Vhalemba Mining (“Vhalemba Mining”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you visit or use our website at https://vhalemba.com/, contact us, submit information to us, or otherwise interact with our services.

We aim to process personal information in accordance with applicable laws of Zimbabwe, including the Cyber and Data Protection Act [Chapter 12:07], as amended or replaced from time to time.

1. Who We Are

The organisation responsible for the processing of your personal information is:

For questions, requests, or concerns relating to this Privacy Policy or your personal information, you may contact us using the details above.

2. Information We May Collect

Depending on how you interact with us, we may collect and process different categories of personal information.

2.1 Information You Provide to Us

This may include:

• Your full name;
• Email address;
• Telephone or mobile number;
• Physical, postal, or business address;
• Company or organisation name;
• Job title or position;
• Information contained in enquiries, messages, applications, forms, or correspondence;
• Information you provide when requesting information about our mining activities, products, services, or business opportunities;
• Information contained in documents that you voluntarily provide to us; and
• Any other information you choose to provide.

2.2 Information Collected Automatically

When you visit our website, certain technical information may be collected automatically, depending on the website technologies and services we use. This may include:

• IP address;
• Browser type and version;
• Device type;
• Operating system;
• Pages visited;
• Date and time of visits;
• Referring website or source; and
• General website usage information.

We use such information where necessary to operate, secure, maintain, and improve our website and services.

3. How We Use Personal Information

We may use personal information for legitimate business and operational purposes, including:

• Responding to enquiries and requests;
• Communicating with customers, suppliers, contractors, business partners, and other stakeholders;
• Providing information about our business, mining activities, products, and services;
• Managing business relationships;
• Processing applications or expressions of interest;
• Evaluating and responding to business opportunities;
• Maintaining and improving our website;
• Monitoring website performance and security;
• Preventing fraud, abuse, unauthorised access, or other unlawful activity;
• Maintaining business, accounting, administrative, and operational records;
• Complying with applicable laws, regulations, court orders, or lawful requests from authorities;
• Protecting our rights, property, employees, customers, and business operations; and
• Performing other purposes disclosed to you when your personal information is collected.

We will not use your personal information for purposes that are incompatible with the purpose for which it was collected unless permitted or required by applicable law.

4. Lawful Processing

We will process personal information only where there is a lawful basis to do so.

Depending on the circumstances, processing may be based on:

• Your consent;
• The performance of a contract or steps taken at your request before entering into a contract;
• Compliance with a legal or regulatory obligation;
• A legitimate business or operational purpose, where permitted by applicable law;
• Protection of rights, property, or safety; or
• Another lawful basis recognised under applicable Zimbabwean law.

Where we rely on consent, you may withdraw that consent where applicable. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

5. Data Minimisation and Accuracy

We seek to collect personal information that is adequate, relevant, and limited to what is reasonably necessary for the purpose for which it is collected.

We also take reasonable steps to keep personal information accurate and up to date where accuracy is necessary for the purpose of processing.

You should notify us if information you have provided to us changes or is inaccurate.

6. Cookies and Similar Technologies

Our website may use cookies and similar technologies.

Cookies are small files stored on your device that can help a website recognise your browser, remember preferences, improve functionality, understand website usage, and maintain security.

Depending on how our website is configured, cookies may be used for:

• Essential website functionality;
• Security;
• User preferences;
• Website performance;
• Analytics;
• Understanding how visitors use our website; and
• Other purposes disclosed through our website.

You can manage or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of some parts of the website.

7. Analytics and Third-Party Services

We may use third-party services to operate, secure, analyse, or improve our website and business.

These services may include:

• Website hosting;
• Analytics;
• Communications;
• Security;
• Cloud storage;
• Email services;
• Payment processing; and
• Other technology providers.

Where third-party providers process personal information on our behalf, we will take reasonable steps to ensure that they process information only for authorised purposes and apply appropriate confidentiality and security measures.

8. Sharing of Personal Information

We do not sell personal information as a business practice.

We may disclose personal information where reasonably necessary and lawful, including to:

• Employees and authorised representatives of Vhalemba Mining;
• Contractors, consultants, professional advisers, and service providers;
• Website, hosting, IT, cybersecurity, cloud, communications, and technology providers;
• Financial, accounting, auditing, or professional service providers;
• Business partners where disclosure is necessary for a legitimate business purpose;
• Government departments, regulatory authorities, law-enforcement agencies, courts, or other authorities where required or permitted by law;
• Persons involved in a corporate transaction, restructuring, merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality arrangements; and
• Other persons where you have authorised or requested the disclosure.

We will seek to limit disclosures to information that is reasonably necessary for the relevant purpose.

9. International Transfers

Some service providers we use may store or process information outside Zimbabwe.

Where personal information is transferred, stored, or processed outside Zimbabwe, we will take reasonable steps to ensure that the transfer and subsequent processing are carried out in accordance with applicable data-protection requirements and that appropriate safeguards are applied where required.

10. Security of Personal Information

We take reasonable technical, organisational, and administrative measures designed to protect personal information against:

• Unauthorised access;
• Unauthorised disclosure;
• Loss;
• Destruction;
• Alteration;
• Misuse; and
• Other unlawful or unauthorised processing.

Security measures may include access controls, authentication, confidentiality obligations, secure systems, monitoring, backups, and other safeguards appropriate to the nature of the information and the risks involved.

However, no electronic transmission, website, information system, or storage method can be guaranteed to be completely secure.

11. Data Security Incidents and Breaches

If we become aware of a personal-information security incident or breach, we will take reasonable steps to investigate, contain, mitigate, and address the incident.

Where notification is required under applicable Zimbabwean law, we will make the required notifications to the relevant authority and/or affected data subjects within the applicable legal requirements.

12. Retention of Personal Information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Retention periods may depend on:

• The nature and purpose of the information;
• Our ongoing business relationship with you;
• Legal, accounting, tax, regulatory, or reporting requirements;
• Dispute resolution;
• Enforcement of agreements; and
• The need to establish, exercise, or defend legal claims.

When personal information is no longer required, we will take reasonable steps to delete, anonymise, securely dispose of, or otherwise appropriately deal with it.

13. Your Data Protection Rights

Subject to applicable legal limitations and requirements, you may have rights in relation to your personal information.

Under Zimbabwe’s Cyber and Data Protection Act, data subjects have rights including being informed about the use of their personal information, accessing personal information held by a controller or processor, objecting to certain processing, correcting false or misleading personal information, and requesting deletion of false or misleading data.

Depending on the circumstances and applicable law, you may request that we:

• Tell you whether we hold personal information about you;
• Provide access to personal information we hold about you;
• Correct inaccurate or misleading personal information;
• Address your objection to particular processing activities;
• Delete or otherwise deal with information where legally required or permitted; or
• Provide information about how your personal information is being processed.

These rights are not absolute and may be subject to legal exceptions, including circumstances where we are required to retain or process information by law.

14. How to Exercise Your Rights

To exercise a privacy or data-protection right, please contact us:

To protect your personal information, we may need to verify your identity before processing certain requests.

We will consider and respond to legitimate requests within the period required by applicable law.

15. Direct Marketing

Where we use your personal information for direct marketing, we will comply with applicable Zimbabwean data-protection and communications requirements.

Where applicable, you may object to receiving direct marketing communications and may unsubscribe using the mechanism provided in the communication or by contacting us at unite@vhalemba.com.

16. Children’s Privacy

Our website and services are not intentionally directed at children unless expressly stated otherwise.

We do not knowingly seek to collect personal information from children without an appropriate lawful basis and, where required, the involvement or consent of a parent or legal guardian.

Where we become aware that personal information relating to a child has been collected unlawfully, we will take reasonable steps to address the situation in accordance with applicable law.

17. Links to Third-Party Websites

Our website may contain links to third-party websites or services.

Those websites operate independently from Vhalemba Mining and may have their own privacy policies and terms of use.

We are not responsible for the privacy practices, content, security, or policies of third-party websites. We encourage you to review their privacy policies before providing personal information.

18. Business and Mining-Related Information

In the course of our mining and business activities, we may receive information relating to employees, contractors, suppliers, customers, investors, prospective business partners, visitors, consultants, and other stakeholders.

Such information will be processed only for legitimate business, operational, contractual, regulatory, employment, safety, security, or legal purposes, as applicable.

Where personal information is contained within business documents, applications, correspondence, reports, or other records, we will seek to handle that information in accordance with applicable data-protection requirements.

19. Confidential Business Information

This Privacy Policy primarily concerns personal information.

Confidential commercial, technical, geological, financial, operational, or other proprietary information supplied to Vhalemba Mining may also be subject to contractual confidentiality obligations, non-disclosure agreements, applicable law, or separate company policies.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes in applicable laws or regulations;
• Changes to our business;
• Changes to our website or services;
• Changes to technology or security practices; or
• Changes to how we process personal information.

When we make material changes, we may update the “Last Updated” date at the top of this Privacy Policy and, where appropriate, provide additional notice.

We encourage you to review this Privacy Policy periodically.

21. Contact Us

If you have any questions, concerns, complaints, or requests concerning this Privacy Policy or the way we process personal information, please contact:

We will seek to address privacy concerns fairly and in accordance with applicable Zimbabwean law.

22. Governing Law

This Privacy Policy shall be interpreted in accordance with the laws of Zimbabwe, including applicable data-protection and privacy legislation.

Where applicable, disputes concerning the processing of personal information shall be dealt with through the procedures and legal remedies available under Zimbabwean law.