CARPE VINUM COMPANY LIMITED
PRIVACY POLICY

1. Introduction

CARPE VINUM COMPANY LIMITED (“the Company”, “we”, “us” or “our”) respects the privacy and protection of personal data belonging to our employees, customers, suppliers, distributors, visitors, business partners and other individuals whose personal information we process.

This Privacy Policy explains how CARPE VINUM COMPANY LIMITED collects, uses, stores, protects and, where necessary, shares personal data in the course of its business activities. We are committed to handling personal data responsibly and in accordance with applicable data protection laws and regulations in Tanzania.

2. Personal Data We Collect

Depending on the nature of our relationship with an individual, we may collect and process the following categories of personal data:

• Full name and other identification details.
• National identification or other identification information where legally or operationally necessary.
• Telephone/mobile number.
• Email address.
• Residential or business address.
• Employment and human-resource information.
• Payroll and payment information.
• Bank or other financial information where required for legitimate business transactions.
• Customer, supplier and distributor information.
• Business contact information.
• Visitor information and records.
• CCTV images and recordings within areas covered by our surveillance systems.
• Website and online interaction information.
• Marketing preferences and communication records.
• Information contained in correspondence, applications, forms, contracts and other business documents.

We will only collect personal data that is relevant and reasonably necessary for specified purposes.

3. How We Collect Personal Data

We may collect personal data through:

• Employment applications and employee records.
• Customer registration, orders and sales transactions.
• Supplier and distributor registration.
• Contracts and business correspondence.
• Telephone calls, email, WhatsApp and other business communications.
• Website and online forms.
• Visitor registration at our premises.
• CCTV systems.
• Marketing and promotional activities.
• Other lawful business interactions.

4. Purposes for Processing Personal Data

We may process personal data for the following purposes:

• Managing employees and employment relationships.
• Processing salaries, benefits and other employment-related matters.
• Providing products and services to customers.
• Processing customer orders and maintaining business records.
• Managing suppliers, distributors and business partners.
• Processing invoices, payments and financial transactions.
• Maintaining security at our premises.
• Operating CCTV systems for safety and security.
• Communicating with customers, employees, suppliers and other stakeholders.
• Conducting lawful marketing and promotional activities where applicable.
• Managing our website and digital platforms.
• Complying with legal, regulatory, tax, accounting and other obligations.
• Preventing fraud, theft, misuse and other unlawful activities.
• Protecting the Company's rights, property, employees and visitors.
• Handling complaints, disputes and legal matters.
• Other legitimate and lawful business purposes.

5. Legal Basis for Processing

CARPE VINUM COMPANY LIMITED will process personal data only where there is a lawful basis for doing so, including where:

• The individual has provided consent where consent is required.
• Processing is necessary for the performance of a contract.
• Processing is necessary to comply with a legal or regulatory obligation.
• Processing is necessary to protect legitimate business interests, rights or property, where permitted by law.
• Processing is otherwise permitted or required under applicable law.

6. Marketing and Communications

We may use personal data to communicate information about our products, services, promotions or other business activities where permitted by law. Individuals may request to stop receiving marketing communications by contacting us at any time.

7. CCTV and Video Surveillance

CARPE VINUM COMPANY LIMITED may operate CCTV cameras at selected areas of its premises for legitimate security and safety purposes to protect employees, visitors, and company property.

8. Sharing and Disclosure of Personal Data

We may disclose or share personal data where necessary and lawful with government authorities, regulatory bodies, financial institutions, legal advisers, and authorized service providers.

9. International Transfers

Where personal data is transferred outside Tanzania, the Company will take appropriate steps to ensure the data receives an adequate level of protection.

10. Data Security

We take reasonable technical and organizational measures (including access controls, passwords, secure storage, and confidentiality obligations) to protect personal data against unauthorized access, loss, or misuse.

11. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected or to comply with legal requirements.

12. Rights of Data Subjects

Under applicable law, individuals have rights regarding their personal data, including the right to access, correct, delete, or object to the processing of their personal data.

13. Employees

Employee personal data is processed for legitimate employment and administrative purposes including payroll, recruitment, performance, and statutory reporting.

14. Customers, Suppliers and Distributors

Data related to commercial partners is processed for account management, orders, deliveries, invoicing, and contract compliance.

15. Website and Social Media

Information collected via online forms or digital platforms will be handled securely and responsibly in accordance with this policy.

16. Data Breaches and Incidents

In the event of a personal data breach, the Company will assess, respond, and notify relevant authorities and affected individuals as required by law.

17. Changes to This Privacy Policy

We may update this Privacy Policy periodically. The updated version will be posted on our website and official company channels.

18. Contact Us

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