Privacy Policy
Last updated: 28th June 2023
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Please read this Privacy Policy carefully before using Our Service.
1 - Interpretation and Definitions
1.1 - Interpretation
The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in the singular or in the plural.
1.2 - Definitions
For the purposes of this Privacy Policy:
● Account means a unique account created for You to access our Service or parts of our Service.
● Affiliate means an entity that controls, is controlled by, or is under common control with a party, where"control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.
● Application means the software program provided by the Company or Operator downloaded by You on any electronic device, named Rivuuz
● Business refers to the Company or Operator as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information.
● Company (referred to as either "the Company", "We", "Us" or "Our" in thisAgreement) refers to Rivuuz Business Solutions Ltd (‘Rivuuz’), Ibex Hill, Lusaka. For the purpose of the GDPR, the Company or Operator is the DataController.
● Consumer, refers to You.
● Cookies are small files that are placed onYour computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
● Country refers to Zambia
● Data Controller, for the purposes of the GDPR(General Data Protection Regulation), refers to the Company or Operator as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
● Device means any device that can access theService such as a computer, a cellphone, or a digital tablet.
● Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal TradeCommission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
● Operator (referred to as either "theOperator", "We", "Us" or "Our" in thisAgreement) refers to Rivuuz. For the purpose of the GDPR, the Company orOperator is the Data Controller.
● Personal Data is any information that relates to an identified or identifiable individual.
For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, PersonalData means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
● Sale, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.
● Service refers to the Application or theWebsite or both.
● Service Provider means any natural or legal person who processes the data on behalf of the Company or Operator. It refers to third-party companies or individuals employed by the Company or Operator to facilitate the Service, to provide the Service on behalf of the Company orOperator, to perform services related to the Service or to assist the Company or Operator in analysing how the Service is used. For the purpose of the GDPR,Service Providers are considered Data Processors.
● Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
● Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
● Website refers to Rivuuz accessible from www.rivuuz.com
● You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as theData Subject or as the User as you are the individual using the Service.
2 - Contact Us
If you have any questions about thisPrivacy Policy, You can contact us:
● By email: hello@rivuuz.com
● By visiting this page on our website: https://www.rivuuz.com/contact-us
3 - Collecting and Using Your Personal Data
3.1 - Types of Data Collected
3.1.1 - Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally, identifiable information may include, but is not limited to:
● Email address
● First name and last name
● Phone number
● Address, State, Province,ZIP/Postal code, City
● Bank account information
● Credit card number and expiration date
● Usage Data
3.1.2 - Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date ofYour visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
3.1.3 - Information fromThird-Party Social Media Services
The Company or Operator may allow You to create an account and log in to use the Service through the followingThird-party Social Media Services. These Third-party Social Media Services, may include, but is not limited to:
● Apple
If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collectPersonal data that is already associated with Your Third-Party Social MediaService's account, such as Your name, Your email address, Your activities orYour contact list associated with that account.
You may also have the option of sharing additional information with the Company or Operator through Your Third-PartySocial Media Service's account. If You choose to provide such information andPersonal Data, during registration or otherwise, You are giving the Company orOperator permission to use, share, and store it in a manner consistent with this Privacy Policy.
3.1.4 - Tracking Technologies andCookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies We use may include:
● Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse allCookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, ourService may use Cookies.
● Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit theCompany or Operator, for example, to count users who have visited those pages or opened an email and for other related application or website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or"Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and PersistentCookies for the purposes set out below:
● Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Application or Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
● Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Application or Website.
● Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use theApplication or Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Application or Website.
● Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to theApplication or Website and how users use the Application or Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Application or Website. We may also use these Cookies to test new pages, features or new functionality of the Application or Website to see how our users react to them.
3.2 - Use of Your Personal Data
The Company or Operator may use PersonalData for the following purposes:
● To provide and maintain our Service, including to monitor the usage of our Service.
● To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can giveYou access to different functionalities of the Service that are available toYou as a registered user.
● For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
● To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
● To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unlessYou have opted not to receive such information.
● To manage Your requests: To attend and manageYour requests to Us.
● To deliver targeted advertising to You: We may use Your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.
● For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
● For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
● With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to advertise on third party websites to You after You visited ourService, for payment processing, to contact You.
● For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company or Operator assets, financing, or acquisition of all or a portion of Our business to another company.
● With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to hon or this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
● With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
● With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.If You interact with other users or register through a Third-Party Social MediaService, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
● With Your consent: We may disclose Your personal information for any other purpose with Your consent.
3.3 - Retention of Your Personal Data
The Company or Operator will retain YourPersonal Data only for as long as is necessary for the purposes set out in thisPrivacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company or Operator will also retainUsage Data for internal analysis purposes. Usage Data is generally retained fora shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
When Your Personal Data is no longer required by law or rights or obligations by Us or You, We will delete thePersonal Data. In most cases, Personal Data will be deleted upon termination or expiry of the agreement between the You and the Company or Operator or uponYour written request.
3.4 - Transfer of Your Personal Data
Your information, including PersonalData, is processed at the Company’s or Operator's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company or Operator will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other personal information.
3.5 - Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis todo so.
3.6 - Disclosure of Your Personal Data
3.6.1 - Business Transactions
If the Company or Operator is involved ina merger, acquisition or asset sale, Your Personal Data may be transferred. Wewill provide notice before Your Personal Data is transferred and becomessubject to a different Privacy Policy.
3.6.2 - Law enforcement
Under certain circumstances, the Companyor Operator may be required to disclose Your Personal Data if required to do soby law or in response to valid requests by public authorities (e.g. a court ora government agency).
3.6.3 - Other legal requirements
The Company or Operator may disclose YourPersonal Data in the good faith belief that such action is necessary to:
● Comply with a legal obligation
● Protect and defend the rights orproperty of the Company or Operator
● Prevent or investigate possiblewrongdoing in connection with the Service
● Protect the personal safety ofUsers of the Service or the public
● Protect against legal liability
3.7 - Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
4 - Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
4.1 - Analytics
We may use third-party Service providers to monitor and analyse the use of our Service. They may include, but are not limited to:
● Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to GoogleAnalytics by installing the Google Analytics opt-out browser add-on. The add-onprevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) fromsharing information with Google Analytics about visits activity.
You may opt-out of certain Google Analytics features through your mobile devicesettings, such as your device advertising settings or by following theinstructions provided by Google in their Privacy Policy: https://policies.google.com/privacy
For more information on the privacy practices of Google, pleasevisit the Google Privacy & Terms web page: https://policies.google.com/privacy
● Matomo
Matomo is a web analytics service. You can visit their Privacy Policy pagehere: https://matomo.org/privacy-policy
● Fathom
Fathom is a web analytics service. You can visit their Privacy Policy pagehere: https://www.fathomhq.com/privacy
4.2 - Email Marketing
We may use Your Personal Data to contactYou with newsletters, marketing or promotional materials and other informationthat may be of interest to You. You may opt-out of receiving any, or all, ofthese communications from Us by following the unsubscribe link or instructionsprovided in any email We send or by contacting Us.
We may use Email Marketing ServiceProviders to manage and send emails to You. They may include, but are notlimited to:
● Mailerlite
Mailerlite is an email marketing sending service. For more information on the privacy practices of Mailerlite, please visit their Privacy policy: https://www.mailerlite.com/legal/privacy-policy
4.3 - Payments
We may provide paid products and/orservices within the Service. In that case, we may use third-party services forpayment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
They may include, but are not limited to:
● DPO
Their Privacy Policy can be viewed at https://dpogroup.com/privacy-policy/
4.4 - Behavioral Remarketing
The Company or Operator uses remarketing services to advertise to You after You accessed or visited our Service. We andOur third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.
These third-party vendors collect, store,use, process and transfer information about Your activity on Our Service inaccordance with their Privacy Policies and to enable Us to:
● Measure and analyze traffic andbrowsing activity on Our Service
● Show advertisements for ourproducts and/or services to You on third-party websites or apps
● Measure and analyze theperformance of Our advertising campaigns
Some of these third-party vendors may usenon-cookie technologies that may not be impacted by browser settings that blockcookies. Your browser may not permit You to block such technologies. You canuse the following third-party tools to decline the collection and use ofinformation for the purpose of serving You interest-based advertising:
● The NAI's opt-out platform: http://www.networkadvertising.org/choices/
● The EDAA's opt-out platform http://www.youronlinechoices.com/
● The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
You may opt-out of all personalizedadvertising by enabling privacy features on Your mobile device such as Limit AdTracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobiledevice Help system for more information.
We may share information, such as hashedemail addresses (if available) or other online identifiers collected on OurService with these third-party vendors. This allows Our third-party vendors torecognize and deliver You ads across devices and browsers. To read more aboutthe technologies used by these third-party vendors and their cross-devicecapabilities please refer to the Privacy Policy of each vendor listed below.
The third-party vendors We may use are,but are not limited to:
● Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise theGoogle Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-outBrowser Add-on - https://tools.google.com/dlpage/gaoptout - foryour web browser. Google Analytics Opt-out Browser Add-on provides visitors withthe ability to prevent their data from being collected and used by GoogleAnalytics.
For more information on the privacy practices of Google, please visit theGoogle Privacy & Terms web page: https://policies.google.com/privacy
● Twitter
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by following theirinstructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies ofTwitter by visiting their Privacy Policy page: https://twitter.com/privacy
● Facebook / Meta
Facebook or Meta remarketing service is provided by Facebook Inc. and Meta Inc.
You can learn more about interest-based advertising from Facebook by visitingthis page: https://www.facebook.com/help/516147308587266
To opt-out from Facebook's interest-based ads, follow theseinstructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for OnlineBehavioural Advertising established by the Digital Advertising Alliance. Youcan also opt-out from Facebook and other participating companies through theDigital Advertising Alliance in the USA http://www.aboutads.info/choices/,the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/,or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visitFacebook's Data Policy: https://www.facebook.com/privacy/explanation
● Pinterest
Pinterest remarketing service is provided by Pinterest Inc.
You can opt-out from Pinterest's interest-based ads by enabling the "DoNot Track" functionality of your web browser or by following Pinterestinstructions: http://help.pinterest.com/en/articles/personalization-and-data
You can learn more about the privacy practices and policies ofPinterest by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy
4.5 - Usage, Performance and Miscellaneous
We may use third-party Service Providersto provide better improvement of our Service. They may include, but are notlimited to:
● Intercom
Their Privacy Policy can be viewed at https://www.intercom.com/legal/privacy
● Facebook Messenger
Their Privacy Policy can be viewed at https://www.facebook.com/privacy/policy
● Zendesk
Their Privacy Policy can be viewed at https://www.zendesk.com/company/agreements-and-terms/privacy-notice/
● Tawk
Their Privacy Policy can be viewed at https://www.tawk.to/privacy-policy/
5 - Links to Other Websites
Our Service may contain links to otherwebsites that are not operated by Us. If You click on a third party link, Youwill be directed to that third party's site. We strongly advise You to reviewthe Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
6 - GDPR Privacy
6.1 - Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
● Consent: You have given Your consent forprocessing Personal Data for one or more specific purposes.
● Performance of a contract: Provision ofPersonal Data is necessary for the performance of an agreement with You and/orfor any pre-contractual obligations thereof.
● Legal obligations: Processing Personal Data isnecessary for compliance with a legal obligation to which the Company orOperator is subject.
● Vital interests: Processing Personal Data isnecessary in order to protect Your vital interests or of another naturalperson.
● Public interests: Processing Personal Data isrelated to a task that is carried out in the public interest or in the exerciseof official authority vested in the Company or Operator.
● Legitimate interests: Processing Personal Datais necessary for the purposes of the legitimate interests pursued by theCompany or Operator.
In any case, the Company or Operator willgladly help to clarify the specific legal basis that applies to the processing,and in particular whether the provision of Personal Data is a statutory orcontractual requirement, or a requirement necessary to enter into a contract.
6.2 - Your Rights under the GDPR
The Company or Operator undertakes torespect the confidentiality of Your Personal Data and to guarantee You canexercise Your rights.
You have the right under this PrivacyPolicy, and by law if You are within the EU, to:
● Request access to Your Personal Data. Theright to access, update or delete the information We have on You. Whenever madepossible, you can access, update or request deletion of Your Personal Datadirectly within Your account settings section. If you are unable to performthese actions yourself, please contact Us to assist You. This also enables Youto receive a copy of the Personal Data We hold about You.
● Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information Wehold about You corrected.
● Object to processing of Your Personal Data.This right exists where We are relying on a legitimate interest as the legalbasis for Our processing and there is something about Your particular situation,which makes You want to object to our processing of Your Personal Data on thisground. You also have the right to object where We are processing Your PersonalData for direct marketing purposes.
● Request erasure of Your Personal Data. Youhave the right to ask Us to delete or remove Personal Data when there is nogood reason for Us to continue processing it.
● Request the transfer of Your Personal Data. Wewill provide to You, or to a third-party You have chosen, Your Personal Data ina structured, commonly used, machine-readable format. Please note that thisright only applies to automated information which You initially providedconsent for Us to use or where We used the information to perform a contractwith You.
● Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
6.3 - Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. IfYou make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a DataProtection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
7 - Children's and Minor Users Privacy Rights
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You area parent or guardian and You are aware that Your child has provided Us withPersonal Data, please contact Us. If We become aware that We have collectedPersonal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legalbasis for processing Your information and Your country requires consent from aparent, We may require Your parent's consent before We collect and use thatinformation.
8 -Changes to this Privacy Policy
We may update Our Privacy Policy fromtime to time. We will notify You of any changes by posting the new PrivacyPolicy on this page.
We will let You know via email and/or aprominent notice on Our Service, prior to the change becoming effective andupdate the "Last updated" date at the top of this Privacy Policy.
You are advised to review this PrivacyPolicy periodically for any changes. Changes to this Privacy Policy areeffective when they are posted on this page.