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Last Updated: December 08, 2025

Privacy Policy

1. Introduction

Welcome to Mtaalam Digital Learning ("we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our digital learning platform at https://lms.sanganosoft.co.zw/ (the "Platform").

By accessing or using our Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our policies and practices, please do not use our Platform.

Data Controller: Mtaalam Digital Learning is the data controller responsible for your personal information collected through the Platform.

2. Legal Compliance

This Privacy Policy complies with:

  • The Cyber and Data Protection Act Chapter 12:07
  • The Constitution of Zimbabwe (Section 57 - Right to Privacy)
  • Access to Information and Protection of Privacy Act (AIPPA)
  • Postal and Telecommunications Act

We are committed to processing your personal data lawfully, fairly, and transparently in accordance with these legal frameworks.

3. Information We Collect

3.1 Personal Information You Provide

When you register and use our Platform, we collect:

  • Account Information: Full name, username, email address, phone number, password (encrypted)
  • Profile Information: Student grade level, educational interests, profile photo, bio
  • Payment Information: Billing details, transaction history (payment card data is processed by secure third-party payment processors)
  • Communication Data: Forum posts, chat messages with instructors, course reviews, support inquiries
3.2 Information Automatically Collected
  • Usage Data: Course enrollments, quiz attempts, assignment submissions, video watch time, learning progress
  • Device Information: IP address, browser type, operating system, device identifiers
  • Location Data: General geographic location (country/city level)
  • Log Data: Access times, pages viewed, time spent on platform, clickstream data
3.3 Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to enhance your experience. You can control cookie preferences through your browser settings.

4. How We Use Your Information

In accordance with Section 7 of the Cyber and Data Protection Act, we process your personal data for the following lawful purposes:

Platform Services
  • Providing access to courses and learning materials
  • Processing enrollments and subscriptions
  • Tracking learning progress and issuing certificates
  • Grading quizzes and assignments
Communication
  • Sending course updates and announcements
  • Responding to support inquiries
  • Facilitating instructor-student communication
  • Notifying you of new features and content
Platform Improvement
  • Analyzing usage patterns to enhance user experience
  • Developing new features and courses
  • Conducting research on learning outcomes
  • Troubleshooting technical issues
Legal & Security
  • Preventing fraud and unauthorized access
  • Complying with legal obligations
  • Enforcing terms of service
  • Protecting rights and property

5. Legal Basis for Processing

We process your personal data based on:

  • Consent: You have given explicit consent for us to process your data for specific purposes
  • Contract Performance: Processing is necessary to fulfill our service agreement with you
  • Legal Obligation: Processing is required to comply with Zimbabwean law
  • Legitimate Interests: Processing is necessary for our legitimate business interests, provided your rights are not overridden

6. Data Sharing and Disclosure

We do not sell your personal information. We may share your data with:

Third Party Purpose Data Shared
Course Instructors Educational services delivery Name, progress, submissions
Payment Processors Processing subscription payments Billing information
Cloud Service Providers Hosting and data storage All platform data (encrypted)
Analytics Providers Platform improvement and insights Usage statistics (anonymized)
Law Enforcement Legal compliance and public safety As required by law

All third-party service providers are contractually bound to protect your data and comply with applicable data protection laws.

7. Data Security

In compliance with Section 18 of the Cyber and Data Protection Act, we implement appropriate technical and organizational measures to protect your data:

Encryption

All data in transit is encrypted using SSL/TLS protocols. Sensitive data at rest is encrypted using industry-standard algorithms.

Access Controls

Role-based access controls ensure only authorized personnel can access personal data on a need-to-know basis.

Secure Infrastructure

Our servers are hosted in secure data centers with physical and digital security measures including firewalls and intrusion detection.

Monitoring & Auditing

We continuously monitor our systems for security threats and conduct regular security audits and vulnerability assessments.

8. Your Data Protection Rights

Under the Cyber and Data Protection Act Chapter 12:07, you have the following rights:

You have the right to request copies of your personal data. We may charge a reasonable fee for providing copies.

How to exercise: Email privacy@mtaalam.co.zw with your request.

You have the right to request correction of inaccurate or incomplete personal data.

How to exercise: Update your information in Account Settings or contact support.

You have the right to request deletion of your personal data under certain conditions.

Note: We may retain certain data for legal compliance, dispute resolution, and fraud prevention.

You have the right to receive your personal data in a structured, commonly used, and machine-readable format.

You have the right to object to our processing of your personal data for direct marketing purposes.

Where processing is based on consent, you have the right to withdraw that consent at any time.

Response Time: We will respond to your request within 30 days as required by law.

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

  • Active Accounts: Data retained while your account is active
  • Inactive Accounts: Data retained for 3 years after last login, then deleted
  • Payment Records: Retained for 7 years for tax and accounting purposes
  • Course Progress: Retained for 5 years after course completion
  • Legal Records: Retained as required by law

10. Children's Privacy

Our Platform is designed for students of all ages, including minors. We comply with special protections for children's data:

  • Users under 18 require parental/guardian consent to create an account
  • We collect minimal personal information from minors
  • Parents/guardians can review, modify, or delete their child's data by contacting us
  • We do not use minors' data for marketing purposes

11. International Data Transfers

Your personal data is primarily stored and processed in Zimbabwe. However, some of our service providers may process data outside Zimbabwe. When this occurs:

  • We ensure appropriate safeguards are in place
  • We comply with Section 19 of the Cyber and Data Protection Act regarding cross-border data transfers
  • We use standard contractual clauses approved by data protection authorities

12. Data Breach Notification

In the event of a data breach that compromises your personal information, we will:

  • Notify you within 72 hours of discovering the breach
  • Report the breach to the Cyber and Data Protection Authority
  • Provide details about the breach and steps being taken
  • Advise you on protective measures you should take

13. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will:

  • Notify you by email of significant changes
  • Display a prominent notice on our Platform
  • Update the "Last Updated" date at the top of this policy

Your continued use of the Platform after changes indicates acceptance of the updated policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

Data Protection Officer

Email: privacy@mtaalam.co.zw

Phone: +263 XXX XXX XXX

Registered Office

Mtaalam Digital Learning
[Your Physical Address]
Harare, Zimbabwe

15. Filing a Complaint

If you believe we have violated your data protection rights, you have the right to lodge a complaint with:

Cyber and Data Protection Authority of Zimbabwe

Website: https://cdpa.gov.zw

Email: info@cdpa.gov.zw

Physical Address: [Authority Address]

We encourage you to contact us first to resolve any concerns before filing a complaint with the regulator.