Version 1.0
This Privacy Policy explains how ACOOMAT TECH SOLUTIONS (PRIVATE) LIMITED ("FundoLMS", "we", "us"), a company registered in Zimbabwe, collects, uses, and protects personal information through the FundoLMS platform ("the Platform"). We are the data controller for the personal information described in this Policy, as that term is defined in the Cyber and Data Protection Act [Chapter 12:07] ("the Act").
When a Subscription is purchased, our payment gateway processes the transaction. We retain a record of the amount, date, and a payment reference, but do not store full mobile money PINs, card numbers, or banking credentials on our own systems.
We automatically collect limited technical data such as device type, browser or app version, and access logs, used for security, troubleshooting, and service improvement.
Consistent with the Act's requirement that data be collected for specified, explicit and legitimate purposes, we use personal information to:
Our processing relies on the consent given at registration — by the Student directly where aged 16 or older, or by a Parent/Guardian acting as the child's legal representative where the Student is younger, consistent with the Act's definition of consent. Where processing is necessary to perform our contract with a user (for example, delivering a class that has been paid for), we rely on that basis instead of, or in addition to, consent.
The Act defines a child as any person under 18. Because many Platform users are children, we apply additional care to their data: we collect only what is necessary to provide the educational service, restrict who can view a child's activity to that child's own Teachers and their Parent/Guardian, and conduct data protection impact assessments for processing activities involving children's data, as required by the Act's regulations. A Parent/Guardian may review, correct, or request deletion of their child's information at any time, subject to Section 8.
We share personal information only as necessary to operate the Platform, with the following categories of recipient:
We do not sell personal information to third parties.
Some of the providers listed in Section 6 process data outside Zimbabwe. Where this occurs, we rely on the bases recognised in section 29 of the Act for such transfers, including that the transfer is necessary for the performance of our contract with the data subject, or that unambiguous consent has been given.
Subject to the Act, you (or, for a child, their Parent/Guardian) have the right to:
To exercise these rights, contact us using the details in Section 12. We may need to verify your identity before actioning a request.
We retain personal information for as long as the related Account is active, and for a reasonable period afterward as needed to meet legal, accounting, or dispute-resolution requirements. Financial records relating to payments are retained for the period required by Zimbabwean tax and financial record-keeping law.
We maintain reasonable technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure, or destruction, and will notify affected users and, where required, the Data Protection Authority, in the event of a breach affecting their information, in line with the Act.
The Platform uses essential session cookies required for you to stay logged in and to keep your data secure while using the site. We do not currently use third-party advertising or tracking cookies.
Questions about this Policy, or requests relating to your personal information, can be directed to ACOOMAT TECH SOLUTIONS (PRIVATE) LIMITED, [registered address], [support email]. If you are not satisfied with our response, you may lodge a complaint with the Data Protection Authority (the Postal and Telecommunications Regulatory Authority of Zimbabwe, POTRAZ).
We may update this Policy from time to time. Material changes will be notified in-app before they take effect. Each version is dated, and we keep a record of which version each user last accepted.
All Protocol Observed.
