Privacy Notice

This privacy notice for Belina Time Systems ('Company', 'we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:

• Visit our website at belinapayroll.com, or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

This Privacy Statement applies to all personal information you provide to us. In this document we will tell you how we collect, process & share your personal information and explain your rights regarding it.

Our Role

We act as either a Controller or Processor depending upon the nature of our engagement with you. Generally:

• Where we determine the purpose and means of processing, we are a data controller.
• Where we process personal data based upon your explicit instructions as per the provisions of The Cyber and Data Protection Act [Chapter 12:07], we are a data processor.

How we obtain personal information

Personal information also known as personal data is any information that relates to a specific natural person or individual. We collect this information for us to perform or inform you about our services.

Personal information that you provide us by:

• Filling in forms on our websites belinapayroll.com
• Corresponding with us via email, letter, or by telephone
• Communicating with us via chat on our website
• Communicating with us via the clients' portal "Freshdesk"
• CCTV system footage that may be recorded when you visit our premises.
• Personal Messaging via services such as SMS, WhatsApp® and Facebook®

Personal Information that we process about you

If you are enquiring about our services as a prospective customer, we process the following:

• First name
• Last name
• phone numbers
• email address
• Postal address
• Physical Address
• Tax Identification Number (TIN Number for Company)
• job titles
• Company Names

If you are a supplier, we process the following:

• Company Name
• TIN Number
• Company Address
• Phone Numbers
• contact person's details (Name, email address, phone number)

If you contact us for recruitment purposes, we may process:

• Your Curriculum Vitae (CV) containing your Personal Information

If you are a customer using our payroll services, we may process:

• Contact Details
• Unique identification numbers such as TIN numbers
• National Identification Numbers
• Social Security Numbers and other related numbers
• Salary information (Earnings, Tax and Deductions)

Sensitive Information (Special Categories of personal information)

We do not process sensitive information such as ethnicity or marital status. However, for certain activities such as the payroll bureau service this may be necessary in order to fulfil the contractual and/or legal obligations.

Legal basis of data processing

We process your personal information based on one or more of the following legal bases, depending on the purpose of the processing.

• Performance of a Contract: We process your personal information to fulfill our contractual obligations to you. This is the primary basis for collecting your contact details, as it is necessary to provide you with a software license, manage billing, and offer technical support.
• Legitimate Interests: We process your information for our legitimate business interests, provided that these interests do not override your fundamental rights and freedoms. Our legitimate interests include: Service Improvement, Fraud Prevention, Security, and Procurement.
• Legal Obligation: We may process your personal information to comply with legal and regulatory obligations, such as responding to a court order or other lawful requests from public authorities.
• Consent: In certain situations, we may ask for your explicit consent to process your personal information for a specific purpose. When we do this, we will clearly explain the purpose and you have the right to withdraw your consent at any time.

Retention of personal information

We retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

The criteria used to determine our retention periods include:

• The length of our ongoing relationship with you
• The existence of a legal or regulatory obligation to retain the data

When the retention period for your personal information expires, we will either securely delete or anonymize it so that it can no longer be associated with you.

Security and International Transfers

Security

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

International Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are a resident. The cloud service providers that we use such as Microsoft Azure and AWS have data centres all over the world other than Zimbabwe.

When we transfer your information internationally, we will take appropriate safeguards to ensure that your data is protected in accordance with this Privacy Policy and applicable law. This includes:

• Transferring data to countries that have been deemed to provide an adequate level of data protection.
• Using standard contractual clauses (SCCs) approved by data protection authorities.
• Implementing other technical and organizational security measures.

Data sharing

We do not sell, trade, rent, or otherwise transfer your personally identifiable information to third parties, except as described below:

• Service Providers: We may share information with trusted third-party service providers (such as Freshdesk for customer relationship management, Microsoft Azure and Amazon Web Services for cloud-hosted services) who assist us in operating our business and providing services to you, provided that these parties agree to keep this information confidential and comply with privacy regulations.
• Legal Requirements: We may disclose information if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email or a prominent notice on our website of any such change in ownership or control of your personal information.

Your Rights

You have certain rights regarding your personal information:

• Access and Correction: You may request access to the client contact details we hold about you and request corrections to any inaccuracies.
• Data Portability: You may request a copy of the client contact details you have provided to us.
• Withdraw Consent: Where we rely on your consent to process your information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
• Objection/Deletion: You may have the right to object to certain processing activities or request the deletion of your client contact details, subject to our legal and contractual obligations to retain certain information.
• Complain: You have the right to lodge a complaint with a data protection authority if you believe your rights have been violated.

Profiling and automated decision making

You have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you.

Children's Privacy

We do not solicit data from or market to individuals under 18. Unauthorized minor data will be deleted promptly.

Updates to Privacy Notice

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

Contact Us

If you have any questions about this Privacy Policy, our data practices, or your dealings with our software, please contact us at:

Email: dpo@belinamail.com

Phone: 08677799799

Company Address: 27 Van Praagh Avenue, Milton Park, Harare, Zimbabwe