Privacy Policy

1. INTRODUCTION

The Malilangwe Trust (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Notice explains how we collect, use, disclose, store, and safeguard your personal information when you visit our Site, open a customer account, or use our Services, in accordance with the Cyber and Data Protection Act [Chapter 12:07] (“CDPA” or “the Act”).

By using our Site or Services, you consent to the collection, storage, use, and disclosure of your personal information as described in this Privacy Notice.

If you are not comfortable with any part of this Policy, we kindly ask that you refrain from using our Site or Services.

2. WHAT IS PERSONAL INFORMATION

Personal information refers to any information relating to an identified or identifiable natural person. Examples of personal information include (but are not limited to):

  • Name, address, and contact details (telephone number, email address).
  • Age, gender, marital status, or family details.
  • National identification numbers or unique identifiers.
  • Financial, employment, or educational information.
  • Health-related information (where applicable).
  • Online identifiers such as IP addresses, location data, and device information.

3. WHAT PERSONAL INFORMATION DO WE COLLECT

Malilangwe or third parties providing services to Malilangwe, may collect information or data from you, either actively (where you provide the information) or inactively (usage data automatically collected). Users are responsible for third-party information obtained, published or shared through our Site or Services.

ACTIVE INFORMATION COLLECTION:

  • Your name and surname.
  • Your gender, age group and weight (where required by our flight charter partners).
  • Your physical address.
  • Your e-mail address.
  • Your telephone and mobile number.
  • Your identity and/or passport number.
  • Your company details.
  • Your passport nationality, issue date and expiry date.
  • Marital status (to assist the lodge with rooming services).
  • Your emergency contact details.
  • Your medical requirements (if necessary).
  • Your dietary, allergies, and special requirements (if necessary).
  • For the security of our premises, we may capture
    • CCTV images / video
    • Your vehicle registration number

INACTIVE INFORMATION COLLECTION:

  • IP address.
  • Cookies.
  • Browser type, language, plug-ins, Internet domain, and operating system.
  • The website(s) visited before visiting the Site and the website(s) visited after visiting the Site.
  • Unique identifiers, including mobile device identification numbers, which may identify the physical location of such devices.

4. HOW DO WE USE YOUR INFORMATION?

We use your personal information for the following purposes:

  • To provide, maintain, and improve our services.
  • To communicate with you in line with your subscription to newsletters or request for information.
  • To comply with legal and regulatory obligations and enforce our terms and conditions.

5. SHARING YOUR INFORMATION

We may share your personal information with the following parties, including but not limited to:

  • Conservation Authorities.
  • Anti Poaching Units.
  • Environmental Regulators.
  • Service Providers: Third‑party companies that assist us in operating and supporting our Services, such as:
  • Payment Processors.
  • Customer Support Teams.
  • Contractors.
  • Service Providers.
  • Marketing Partners.
  • Business Partners: Organisations we collaborate with to provide or enhance our services, including:
  • Internet companies.
  • Legal Authorities: We may disclose your personal information to law enforcement or regulatory authorities where required by law.
  • Business Transfers: If we merge with or are acquired by another company, your personal information may be transferred to the new entity.
  • Affiliates: We may share your information with our related or affiliated companies.

6. LAWFUL BASIS OF PROCESSING

We rely on the following lawful basis for processing your personal information:

  • Consent:We may process your personal information if you have given us explicit consent to do so for a specific purpose.
  • Contractual Necessity:We may process your personal information when it is necessary for the performance of a contract with you or to take steps at your request before entering a contract.
  • Legal Obligation:We may process your personal information to comply with a legal obligation.
  • Legitimate Interests: We may process your personal information for our legitimate business operations, or those of a third party, provided that your interests and fundamental rights do not override those interests.
  • Vital Interests:In exceptional circumstances, we may process your information when necessary to protect your vital interests or those of another person, such as in a medical emergency.
  • Public Interest:We may process your personal information when necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

7. DATA SECURITY

While Malilangwe has taken reasonable technical and organizational measures to safeguard the information we collect online, the transmission of Personal Information via the internet is not completely secure and we cannot guarantee the security of data transmitted to or from us.

We will take steps reasonably necessary to ensure the integrity and confidentiality of the Personal Information in our possession, to guard against the loss of, damage to, unauthorized access to, processing of and destruction of such information. However, we do not guarantee that our security systems are 100% secure nor error-free, neither do we guarantee the accuracy of the information (whether it be Personal Information or otherwise) that we collect from you or process in accordance with this Policy.

Access to your personal information is restricted to employees and contracted third‑party service providers who have a legitimate operational reason for accessing such information. We maintain physical, electronic, and procedural safeguards that comply with the CDPA and other applicable laws and regulations to protect your personal information from unauthorised access.

8. COOKIE POLICY

When you agree to allow our website to use Cookies, you also agree to our use of the data collected regarding your online behaviour (such as analysing web traffic, and the web pages you visit and spend the most time on)

After the data is used for statistical analysis, it is completely removed from our systems. Please note that Cookies do not give us access to your computer or any information beyond what you choose to share with us. They are used solely to monitor which pages and content you find useful.

If you wish to disable Cookies, you may do so by adjusting your internet browser settings, or by visiting, or visit https://www.internetcookies.com, which provides comprehensive instructions for a wide range of browsers and devices.

9. THIRD PARTY POLICIES

On our Site you may find links that direct you to websites, plug‑ins, applications, and other services owned or operated by third parties. These third Parties are independent from The Malilangwe Trust and are not governed by this Privacy Notice.

If you click on any of these links, Malilangwe is not responsible for your data and privacy protection. These third parties maintain their own Privacy Policies, and we encourage you to review the Privacy Policy or Notice of any website you visit.

All third-party Processing takes place under the lawful basis outlined in the respective third-party’s Privacy Policy/Notice.

Third parties may implement different security measures. If you choose to use these Third-Party Websites or features, you may disclose your information to these third parties, their users, and the public more generally, depending on how their services function. Links to third-party websites are provided for your convenience only and do not constitute endorsement by The Malilangwe Trust of their content, security measures, or privacy practices.

We encourage you to exercise caution and review the privacy controls available to you whenever you leave our Site.

10. CONSENT

Where required by law and where legally permissible, we process personal information based on consent. When we rely on consent as the lawful basis for processing your personal information, you have the right to withdraw that consent at any time in accordance with applicable laws.

 11. KNOW YOUR RIGHTS

You have the following rights regarding your personal information:

  • Right to Be Informed: You have the right to be informed of the use to which your personal information is being subjected.
  • Right to Access Information: You may request a copy of the personal information we hold about you.
  • Right to Correction or Rectification: You may request corrections to any inaccurate or incomplete information.
  • Right to Deletion (Right to Be Forgotten): You may request the deletion of your personal information under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.
  • Right to Restrict Processing: You may request that we restrict the processing of your personal information in certain situations, such as when you contest the accuracy of the data.
  • Right to Data Portability: You may request to receive your personal information in a structured, commonly used, and machine‑readable format, and request that we transfer it to another data controller where technically feasible.
  • Right to Object to Processing: You may object to the processing of your personal information in certain situations, including direct marketing.
  • Right to Give or Withdraw Consent: If we process your personal information based on your consent, you have the right to withdraw that consent at any time.
  • Rights Related to Automated Decision‑Making, Including Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless there is a lawful basis for such processing.

12. HOW TO EXERCISE YOUR RIGHTS

To exercise any of your rights, please contact us using the details provided in the Contact Us section of this Privacy Notice. We may require you to verify your identity before processing your request. We will respond to your request within the timelines prescribed under the CDPA.

13. CROSS BORDER TRANSFER OF DATA

Your personal information may be transferred to and processed in countries outside Zimbabwe. These countries may have different data protection laws from those in your home country.

When we transfer your personal information outside Zimbabwe, we will ensure that adequate safeguards are in place to protect it in accordance with applicable laws.

14. DATA RETENTION

We will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to meet any legal, accounting, or reporting requirements. When your personal information is no longer required, we will securely delete, destroy, or anonymize it.

15. CONTACT US

If you have any requests, questions, or concerns about this Privacy Notice or our privacy practices, please contact our Data Protection Officer:

Mr Bannister Chitate
Email: dpo@malilangwe.org
Telephone: +263 772 609 646

If you do not receive timely acknowledgment of your communication, or if your requests, questions or concerns are not satisfactorily addressed, you may visit the Zimbabwe Data Protection Authority (POTRAZ) website for more information or to file a complaint:
https://www.potraz.gov.zw/?page_id=987

16. CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice will be reviewed annually or as required to address changes in organizational needs, legal regulations, or technological advancements. We will notify you of any changes by posting the new Privacy Notice on our website with a new effective date (10/03/2026).