Privacy Policy

WATHACI Corporate Services is a business advisory, corporate services and technology firm registered in the Republic of Zambia, with its principal place of business in Lusaka. For the purposes of the Zambia Data Protection Act No. 3 of 2021 and the EU/UK General Data Protection Regulation (where applicable), WATHACI is the data controller of personal information it collects through this website and its client engagements.

This policy applies to personal information collected through wathaci.com, our client engagements, and interactions with our digital products. Each product may publish its own supplemental privacy notice covering product-specific processing.

• Identity data: name, job title, employer, professional credentials.
• Contact data: email address, telephone number, physical address.
• Engagement data: information you share when requesting a proposal, consultation or service, including business objectives and documents you submit.
• Technical data: IP address, device identifiers, browser type, operating system, referring URLs and pages viewed.
• Usage data: interactions with our website and products, including analytics and performance metrics.
• Recruitment data: information provided when applying for a role (CV, cover letter, references).
• Product data: account details, transactions, group/league/network data submitted through POKOTO, Cue Hard-Breaks or WATHACI Connect.

We do not intentionally collect sensitive personal information (e.g. health, biometric, political opinions) unless it is strictly necessary for a specific engagement and you have given explicit consent.

• Directly from you when you complete forms, email us, engage us as a client, or register for a product.
• Automatically through cookies and similar technologies when you visit our website.
• From third parties such as public registries, referral partners, and reference checks (with your knowledge).

We process personal information on the following legal bases under the Zambia Data Protection Act, GDPR and comparable laws:

• Contract: to negotiate, deliver and manage the services you request from us.
• Legitimate interests: to operate and secure our business, communicate about services, and improve our products, balanced against your rights.
• Consent: for marketing communications, non-essential cookies and any optional data you provide.
• Legal obligation: to comply with tax, corporate, anti-money-laundering, know-your-customer and other statutory requirements.
• Vital interests / public interest: only where strictly necessary.

We do not sell personal information. We share it only with:

• Authorised WATHACI staff and contractors bound by confidentiality.
• Trusted service providers (cloud hosting, email, analytics, payment processors) under written data processing agreements.
• Professional advisers (auditors, lawyers, accountants) where necessary.
• Regulators, courts and law enforcement where required by Zambian or applicable foreign law.
• Successors in the event of a merger, acquisition or reorganisation, subject to equivalent protection.

Some of our service providers are located outside Zambia. Where personal information is transferred cross-border, we rely on appropriate safeguards permitted under the Zambia Data Protection Act (including consent, contract necessity or adequacy) and, where applicable, GDPR mechanisms such as Standard Contractual Clauses.

We keep personal information only for as long as necessary to fulfil the purposes described above, including legal, accounting and reporting obligations. Client engagement records are typically retained for at least ten (10) years in line with Zambian corporate, tax and anti-money-laundering requirements. Marketing data is retained until you withdraw consent.

Subject to applicable law, you have the right to:

• Access the personal information we hold about you.
• Request correction of inaccurate or incomplete information.
• Request deletion where permitted by law.
• Object to or restrict certain processing.
• Withdraw consent at any time where processing is based on consent.
• Request portability of information you provided to us.
• Lodge a complaint with the Data Protection Commissioner of Zambia or your local supervisory authority.

To exercise these rights, contact us at support@wathaci.com. We will respond within statutory timelines (30 days under the Zambia Data Protection Act, extendable where permitted).

We apply technical and organisational measures including access controls, encryption in transit, secure cloud infrastructure, least-privilege access, regular backups and staff confidentiality obligations. No system is completely secure; we will notify affected individuals and the relevant authority of any personal data breach as required by law.

We use strictly necessary cookies to operate the site and, with your consent, analytics cookies to understand usage. You can control cookies through your browser settings. Disabling cookies may affect functionality.

Our services are directed at businesses and adults. We do not knowingly collect personal information from children under 18 without verifiable parental consent.

We may update this policy from time to time. Material changes will be highlighted on this page with a new effective date.

Data Protection Contact — WATHACI Corporate Services, Lusaka, Zambia. Email: support@wathaci.com · Phone: +260 972 896 005.