Privacy Policy

This Privacy Policy (“Privacy Policy”) applies to the processing of personal data of users (“user” or “you”) by Via Eswatini Logistics (Pty) Ltd (“we” or “us”), the registered legal company of Via Eswatini Foods (“VEF”), when you use the VEF mobile application (“app”) or otherwise interact with us and this Privacy Policy is presented to you, in accordance with Data Protection Act of 2022 (“DPA”) and other applicable local laws, as amended or replaced (jointly, “Applicable Privacy Laws”).

1. Data Controller and Data Protection Officer

The Data Controller is Via Eswatini Logistics (Pty) Ltd, based in Mbabane, Eswatini. For any requests regarding the processing of your personal data, please email us at viaeswatini@hotmail.com.

Our Data Protection Officer can be contacted by sending an email to viaeswatini@hotmail.com for any requests relating to the processing of your personal data or this Privacy Policy.

2. Categories of Personal Data that We Collect, Purposes, and Legal Bases for Our Processing

We process the following categories of personal data, for the purposes and on the legal bases indicated below. Please note that not all of the below information may be deemed personal data in your jurisdiction in all cases.

Purpose	Legal Basis	Categories of Processed Data
To enable you to use the app and to provide you with its functionalities, including changing your profile photos.	The legal basis for the processing is the performance of our contractual relationship.	Identifiers, internet and network activity information such as IP address, device model, device type, OS version, device language, device name, country set in the device settings, information about your interactions with the app, unique identifiers, and metadata (such as your name and copyright information). Images from your library or shot though the in-app camera. If the app needs to access your photo and video library, it requires your permission.
To improve our products and services (for example, by conducting statistical analysis or other research activities to optimize our features and provide you with new ones).	The legal basis for the processing is our legitimate interest to improve our products and services.	Identifiers and internet and network activity information (such as IP address, IDFV and installation identifier), and information collected or generated to improve the app’s functionalities (such as information about your interactions with the app, inferences we generate and other related information about your usage of the app, app version, device info, country, language, timezone, payment transaction identifiers and dates, imported and processed images metadata).
To ensure the quality of the services by analyzing, preventing or correcting failures and bugs, illicit use or misuse of the services.	The legal basis for the processing is our legitimate interest to ensure the quality and the smooth functioning of the service.	Identifiers, internet and network activity information (such as IP address), inferences we generate and other related information about your usage of the app, crash data (such as crash reports, errors happening while capturing a photo or saving a processed picture) and performance data (only linked to crashes).
To comply with our legal obligations, including requests from public authorities.	The legal basis for the processing is compliance with legal obligations to which we are subject.	Any information which may be required by law or under the instructions of public authorities.
To process and respond to customer support communications and to requests for information you may raise with us.	The legal basis for the processing is the performance of our contractual relationship.	Identification and contact information you provide us (such as name, email address, phone number) and the content of your communication or request.
To establish, exercise or defend our rights and those of our employees, and to carry out corporate transactions or operations (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions).	The legal basis for the processing is our legitimate interest to establish, exercise or defend our rights and to carry out corporate transactions or operations.	Any information necessary to ensure the performance of these purposes.
To create user profiles by analyzing your usage information, including your preferences, interests and behaviors when you use our products and services to maintain, optimize, and develop new features.	The legal basis for the processing is our legitimate interest. The collection of personal data by means of profiling and third-party analytics tracking technologies is based on your consent.	Your identification and contact information (such as name, age or email address, when requested), identifiers and Internet and network activity information that we collect, information about your interactions with the app, and other related information about your usage of the app.

3. Data Storage and Protection

Personal data may be processed by both automated and non-automated means and may be stored at our premises and on our service providers’ servers. We adopt technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, we may also adopt data encryption and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk.

Personal data processed for the purposes referred to will be kept for a period not exceeding the one necessary for the said purposes.

Except for any legal obligation that sets a longer data retention period, at the end of the periods, the personal data processed will be deleted or anonymized.

4. Your Choices with Regard to the Use of Your Personal Data

It is mandatory for you to provide your personal data for the purposes of utilizing the App and it is your responsibility to ensure that the details provided by you on registration or any time are accurate, complete and up to date. If you do not provide the personal data, you will not be able to enjoy the app’s services and features.

5. Sharing Your Personal Data

We may share or disclose your personal data to the following categories of recipients:

Vendors carrying out activities that are related or instrumental to our business and operational activities as outsourced data processors appointed in writing in accordance with Applicable Privacy Laws, or acting as autonomous data controllers (such as IT or storage service providers, mobile measurement partners).
If we carry out a corporate transaction or operation (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions), your personal data may be disclosed to our advisers and any prospective purchaser's advisers, and may be one of the assets that is transferred to another owner.
Public, judicial or police authorities, within the limits established by applicable laws.

Personal data will not be disclosed for any reason other than those stated above, unless such disclosure is deemed necessary for the fulfillment of a legal obligation or if we request your consent.

6. Transfers of Personal Data Outside the Kingdom of Eswatini

We may transfer personal data from the Kingdom of Eswatini. Such data transfers are based on appropriate safeguards in accordance with Applicable Privacy Law.

7. Your Rights

At any time and free of charge, you can exercise the following rights, as specified and subject to certain limitations and exceptions under Applicable Privacy Laws:

Right of access. You have the right to obtain information about the processing of your personal data and to access it.
Right to rectification. You have the right to ask for the updating, rectification or integration of your personal data.
Right to erasure. You have the right to request the deletion of your personal data.
Right to restriction of processing. You have the right to request the restriction of the processing of your personal data.
Right to data portability. You have the right to obtain a portable electronic copy of your personal data.
Right to object. Where we rely on our legitimate interest to process your personal data, you have the right to object to such processing, wholly or partly, on grounds related to your particular situation. In particular, you are entitled to object to the processing of your personal data for direct marketing purposes, including profiling.
Right to withdraw your consent. Where we rely on your consent to process your personal data, you have the right to withdraw your consent, although the processing carried out before your withdrawal of consent will remain valid.

You also have the right to lodge a complaint before the competent national Data Protection Authority, in particular before the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

To exercise your rights, you can contact us by sending an email to viaeswatini@hotmail.com. We may take reasonable steps to verify your identity prior to responding to your request.

8. Children’s Personal Data

The app is not intended for anyone under the age of 16. We do not knowingly collect personal data from children. If you believe we have received personal data from children under the age of 16, please email us. If we learn that a user is under the age of 16, we will take reasonable steps to delete any processed data and close such user’s account.

9. Third-party Websites and Services

The app may include links to other websites or services operated by third parties. The activities described in this Privacy Policy do not apply to data processed by such third-party websites and services. We have no control over, and we are not responsible for, the actions and privacy policies of third parties and other websites and services.

10. Changes to this Privacy Policy

We may modify, integrate or update, in whole or in part, this Privacy Policy, and we will notify users of any modification, integration or update in accordance with Applicable Privacy Laws. If we make modifications, we will notify you by revising the date at the bottom of this Privacy Policy and, under certain circumstances, we may also notify you by additional means such as pop-up or push notifications within the app or our website, or email.

12. In-app Tracking Technologies

When we refer to “tracking technology/technologies” in this Policy, we mean any technology that stores or accesses information on the user’s device, including SDK, tracking pixel, HTML5 local storage, local shared object, and fingerprinting technique.

Tracking technologies are usually classified:

by purpose (Technical, Analytics, Profiling);
by publisher (First-party, Third-party).

13. By registering on the App and utilising the services you consent that we may record, use and hold the following types of information about you:

All information contained in the forms or other documentation you submit to us and any other subsequent information or details you update or provide afterwards. This may include your name, contact details, address, age, identity/passport number and transaction records;

Information we use to process your registration on the App;

Other demographic and lifestyle information which is derived from your shopping patterns when using the App and a payment card;

Your delivery address;

The location of your use of the App;

Details of when you contact us and when we contact you. This includes for example email addresses, telephone numbers you contact us from and the content of the communications with us which may be recorded.