Last revised: 22-02-20211.

1. INTRODUCTION
Your privacy is important to us. The purpose of this Privacy Policy is to describe how Fullstack ZW collects, uses and shares information about you through our mobile App, Lotapay. Please read this notice carefully to understand what we do. If you do not understand any aspect of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy.

This Privacy Policy applies only to information we collect at, on and through the Lotapay application. Our website and other affiliated sites, such as fullstack.co.zw may be governed by their own separate privacy policies which are set forth therein. Links to third party sites are not owned or controlled by Fullstack. Please take note that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave the Lotapay application and to read the privacy statements of each and every application that collects personal information. Please note that your use of the Lotapay application is also subject to our Terms of Use.

2. INFORMATION WE COLLECT AND WHY WE COLLECT IT

We collect certain personal information on registration in order to offer the best user experience when interacting with our platform, some of it is personally identifiable information which will never be disclosed to any third parties. This information may consist of the following: your name, contact details, ID number etc. The information you voluntarily supply will be used by Fullstack ZW for regulatory KYC policies and for the purposes of :- responding to your inquiries, supply you with requested information etc. via channels including:

i. Email
ii. Notifications and,
iii. SMS

Your information is considered private and confidential and treated with the strictest confidence. We will not sell or divulge any of your private information to any 3rd parties. If you are not yet a client, but have submitted personal information to Fullstack ZW electronically and would like it removed or modified, please contact us at legal@fullstack.co.zw. We will gladly and expediently comply with your request. Please note that certain confidential client files related to services that have been provided are part of a permanent record that must be kept in accordance with applicable law.Information We Collect Automatically. We collect certain information automatically as you use the Lotapay application, such as general non-personal information used to help improve the Lotapay application. This may include items such as: usage information and device information such as the device you use to access The Lotapay application including the hardware model, operating system and version, IP address, and unique device identifier. In addition, The Lotapay application may access your device’s image storage applications, with your consent, to facilitate your use of certain features of The Lotapay application.Information Collected. We use an analytics tool and may use other third party analytic tools to collect information about use of the Lotapay application, such as how often users visit the Lotapay application. We use the information we get from the analytics tools only to improve the Lotapay application. The analytic tools does not collect your name or other identifying information. We do not combine the information collected through the use of the analytic tools with personally identifiable information. Although analytic tool plants a permanent cookie on your device to identify you as a unique user the next time you use the Lotapay application, the cookie cannot be used by anyone but Fullstack.No Information From Children Under Age 18. If you are under the age of 18, please do not attempt to open a Lotapay account or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 18, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 18, please Contact Us.

3. HOW WE USE AND SHARE YOUR INFORMATION

To Provide Products, Services, and Information. As described above, we collect information from you so that we can communicate with you, and provide and deliver the information and services you have requested. We use your personal information to contact you about your transactions, or to inform you about our other products and services available and new offerings from the Lotapay application. We may provide information to third party service providers that help us process payments, and fulfill and deliver services that you request from us.We may use third parties to help host the Lotapay platform, send out email updates about Fullstack ZW and the Lotapay application, provide marketing and advertising services for us, remove repetitive information from our user lists, and process payments. These service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.Fullstack ZW, from time to time, may contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information is not transferred to the third party. Fullstack ZW may share data with trusted partners to help perform statistical analysis, send you email or mail, provide customer support, or as otherwise @required to deliver the requested services. All such third parties are prohibited from using your personal information except to provide these services to Fullstack, and they are @required to maintain the confidentiality of your information.Except as set forth in this Privacy Policy, we do not share, rent, license, or sell your personal information to third parties.Surveys and Contests. From time-to-time Fullstack ZW may host surveys and contests which may require the submission and collection of personal information. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Personal information requested may include contact information (such as name and shipping address), and demographic information (such as post code, age). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of The Lotapay application and the services you receive from Fullstack ZW.Your Consent. In addition to the sharing described elsewhere in this Policy, we will only share personal information with companies, organizations or individuals outside of Fullstack ZW when we have your consent to do so.Legal Proceedings. We will share personal information with third party companies, organizations or individuals outside of Fullstack ZW if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: (a) meet any applicable law, regulation, subpoena, legal process or governmental request; (b) enforce applicable Terms of Use, including investigation of potential violations; (c) detect, prevent, or otherwise address fraud, security or technical issues; or (d) protect against harm to the rights, property or safety of Fullstack ZW, our users, clients, or the public as @required or permitted by law.

4. ACCESS TO YOUR INFORMATION AND CHOICES

You can access and update certain information we have relating to your Lotapay account by signing into your account and going to the profile section of the Lotapay platform. If you have questions about personal information we have about you or need to update your information, of if you want to opt-out of receiving marketing and promotional e-mails from Fullstack, you can Contact Us. You can also opt-out of receiving future marketing and promotional e-mails from Fullstack ZW by using the opt-out or unsubscribe feature contained in the e-mails.You can close your account by contacting us as set forth below. If you close your account, we will no longer use your online account information or share it with third parties. We may, however, retain a copy of the information to meet regulatory requirements.Fullstack ZW may send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device.

5. SECURITY OF YOUR INFORMATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information.CHANGES TO OUR PRIVACY POLICYOur Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes).

6. QUESTIONS AND HOW TO CONTACT US

You may contact Lotapay regarding the privacy policy, the Terms of Use, or with respect to any other comments or questions at:

Website: www.lotapay.co.zw

Twitter: @Lotapay

Facebook: @Lotapay

Email: hello@lotapay.co.zw