Privacy Policy

1. Introduction

This Privacy Policy applies to Zinia ISP (Pty) Ltd, Zinia Connect (Pty) Ltd and Zinia Devworks (Pty) Ltd, collectively trading as Zinia (“Zinia”, “we”, “us”, or “our”), and is committed to protecting your personal information and ensuring that it is collected, used, and processed lawfully, transparently, and securely.

This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you:

• Visit our website
• Engage with our services
• Communicate with us
• Enter into a business relationship with us

This policy is aligned with the Protection of Personal Information Act, 4 of 2013 (POPIA), as well as applicable provisions of the Electronic Communications and Transactions Act (ECTA) and the Consumer Protection Act (CPA).

2. Company Information

Zinia ISP (Pty) Ltd, Zinia Connect (Pty) Ltd and Zinia Devworks (Pty) Ltd, collectively trading as Zinia.
Johannesburg, South Africa

General Contact: info@zinia.co.za / +27 11 462 0900

3. Information Officer

In accordance with POPIA, Zinia has appointed the following:

Deputy Information Officer:
Julie Davis
Email: privacy@zinia.co.za

The Information Officer is responsible for ensuring compliance with POPIA, managing data protection practices, and handling data-related requests.

You may contact the Information Officer for:

• Access to your personal data
• Correction or deletion requests
• Objections to processing
• Complaints regarding privacy

Access to information requests are governed by our PAIA Manual, available here: [link]

4. Scope of This Policy

This Privacy Policy applies to:

• Website visitors
• Prospective clients and leads
• Existing clients
• Suppliers and partners
• Individuals interacting with Zinia

It covers both:

• Personal information collected via the website, and
• Information processed as part of our IT and technology services

5. Categories of Personal Information We Collect

User-generated content submitted through collaboration, support, productivity, automation, or AI-enabled platforms.

We may collect and process the following categories of personal information:

5.1 Identification & Contact Information

• Full name
• Email address
• Phone number
• Company name and job title

5.2 Business & Service Information

• IT environment details
• Infrastructure and system information
• Service requirements and project data

5.3 Technical & Usage Data

• IP address
• Browser type and version
• Device information
• Pages visited and interaction data

5.4 Communication Data

• Email correspondence
• Support queries
• Meeting notes and call records

5.5 Marketing Data

• Preferences and consent records
• Campaign interaction data

6. How We Collect Information

We collect personal information through:

• Website forms (contact, enquiries, downloads)
• Direct communication (email, phone, meetings)
• Service delivery interactions
• Cookies and tracking technologies
• Third-party platforms (e.g. CRM, marketing tools)

7. Lawful Basis for Processing (POPIA Compliance)

We process personal information based on:

• Consent – where you have explicitly agreed
• Contractual necessity – to provide services to you
• Legitimate interest – to operate and improve our business
• Legal obligation – where required by law

8. How We Use Personal Information

We use personal information to:

• Provide and manage our services
• Deliver managed IT, cybersecurity, cloud, and connectivity solutions
• Respond to enquiries and support requests
• Manage client relationships and contracts
• Improve website functionality and user experience
• Conduct analytics and performance tracking
• Send relevant communications and marketing (where permitted)
• Ensure security, monitoring, and fraud prevention

Use of Artificial Intelligence and AI-Assisted Technologies

Zinia may use artificial intelligence (“AI”), machine learning, automation, and AI-assisted technologies to improve operational efficiency, service delivery, customer support, cybersecurity monitoring and reporting, software development, data analysis, and business administration.

Where AI-assisted technologies are used, Zinia implements reasonable measures to ensure that personal information is processed lawfully, securely, and in accordance with POPIA.

Zinia does not knowingly use personal information submitted through its website to train public AI models. Employees, contractors, and authorised users are required to follow internal policies governing the use of AI tools and the handling of personal information.

The use of AI technologies does not remove Zinia’s responsibility to protect personal information and comply with applicable data protection legislation.

9. Service-Specific Data Processing

As an IT and technology service provider, Zinia may process data on behalf of clients, including:

• System and infrastructure data
• Network traffic and logs
• User and access data
• Security and monitoring data

In these cases:

• Zinia acts as an Operator (Data Processor)
• The client remains the Responsible Party (Data Controller)
• Processing is governed by contractual agreements (e.g. MSA / SLA / DPA)

We implement strict controls to ensure the confidentiality, integrity, and security of client data.

10. Sharing of Personal Information

We may share personal information with:

10.1 Service Providers

Including:

• Hosting providers
• Cloud platforms (e.g. Microsoft, AWS)
• CRM and marketing platforms
• Analytics tools
• IT support and monitoring systems

Cloud platforms, AI service providers, cybersecurity platforms, CRM platforms, communications providers, analytics platforms and other authorised technology partners.

All third parties are contractually required to protect your data.

10.2 Business Partners

Where necessary to deliver services or solutions.

10.3 Legal and Regulatory Authorities

Where required by law or to protect rights and safety.

10.4 Business Transfers

In the event of a merger, acquisition, or restructuring.

11. Cross-Border Data Transfers

Zinia may transfer, process, store, or permit access to personal information outside the Republic of South Africa where required for service delivery, business operations, cloud hosting, cybersecurity, communications, software platforms, artificial intelligence tools, backup services, or other technology services.

These transfers may involve service providers located in jurisdictions including, but not limited to, the United States, European Union member states, the United Kingdom, and other countries in which our authorised service providers operate.

Where personal information is transferred outside South Africa, Zinia takes reasonable steps to ensure that appropriate safeguards are in place, including contractual protections, vendor assessments, security controls, and compliance measures intended to satisfy applicable POPIA requirements.

12. Data Retention

We retain personal information only for as long as necessary:

• Leads: retained for a reasonable period for follow-up
• Clients: duration of relationship + legal retention period
• Financial records: as required by South African law
• Technical logs: limited retention for security and analysis

Data is securely deleted or anonymised when no longer required.

13. Security of Personal Information

Zinia implements industry-standard security measures, including:

• Access control and authentication
• Encryption where appropriate
• Network and endpoint protection
• Continuous monitoring and logging
• Vulnerability management
• Secure data storage practices
• Acceptable Use Policies
• Data Classification Standards
• AI Governance Controls
• Vendor Risk Assessments

While we take all reasonable steps, no system is completely secure.

14. Data Breach Response

In the event of a data breach:

• We will investigate and contain the incident
• Affected parties will be notified where required
• The Information Regulator will be notified where applicable
• Remediation steps will be implemented

15. Your Rights Under POPIA

You have the right to:

• Access your personal information
• Request correction or deletion
• Object to processing
• Withdraw consent
• Lodge a complaint with the Information Regulator

Requests can be submitted to:
privacy@zinia.co.za

16. Direct Marketing

We comply with POPIA, ECTA, and CPA requirements:

• Marketing is based on consent or an existing relationship
• You may opt out at any time
• Opt-out requests are processed free of charge

17. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Ensure website functionality
• Analyse traffic and performance
• Improve user experience

Types of cookies include:

• Essential cookies
• Analytics cookies
• Performance cookies

You can manage cookie preferences via your browser settings.

18. Third-Party Links

Our website may contain links to third-party websites.
We are not responsible for their privacy practices.

19. Children’s Privacy

Our services are not directed at children.
We do not knowingly collect personal information from minors.

20. Changes to This Policy

We may update this Privacy Policy from time to time.
Changes will be published on our website with an updated date.

21. Contact Us

For any privacy-related queries or requests:

Email: privacy@zinia.co.za
Phone: +27 11 462 0900