PRIVACY POLICY

Last updated: July 16, 2025

1. DEFINITIONS AND INTERPRETATION

In this Privacy Policy, the following terms shall have the following meanings:

• “Personal Information” means any data that can identify an individual, such as name, address, or contact details.
• “Processing” means any operation performed on personal data including collection, use, storage, or sharing.
• “Services” refers to the mobile application Airmass Xpress and all related services offered by Airmass Sustainables (Private) Limited.
• “User” means any individual or entity who uses the Airmass Xpress application.
• “We,” “us,” or “our” refers to Airmass Sustainables (Private) Limited.

2. INTRODUCTION

This Privacy Policy for Airmass Sustainables (Private) Limited ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our mobile application Airmass Xpress ("Services").

This Privacy Policy applies regardless of how you access or use the Services, including when you:

• Download and use our mobile application (Airmass Xpress) as an ordinary user, skilled professional or as a company;
• Engage with us in other related ways, including any marketing events.

We respect your privacy and are committed to protecting your personal data. By accepting the terms of this Privacy Policy, you confirm that you have granted us your consent to process your personal data in accordance with this Privacy Policy and further acknowledge that this policy:

1. Tells you about your privacy rights and how the law protects you; and
2. Informs you how we look after your personal data when you visit or use Airmass Xpress.

Reading this Privacy Policy will help you understand your rights and choices. We are responsible for making decisions about how your personal information is processed.

This Privacy Policy shall be governed by and interpreted in accordance with the laws of Zimbabwe. Any disputes arising from this policy shall fall under the exclusive jurisdiction of the courts of Zimbabwe.

3. WHO IS THE DATA CONTROLLER?

Airmass Sustainables (Private) Limited is the Data Controller of your personal information collected and processed through the Airmass Xpress mobile application.

As the Data Controller, we are responsible for determining the purposes for which and the means by which your personal data is processed.

If you have any questions about this Privacy Policy or our use of your personal data, you can contact us using the following details:

Data Controller:
Airmass Sustainables (Private) Limited
356 Rayden Drive, Philadelphia, Borrowdale
Harare, Zimbabwe
Email: info@airmassafrica.co.zw
Phone: +263 789 925 823

4. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us

In Short: We collect personal information that you provide to us.

We collect personal information when you:

• Register on the Airmass Xpress mobile application;
• Participate in activities within the mobile application;
• Contact us through any means.

Types of Personal Data Collected

• Contact Data: Physical address, email address, and phone numbers.
• Financial Data: Mobile wallet number (transmitted to our payment service provider; not stored by us).
• Identity Data: First and last name, username, title, date of birth, and gender.
• Marketing and Communications Data: Preferences in receiving marketing material and communications.
• Profile Data: Username, password, interests, preferences, bids, and feedback.
• Transaction Data: Payment records and services hired through the app.
• Company Data: Company name, address, and proof of registration (for service providers).

Sensitive Information

We do not collect sensitive personal data (e.g. race, religion, health, marital status, or biometric data).

Application Data

• Geolocation: Location access (with user consent) for location-based services.
• Device Access: Camera, storage, and gallery access (with user consent).
• Push Notifications: Sent for account and app activity (users can opt out via settings).

This information is used to maintain application functionality, troubleshoot issues, and for internal analytics.

5. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide and improve our Services, ensure security, and comply with the law.

Legal Bases for Processing

• Performance of a contract: Required for service delivery.
• Legitimate interests: To improve services and prevent fraud.
• Consent: For marketing or optional services.
• Legal obligation: Compliance with applicable law or regulation.

Purposes and Types of Data We Process

We process your personal data for the following purposes and use the associated types of data:

• To create and manage your account → Identity Data, Contact Data, Profile Data
• To deliver services and facilitate usage of the mobile application → Contact Data, Transaction Data
• To provide customer support and respond to inquiries → Contact Data, Profile Data
• To send you important administrative messages (e.g. password resets, service updates) → Contact Data
• To process payments and manage your hires → Contact Data, Financial Data, Transaction Data
• To enable communications between users (e.g. between a professional and a client) → Profile Data
• To send marketing or promotional messages (only with your consent) → Contact Data, Marketing and Communications Data
• To improve services, products, and the overall user experience → Usage Data, Technical Data
• To verify companies registering to offer services via Airmass Xpress → Company Data

6. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We share data only when necessary, with trusted providers or under specific conditions.

• Google Maps API: Used to estimate location using GPS, Wi-Fi, or mobile towers. Data is cached on your device for up to 6 months.
• Other Users: Public posts (e.g., job requests, profile info) may be visible to others on the platform.
• Payment Service Providers: Mobile wallet numbers and payment info are shared for secure transactions.
• Third-party service providers: Vendors may support services like cloud storage, analytics, or customer support, under data protection agreements.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

We retain your information only as long as needed to fulfill the purposes outlined in this policy, unless required otherwise by law.

Retention criteria include:

• Type and sensitivity of data;
• Risk of harm from misuse;
• Legal obligations (e.g. tax law retention periods);
• Purpose fulfillment.

Data will be deleted or anonymized once no longer required.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

We implement appropriate technical and organizational security measures to protect your data. However, no system is 100% secure. We advise accessing Airmass Xpress in secure environments.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In accordance with the Zimbabwe Data Protection Act No. 3 of 2021, you have the right to:

• Access your personal data;
• Correct inaccurate or outdated data;
• Request deletion of your personal data;
• Object to or restrict processing;
• Withdraw consent at any time;
• Lodge a complaint with the Data Protection Authority.

Withdrawing Consent

You may withdraw consent at any time by contacting us. This does not affect prior processing or any lawful basis other than consent.

Account Information

You may:

• Update your profile via the app;
• Use the “Delete my account” button under Privacy and Security;
• Contact us for assistance.

Some data may be retained for fraud prevention, legal obligations, or ongoing investigations.

10. CHILD DATA CLAUSE

Our Services are not intended for individuals under the age of 18.

We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected such data, we will take immediate steps to delete it. Parents or legal guardians may contact us if they believe a minor has submitted information.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

While some browsers and mobile OSs include Do-Not-Track (“DNT”) features, no standard has been established for DNT compliance. We do not currently respond to such signals.

12. DO WE MAKE UPDATES TO THIS POLICY?

We periodically review and update this Privacy Policy in compliance with the Data Protection Act [Zimbabwe]. Changes will be posted with a revised date. Material changes may also be communicated directly.

13. GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by and interpreted in accordance with the laws of Zimbabwe. Any disputes shall fall under the exclusive jurisdiction of the courts of Zimbabwe.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or wish to exercise your rights, please contact us:

Email: info@airmassafrica.co.zw
Phone: +263 789 925 823
Postal Address:
Airmass Sustainables (Private) Limited
356 Rayden Drive, Philadelphia
Borrowdale, Harare, Zimbabwe