Privacy Policy

FRWX TECHNOLOGY LIMITED – PRIVACY POLICY FRWX Technology Limited ("Frameworx," "we," "us," or "our") respects your privacy and is committed to protecting personal data in line with applicable data protection requirements, including Zambia's Data Protection Act No. 3 of 2021 and any other laws that apply to our services. This policy explains what personal data we process, why we process it, how we protect it, and the rights available to individuals whose data we handle. PERSONAL DATA WE PROCESS Depending on the service used, we may process: 1. Account details — name, username, role, and organisation. 2. Contact details — email address, phone number, and physical or postal address. 3. Transaction records — payments, subscriptions, invoices, and service usage history. 4. Communication records — messages, support tickets, and notifications sent or received through our platforms. 5. Security logs — authentication events, access attempts, and audit trails. 6. Device and usage information — IP address, browser type, device identifiers, and interaction data. Any additional information reasonably required to deliver a service requested by a user or customer. WHY WE PROCESS PERSONAL DATA We process personal data to: 1. Create, verify, and manage user accounts. 2. Deliver the products and services requested by our users or customers. 3. Send transactional, service, and security notifications. 4. Process payments and maintain accurate financial records. 5. Safeguard our systems, prevent fraud, and investigate security incidents. 6. Comply with legal, regulatory, audit, and contractual obligations. 7. Resolve disputes and enforce our terms of service. 8. Monitor performance and improve the reliability and quality of our systems. SHARING OF PERSONAL DATA We do not sell personal data. We only share personal data where necessary, and only with: 1. Authorised Frameworx staff bound by confidentiality obligations. 2. Trusted service providers (including payment processors, communication providers, and cloud storage providers) acting on our instructions. 3. Regulators, law enforcement, or other lawful authorities where required by law or to protect our legal rights. 4. Other parties where the user or customer has given consent, or where disclosure is necessary to fulfil a legitimate business, contractual, security, or legal purpose. All third parties are required to apply appropriate safeguards consistent with this policy and applicable law. DATA RETENTION We retain personal data only for as long as is necessary to: 1. Fulfil the purpose for which it was collected. 2. Meet legal, regulatory, or audit obligations. 3. Support security monitoring, dispute resolution, or enforcement of agreements. 4. Satisfy another lawful purpose disclosed at the time of collection. Specific retention periods are maintained in our internal system compliance settings and are reviewed periodically. SECURITY We apply a layered approach to safeguarding personal data, including: 1. Role-based access controls and the principle of least privilege. 2. Secure password hashing and credential protection. 3. Restricted and monitored administrative access. 4. Audit-friendly operational practices and logging. 5. Encrypted, secure backup procedures and disaster recovery measures. While we apply strong safeguards, no system can be guaranteed to be completely secure. Users are encouraged to protect their account credentials and report any suspected misuse promptly. YOUR RIGHTS Subject to applicable law, individuals whose personal data we process have the right to: 1. Access the personal data we hold about them. 2. Correct inaccurate or incomplete information. 3. Request deletion of personal data, where lawful. 4. Object to or restrict certain processing activities. 5. Withdraw consent, where processing is based on consent. 6. Lodge a complaint with the Office of the Data Protection Commissioner of Zambia. We may need to verify identity before acting on a request, and we will respond within the timeframes required by applicable law. CONTACT US For questions about this policy, or to exercise any of the rights above, please contact: Email: privacy@frameworx.tech UPDATES TO THIS POLICY We may update this policy from time to time to reflect changes in our systems, services, business practices, or legal requirements. The latest version will always be available on our official channels, and the Effective Date above will be updated accordingly. Where changes are material, we will provide additional notice through reasonable means