HORTATIVE INVESTMENTS PRIVATE LIMITED GROUP

PRIVACY POLICY

1. Introduction

1.1. Hortative Investments Private Limited (“Hortative Investments Private Limited/ we/ us/ our”) is a Zimbabwean retailer specialising in tiles, sanitary ware, and other home-finishing products. The Group’s retail brands are Tile and Carpet Centre and Ceiling and Aluminium and Partitioning Solutions (C.A.A.P.S.).

1.2. Hortative Investments Private Limited respects your (“you/ your/ data subject”) right to privacy and is committed to protecting it. This Privacy Policy explains how we process the Personal Information we collect from you and outlines your rights in accordance with applicable Zimbabwean data-protection laws. This policy explains, among other things:

1.2.1. what Personal Information we collect;
1.2.2. why we collect Personal Information;
1.2.3. how we collect Personal Information;
1.2.4. how long we retain Personal Information;
1.2.5. your rights as a data subject.

1.3. By using our products, services, or websites; supplying goods or services to Hortative Investments Private Limited; applying for employment; or submitting information to us in any manner, you acknowledge that such conduct constitutes specific, unconditional, and voluntary consent to the processing of your Personal Information in accordance with this Privacy Policy, whether or not processed by automated means.

1.5. This Privacy Policy applies to all companies within the Hortative Investments Private Limited Group that are domiciled in Zimbabwe. The legal entity that collects your Personal Information or determines the purpose for processing it will be the responsible party for that information.

2. Principles

2.1. Hortative Investments Private Limited follows these principles in relation to Personal Information:

2.1.1. transparency regarding how Personal Information is collected and processed;
2.1.2. compliance with all applicable legal and regulatory requirements;
2.1.3. lawful, transparent collection of Personal Information and processing only for compatible purposes;
2.1.4. maintaining information that is accurate, complete, up-to-date, and reliable;
2.1.5. protecting Personal Information physically and digitally to prevent leakage, loss, alteration, or misuse;
2.1.6. ensuring that external service providers entrusted with Personal Information meet required security standards;
2.1.7. making this policy available to customers, employees, suppliers, service providers, and prospective employees;
2.1.8. continually improving data-protection practices in line with evolving environments and legislative requirements.

3. Personal Information Collected by Hortative Investments Private Limited

3.1. Personal Information refers to information relating to an identifiable, living natural person, and where applicable, an identifiable juristic person. This includes, but is not limited to:

3.1.1. demographic and sensitive information (e.g., race, gender, sex, pregnancy, marital status, origin, health, disability, religion, belief, culture, language, birth);
3.1.2. educational, medical, financial, criminal, or employment history;
3.1.3. identifying details (e.g., ID numbers, contact details, location data, online identifiers);
3.1.4. biometric information;
3.1.5. personal opinions, views, or preferences;
3.1.6. private or confidential correspondence;
3.1.7. opinions of others about the person;
3.1.8. a person’s name when combined with other identifying information.

3.2. We will only process Personal Information that is adequate, relevant, and not excessive in relation to the purposes for which it is required.

4. Purpose for Collecting Personal Information

4.1. Our primary purpose for collecting Personal Information is to conduct business activities, enter into agreements with you, and fulfil our contractual obligations.

4.2. The purposes differ based on your relationship with us:

4.2.1. If you are a customer:

• identification and verification processes;
• marketing and promotions;
• administration and management of products and services;
• handling customer complaints;
• participation in promotional competitions;
• granting access to premises;
• understanding customer needs, behaviours, and interactions to improve offerings and strategy.

4.2.2. If you are a supplier or service provider:

• verifying company information and conducting due diligence;
• processing payments;
• communication regarding supplied goods or services;
• reviewing and evaluating goods or services;
• record keeping;
• fulfilling contractual obligations.

4.2.3. If you are an employee or prospective employee:

• conducting checks and verification;
• payroll and benefits administration;
• statutory reporting and compliance;
• communication;
• access control;
• evaluating qualifications and work experience;
• recruitment.

4.3. We may further process your Personal Information to:

4.3.1. compile reports and conduct statistical analysis;
4.3.2. comply with internal/external auditors or regulatory requirements;
4.3.3. provide information about products and services;
4.3.4. meet legal and regulatory requirements;
4.3.5. support legal proceedings;
4.3.6. assist with criminal or investigative processes.

4.4. We may share your Personal Information with:

• third parties necessary to meet contractual obligations (e.g., transporters);
• external auditors;
• regulators, government authorities, and law enforcement.

4.5. Third parties may only use this information for the purposes for which it was shared. We maintain agreements to ensure compliance.

4.6. Your Personal Information may be transferred or stored outside Zimbabwe for cloud-based or website-related purposes, in accordance with applicable laws.

4.7. We will not sell or disclose your Personal Information without your consent. You indemnify us against unintentional disclosures beyond our control.

4.8. If you refuse to provide Personal Information, we may be unable to fulfil obligations or continue our relationship with you.

5. How Personal Information Is Collected

5.1. We collect Personal Information:

5.1.1. Directly from you — e.g., point-of-sale interactions, website forms, employment applications.
5.1.2. From third parties — e.g., credit checks, fraud checks, public records (with prior notice where applicable).

6. Marketing

6.1. We may contact past or current customers regarding products or services similar to previous purchases, or share newsletters and related value-add content.

6.2. Personal Information may be shared within the Hortative Investments Group for marketing purposes.

6.3. You may opt out at any time by following the instructions in our communications or contacting our helpdesk.

7. Retention of Personal Information

We retain Personal Information only for as long as necessary:

7.1.1. to comply with legal obligations;
7.1.2. to fulfil contractual obligations;
7.1.3. where consent has been granted;
7.1.4. to meet the purpose for which the information was collected;
7.1.5. for legitimate business purposes;
7.1.6. where litigation, investigations, or regulatory queries exist.

8. Your Rights as a Data Subject

8.1. You have the legal right to:

8.1.1. request access to your Personal Information;
8.1.2. request correction or deletion;
8.1.3. request restriction or object to processing;
8.1.4. withdraw consent;
8.1.5. withdraw consent for marketing;
8.1.6. lodge a complaint with the Information Regulator.

8.2. More information is available on www.tileandcarpetcentre.co.zw.

8.3. Important notes:

• We require proof of identity before responding.
• We will correct or delete information unless legally required to retain it.
• If correction is not warranted, we will explain why.

9. Cookies

Our websites use cookies to improve user experience, recognise repeat visits, analyse behaviour, and display relevant advertising. Cookies do not personally identify you.

You may disable cookies in your browser settings, though this may limit website functionality.

10. Security Breaches

10.1. We maintain technical and structural safeguards to protect Personal Information from loss, damage, alteration, or unauthorised access.

10.2. If a data breach occurs, we will assess, respond, and notify affected individuals as required by law.

10.3. Third-party processors are bound by confidentiality and security obligations.

10.4. While we take all reasonable steps to protect your data, we cannot be held liable for unauthorised disclosures beyond our control.

10.5. If you voluntarily disclose Personal Information to third parties (including linked websites), we are not responsible for how such parties handle your data. You should review their privacy policies.

11. The Information Regulator

11.1. You may lodge a complaint with the Information Regulator in the manner prescribed under Zimbabwean law.

12. Updates to This Privacy Policy

12.1. This policy is approved by Hortative Investments Private Limited’s Information Officer and may be updated without prior notice. The most current version will be available on our websites.
This Privacy Policy is dated July 2022.

13. Contact Us

13.1. For questions, concerns, or requests relating to this Privacy Policy, please contact our Information Officer at:
Tel: 08677008944