Privacy Policy

Our Responsibilities

This Privacy Policy for SART Advisory Private Limited (‘SART Advisory, ‘we’, ‘us’, or ‘our’,) describes how and why we collect, store, use, and/or share, (‘process’) your personal data and information when you use our services (‘Services’) such as when you:

• Visit our website at https://sartadvisory.tech
• Express an interest in or take up one of our Services.
• Engage with us in other related ways, including any sales, marketing, or events.

SART Advisory are responsible for the data we collect and process for our own purposes. We’re committed to maintaining the security and privacy of the personal data we process, both through our website or through our interactions with clients, prospects, or industry partners.

Whether we are supporting our clients or managing our own data, privacy and security are at the heart of our operations. Whilst we take appropriate measures in our own practices, security and privacy is at the core of our business operations, so it is imperative we operate in accordance and where possible above industry and regulatory requirements.

Contacting us

Should you wish to contact us to find out more about how we process personal data and information, to exercise your rights, make a complaint or to discuss our practices, please use the following details:

• Email: dpo@sartadvisory.tech

What personal data will we collect about you?

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data and personal information which have been grouped together below:

Category	Personal Data Items
Identity data	Includes first name, last name, alias, unique personal identifier (such as an ID number or password), online identifiers (such as an IP address) and account name (the name provided as the account holder).
Contact data	Includes postal address, email address and telephone or mobile number.
Internet or other similar network activity	Online behaviour and interactions with our and other websites, applications, systems, and advertisements. Some of this information will be collected through cookies and similar technologies.
Professional or employment-related information	Business contact details to provide you our Services at a business level or job title.

How will we collect your personal data?

We use different methods to collect data from and about you including:

• Personal data and information provided by you: The personal data and information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products you use. We will typically collect personal data directly from you via our website or in-person, such as during an industry event. 
• Third parties or publicly available sources: To enhance our ability to provide relevant marketing, offers, and Services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, data providers, and from other third parties. Third party sources include LinkedIn.   
• Information automatically collected: We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

How do we use your personal data?

• The following table sets out why we process your personal data and information, including our lawful basis for processing your personal data, in accordance with Zimbabwe Legislation. We may rely on more than one lawful basis for processing your personal data depending on the context of the processing activity.

Purpose/activity	Lawful basis for processing	Personal Data Categories
To provide our Services. Although our core Services do not revolve around collecting and processing personal data, we may process small amounts of personal data in order to fulfil our contractual obligations. This includes management of contracts, using job titles in reports and sending email communications to our clients.	This processing is carried out in our legitimate business interests of providing you with our services.   This processing may be necessary for the performance of a contract, or to take steps prior to entering into a contract which SART Advisory and our clients are subject to.	Name Email addresses Address Contact number Signatures Business contact details
To handle website enquiries. We have a Contact Us page on this website, which allows individuals to ask questions about our Services, The Contact Us page and any correspondence sent via email is monitored by our internal teams, to ensure we identify and handle your request effectively.	This processing is carried out for our legitimate interests, enabling SART Advisory to facilitate to your enquiry.	Name Email addresses Telephone number
To engage with prospective clients. We process basic business contact information of prospective clients and opportunities, which may initially be collected via sales meetings, business cards, verbally, events we may host, speak at, or attend. We may obtain information from third parties or publicly available sources, including those outlined under the section ‘How will we collect your personal data?’	This processing is carried out for our legitimate interests of promoting our Services to your organisation.   This information may also be processed for the performance of a contract or to take steps prior to entering a contract, when you are a named signatory within the contract.	Name Email addresses Address Contact number Business contact details Email conversations Physical and Electronic Signatures
To manage Financial Accounting and Administration. Our financial management and accounting Services process basic client contact information to fulfil our accounting requirements. This ranges from invoices, account details, timesheet approvals, statement of works, terms and conditions and bank details	This processing is necessary for the performance of a contract with you, in our legitimate interests with your organisation, or to meet our legal obligations for financial reporting.	Name Email addresses Address Contact number Business contact details Email conversations Signatures Client and Supplier Bank Details
To collect information on Associates / Contractors. We process basic contact and work information in relation to associates and contractors who would like to work with us or one of our clients. This information could be collected through our website, email, LinkedIn, recruitment agencies or job advertising boards.	This processing is necessary for the performance of a contract with you, or to take steps prior to entering a contract when you are a named signatory within the contract.	Name Email addresses Address Telephone details Skills Job history Bank account details Passport Driving licence References and email conversation
To recruit employees. We process your information in our recruitment processes and when you apply for a role with us. This information could be collected through our website, email, LinkedIn, recruitment agencies or job advertising boards.	This processing is necessary for the performance of a contract of employment with you, or to take steps prior to entering such a contract with you.	Name Email addresses Address Telephone details Skills Job history Bank account details Passport Driving licence References and email conversation
To send you marketing and promotional communications. From time to time, we may email you about our Services or events (including webinars and in-person) which may be of interest to you or your organisation. We will only ever contact you with these communications if we consider you to be a ‘Corporate subscriber’ and the content is relevant to your role as an employee at the organisation you work for.	This processing is carried out for our legitimate interests, for us to promote our Services or events to your organisation. You can tell us not to contact you by following the unsubscribe instructions on any communications sent to you. We will only send communications to individuals within organisations where we believe we have a legitimate interest to do so.    If you do not wish to receive any form of communication from SART Advisory then simply inform us through our contact page, email dpo@sartadvisory.tech or you can unsubscribe using the ‘unsubscribe’ link available at the bottom of any of our communications.	Full name Job title Email address Phone number
To identify usage trends and understand our customer journeys. We will process information about how you use our Services.	This processing is carried out for our legitimate interests to analyse and improve your user experience and the performance of our website.	IP Address Social Media IDs Unique Visitor IDs Telephone Number
Teams meeting recordings.	This processing is carried out in our legitimate interests of accurately capturing a Teams call/meeting.	Full name Image

Where we process your personal data based on our legitimate interests, we have carried out a balancing exercise to make sure our legitimate interest does not override your privacy rights as an individual. We document the balancing exercises we carry out when relying upon this lawful basis for processing your personal data.

Sharing your personal data

As you’d expect, our employees will access personal information for the purposes mentioned above. For example, our Business Development staff may need access to your details to support you when you get in contact with us.  

We will also share information with third parties including service providers, business partners and sub-contractors for business administration, support, processing, Services, or IT purposes. 

Where appropriate, we may also share your personal data with our third-party partners, for the purpose of promoting or delivering our services and events. Our third-party partners include: 

• Microsoft 

Please note that any third parties will only process your personal data for specified purposes and where they have contractually agreed to treat the information confidentially and to keep it secure.

Security of your personal data

At SART Advisory we take the security of personal data extremely seriously

We assess security for Confidentiality, Integrity, and Availability to ensure that data remains protected, accurate and available for its intended purposes. Some of the core controls we have implemented are:

• Multi-Factor Authentication (MFA) on all internet-based systems
• Encryption of data at rest and in transit
• Technical assessments of our systems for vulnerabilities and configuration weaknesses
• Controlled access to only approved individuals
• Screening of all employees .
• Data handling training for all employees
• Policies and procedures on secure operations and configuration of systems

How long will we keep your personal data?

SART Advisory only processes personal data for as long as necessary to meet our legal obligations or where we have a legitimate business reason for keeping it. We review personal data on a case-by-case basis and document the period of retention for each.

For further information on how long personal data is likely to be kept before being removed from our systems and databases, please contact us via:dpo@sartadvisory.tech

Your rights

Data Protection Legislation gives you several Rights over your information which are focused on placing you in control of how your data are processed.

You can exercise these Rights by emailing us at dpo@sartadvisory.tech 

We may verify your request and identity before any information is provided to you. This is to make sure you are entitled to receive the information.  

You have the following Rights in relation to the processing of your personal data:

Data Subject Right	Description
Right to be informed	A right to be informed about the personal data we hold about you.
Right of access	A right to access the personal data we hold about you.
Right to rectification	A right to require us to rectify any inaccurate personal data we hold about you.
Right to erasure	A right to ask us to delete the personal data we hold about you. This right will only apply where (for example):   – We no longer need to use the personal data to achieve the purpose we collected it for. – Where you withdraw your consent if we are using your personal data based on your consent. – Where you object to the way we process your data (see the right to object described below). If you request us to delete your data, we will retain minimum personal data to document these requests and thereby avoid using your personal data for any other purpose.
Right to restrict processing	In certain circumstances, a right to restrict our processing of the personal data we hold about you. This right will only apply where (for example): – You dispute the accuracy of the personal data held by us. – Where you would have the right to ask us to delete the personal data but would prefer that our processing is restricted instead. – Where we no longer need to use the personal data to achieve the purpose, we collected it for, but you need the data for the purposes of establishing, exercising, or defending legal claims.
Right to data portability	In certain circumstances, a right to receive the personal data you have given us, in a structured, commonly used, and machine-readable format. You also have the right to require us to transfer this personal data to another organisation, at your request.
Right to object	A right to object to our processing of the personal data we hold about you where our lawful basis is for the purpose of our legitimate interests, unless we can demonstrate, on balance, legitimate grounds for continuing to process the personal data which override your rights, or which are for the establishment, exercise or defence of legal claims. In particular, you can exercise your right to object to marketing communications being sent to you by utilising opt-out mechanisms in emails we send to you.
Right related to automated decision-making and profiling	A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to withdraw your consent	A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with brochures and newsletters).

Your right to complain to the Supervisory Authority

If you’re unhappy with how we’re using your personal data, you can contact us at dpo@sartadvisory.tech and we will work with you to resolve the matter.