and respecting it. At FGR, we are committed to protecting the privacy of our stakeholders, including staff, clients, partners and visitors to our website. This Privacy Policy (“Privacy Policy”) outlines how we collect, use, store, and protect personal data in compliance with applicable laws, including the Cyber and Data Protection Act [Chapter 12:07]. FGR processes personal data lawfully, fairly and transparently and only for specified, explicit and legitimate purposes. By using this website, you acknowledge this Privacy Policy and, where consent is required by law, provide your consent to the processing of your personal information as described herein.

Scope

This policy applies to all personal data collected through:

  1. The Fidelity Gold Refinery website (www.fgr.co.zw).
  2. Other digital platforms, applications, and online services operated by FGR.
  3. Interactions with FGR in any digital or electronic format.

Your Personal Information

You can browse the main FGR website without identifying yourself or providing any personal information. However, certain services, enquiries, transactions or interactions may require you to provide personal information.

Who Will Process My Personal Information

When you view or use www.fgr.co.zw, Fidelity Gold Refinery (‘we’, ‘us’ and ‘the Company’) is the data controller.

This privacy notice applies to the use of your personally identifiable information (also known as PII or ‘personal data’) by Fidelity Gold Refinery, including its Directorates, Management, Departments and Centres.

We, along with our third-party vendors, collect certain information about your use of www.fgr.co.zw, including your IP address and browser type.

Data We Collect

We may collect the following categories of personal data:

  1. Personal Identification Information: Name, address, phone number, email address, national ID, passport number.
  2. Employment and Professional Data: Recruitment information, employment details and other information necessary for employment or business-related purposes.
  3. Online Interaction Data: IP addresses, browser type, device information, cookies, and usage data from our website or applications.
  4. Financial Data: Bank account details, payment history, and transaction records.
  5. Transaction and Customer Due Diligence Data: Information required to process gold, precious-metal and jewellery-related transactions, including customer verification and other information required for regulatory, security and compliance purposes.
  6. Biometric and Sensitive Personal Data: Where necessary and permitted by law, FGR may collect and process sensitive personal data, including biometric information such as photographs, fingerprints or facial recognition data, for purposes including identification, verification, security and regulatory compliance. Such information will only be processed where there is a lawful basis and appropriate safeguards are in place.

How We Use Your Data

If you contact us via email, the email address you provide may be used to send information, respond to your inquiries, or address other requests or questions. Your email address will not be shared, sold, rented, exchanged, or used for commercial purposes by any third party without your explicit consent. More specifically, the data collected is used for the following purposes:

  1. Gold, Precious Metals and Jewellery Sales: Processing gold buying, refining, precious-metal and jewellery-related sales, customer enquiries, transactions and related services.
  2. Website Optimization: Improving user experience, troubleshooting, and performance analytics.
  3. Security: Ensuring the security of our systems and protecting against unauthorized access, fraud and other security risks.
  4. Regulatory Compliance: Meeting legal, regulatory and licensing requirements applicable to our gold, precious metals and related operations.
  5. Marketing and Communication: Sending newsletters, product information, announcements and updates, where permitted and with consent where required.
  6. Business and Transaction Management: Managing customer, supplier, employee and stakeholder relationships, processing transactions, maintaining records, conducting due diligence and protecting FGR’s legitimate business interests.

FGR may process personal data on the basis of consent or where processing is otherwise permitted by law, including where necessary to fulfil a contractual obligation, comply with a legal or regulatory obligation, protect vital interests, perform a task in the public interest, or pursue legitimate interests where permitted by law.

Data Sharing

We do not sell or rent personal data. However, we may share data with:

  • Internal Departments: For operational, administrative, sales, customer service and compliance purposes.
  • Third-Party Service Providers: For website hosting, analytics, payment processing and other business services, ensuring they comply with our privacy standards.
  • Regulatory Authorities: When required by law or for regulatory or legal proceedings.
  • Professional Advisers and Service Providers: Where necessary to support our business, compliance and operational requirements.
  • Data Processors: Where third parties process personal data on behalf of FGR, FGR will take reasonable steps to ensure that appropriate confidentiality, security and data protection obligations are in place.
  • Cross-Border Transfers: Where personal data is transferred, stored or accessed outside Zimbabwe, FGR will ensure that such transfer is undertaken in accordance with applicable data-protection laws and regulatory requirements, including appropriate safeguards to protect the personal data and the rights of data subjects.

Cookies and Tracking

Cookies are small files stored on your computer unless you choose to block them. Our website uses cookies, page-tagging techniques and other similar technologies to enhance user experience after collecting information about your visit. Cookies collect data on browsing habits but do not identify individual users. Users can disable cookies via their browser settings.

The information we collect using cookies include the following:

  • Your IP address
  • The date and time of your visit
  • The version of the web browser you are using
  • The pages you view

We utilize this information to safeguard the security of our website and to monitor its performance. Cookie information will be retained only for as long as necessary for the relevant purpose or as otherwise required by law. It may be disclosed if required to address a security concern or incident.

Data Protection Measures

We implement appropriate security measures to safeguard personal data, including:

  1. Data encryption during transmission and storage.
  2. Access controls to limit unauthorized access to sensitive information.
  3. Regular security audits and vulnerability assessments.
  4. Appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, loss, destruction or other unlawful processing.

However, no method of internet transmission or electronic storage is completely (100%) secure.

In the event of a personal data security breach, FGR will take appropriate steps to contain, investigate and address the breach and will notify POTRAZ and affected data subjects where required by law. FGR will comply with the applicable statutory requirements for reporting security breaches, including the requirement to notify the Authority within 24 hours where applicable.

Data Retention

Personal data is retained only as long as necessary to fulfil the purposes for which it was collected or as required by law. We may retain information for legitimate business, regulatory, audit, security and legal purposes, including for defending against potential legal claims. Where appropriate and legally permissible, data may be anonymized or securely deleted when it is no longer required.

Your Rights

You have the following rights regarding your personal data:

  1. Access: Request access to the personal data we hold about you.
  2. Correction: Request corrections to inaccurate or incomplete data.
  3. Deletion: Request the deletion of your personal data where applicable.
  4. Objection: Object to data processing based on legitimate interests.
  5. Data Portability: Request a copy of your data in a machine-readable format.
  6. Restriction: Request restriction of processing where applicable under the law.
  7. Withdrawal of Consent: Where processing is based on consent, withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

To exercise these rights, contact us at dataprotection@fgr.co.zw.

Children’s Privacy

At Fidelity Gold Refinery, protecting children’s privacy is a priority. Our website and services are primarily intended for individuals aged 18 and above. Where we are required to collect or process personal data relating to an individual under the age of 18, written parental or legal guardian consent will be obtained where required by law.

User Responsibilities

To ensure the security and privacy of your personal data, we ask that you adhere to the following responsibilities:

  1. Account Security:
    • Keep your account credentials confidential and do not share them with anyone.
    • Use strong passwords and take reasonable measures to protect your accounts.
  2. Data Accuracy:
    • Provide accurate and up-to-date information when interacting with FGR.
    • Notify us of any changes to your personal information where necessary.
  3. Secure Communication:
    • Avoid sharing sensitive personal or financial information through unsecured channels.
  4. Device Security:
    • Keep your devices and software updated and take reasonable measures to protect against malware and unauthorized access.
  5. Compliance:
    • Comply with applicable laws, regulations and FGR’s requirements when accessing or using our services, including gold and jewellery-related services.

Third-Party Websites

Our website may contain links to external websites. FGR is not responsible for the privacy practices of third-party websites. If you follow a link to another website, we recommend that you review its privacy policy before providing any personal information.

Policy Updates

This policy may be updated periodically to reflect changes in applicable laws, regulations, FGR’s operations or privacy practices. Updated versions will be posted on our website with the revised effective date.

Contact Information

For inquiries or concerns regarding this policy, contact:

Data Protection Officer

Fidelity Gold Refinery (Private) Limited

No. 1 George Drive, Msasa

Harare
Zimbabwe

Tel: +263 242 486 670 Ext: 1135

Email: dataprotection@fgr.co.zw.

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