PRIS Zimbabwe Privacy Policy
1. Introduction & Scope
This Privacy Policy (the “Policy”) sets out the principles and procedures adopted by Puma Energy Zimbabwe (“Puma Energy”, “we”, “our”, or “us”) regarding the collection, use, processing, retention, disclosure and protection of personal information when you engage with the Puma PRIS loyalty programme and its related mobile application (the “PRIS App”).
This Policy applies to:
- Individuals registering for, or making use of, the PRIS App or PRIS loyalty programme.
- Individuals transacting through the PRIS App and cards.
- Any person who otherwise communicates with Puma Energy in relation to PRIS programme
This Policy does not extend to suppliers, contractors, job applicants or other third parties outside of the PRIS programme. Those categories are governed by separate Puma Energy privacy instruments.
By using the PRIS App, you acknowledge that you have read and understood this Policy and consent to the processing of your personal information as described herein.
2. Categories of Personal Data Collected
For the purposes of providing, maintaining and improving the PRIS programme, Puma Energy may collect and process the following categories of information:
- Identity and Contact Information: including but not limited to your full name, government-issued identification number, mobile number, postal and/or email address.
- Loyalty Account and Transactional Information: including your PRIS wallet ID, accumulated balance, top-up history, redemptions, station identifiers, location and time of transactions, rewards earned and redeemed, and promotional campaigns opted into.
- Device and Technical Information: including your device type, device unique identifiers and operating system, the version of the PRIS App in use, limited diagnostic or error reporting, IP address, and session logs, location of usage
- Marketing and Communications Preferences: including records of your decision to opt into or out of receiving marketing communications from Puma Energy.
3. Manner of Collection
We collect your personal information through the following lawful means:
- Direct provision by you: including registration data, transaction instructions, and communication initiated by you with Puma Energy.
- Automated collection: including limited device, log and usage information generated when you access or interact with the PRIS App or our support channels
- Authorised partners: where required to process loyalty points, payments or top-ups, Puma Energy may receive information from authorised third parties such as mobile money operators or payment processors.
We expressly confirm that Puma Energy does not procure PRIS user information from credit vetting agencies or unrelated third parties for the purposes of this programme without your consent.
4. Purpose of Processing
Your personal information will only be processed for legitimate, lawful and specific purposes associated with the PRIS programme, which may include:
- Administering, operating and maintaining the PRIS App and loyalty programme.
- Verifying your identity and eligibility to participate in PRIS.
- Recording and executing transactions, rewards and redemptions.
- Preventing, detecting and responding to fraudulent activity, misuse or security incidents.
- Providing customer support and responding to queries or complaints.
- Complying with statutory and regulatory obligations applicable to Puma Energy
Marketing communications (email & SMS). We will send email , whatsapp & SMS marketing communications only with your consent. You may grant or withhold consent separately for each channel in the PRIS App. You may withdraw either consent at any time by unsubscribing.
Geolocation. The PRIS App will access your device location for store-finding, contextual offers, or fraud prevention only if you explicitly enable location services for the App on your device and toggle geolocation consent in the App. You may withdraw this consent at any time via device settings and in-App controls.
5. Compulsory Data & Consequences of Non-Provision
Certain categories of information are compulsory for the establishment and operation of a PRIS account, including but not limited to name, mobile number and national identification details. Failure to provide such information will prevent Puma Energy from providing you with access to the PRIS App or its services. Optional information may be provided at your discretion, and refusal to provide optional information will not restrict your ability to participate in PRIS.
6. Legal Basis for Processing
Puma Energy processes personal information in PRIS on the following lawful bases:
- Consent: where you have given explicit consent, for example to receive marketing.
- Contractual necessity: to perform obligations relating to your participation in PRIS.
- Legal obligation: to comply with Zimbabwean law and regulatory frameworks.
- Legitimate interest: where processing is reasonably required to protect Puma Energy’s rights, prevent fraud or improve services, and such interests are not overridden by your fundamental rights.
7. Data Sharing & Disclosure
Puma Energy may disclose personal information to the following authorised recipients:
- Puma Energy group companies and affiliates, on a need-to-know basis.
- Service providers who support the PRIS App (including IT, hosting, maintenance, payment processors), subject to binding confidentiality and data protection obligations.
- Regulatory authorities, law enforcement bodies or courts of competent jurisdiction, where disclosure is required or permitted by law.
- Third parties involved in a corporate transaction such as a merger, acquisition or sale of assets, in which case safeguards will be applied to ensure continuity of protection.
8. Cross-Border Transfers
Your personal information may be transferred to, and stored in, countries outside Zimbabwe for purposes of IT hosting or group-level administration. Where such transfers occur, Puma Energy will implement adequate safeguards, including contractual commitments, to ensure that your data is protected to a standard consistent with this Policy and applicable law.
9. Security Measures
Puma Energy implements appropriate technical and organisational measures to ensure the integrity and confidentiality of personal information, including encryption in transit, access restrictions, secure storage facilities, and periodic review of security protocols. While we take reasonable precautions, no system is completely secure, and Puma Energy disclaims liability for unauthorised access beyond our reasonable control.
In the event of a data breach likely to result in material risk to your rights or freedoms, Puma Energy will notify you and, where applicable, the relevant supervisory authority within the period required by law.
10. Data Retention & Accuracy
We retain personal information for as long as is necessary to fulfil the purposes described in this Policy, including to meet legal, regulatory, tax, accounting or evidentiary requirements. Thereafter, information is securely deleted or anonymised per internal policies & procedures.
It is your responsibility to ensure that personal information provided to Puma Energy is accurate, complete and up-to-date. Puma Energy shall not be liable for consequences arising from your failure to update such information.
11. Your Rights
Subject to applicable law, you may exercise the following rights:
- Request access to the personal information held about you.
- Request deletion where information is no longer required.
- Withdraw consent previously given (without affecting lawfulness of prior processing).
- Object to certain forms of processing, including direct marketing.
Requests should be directed to the contact us form or prisafricasupport@pumaenergy.freshdesk.com and will be addressed in accordance with statutory timelines. Puma Energy reserves the right to refuse or charge a fee for manifestly unfounded or excessive requests.
12. Cookies & Similar Technologies
The PRIS App may use cookies or similar technologies for core operational purposes (such as maintaining session state) and for limited analytical purposes. You may disable cookies through your device settings, but please note this may impair the functionality of the PRIS App.
13. Children
The PRIS App and loyalty programme are not intended for use by individuals below the legal age of majority in Zimbabwe. Puma Energy does not knowingly collect information from minors without parental or guardian consent. Should such data be inadvertently collected, Puma Energy will promptly delete it on being notified.
14. Amendments to this Policy
Puma Energy may amend this Policy from time to time to reflect changes in law, regulation or operational practices. Material changes will be notified through the PRIS App or other reasonable communication methods. Continued use of the PRIS App following such notice shall constitute acceptance of the amended Policy.
15. Contact & Complaints
For questions, requests or complaints regarding this Policy, please contact:
Data Protection Officer – Puma Energy Zimbabwe
Email: dpo@pumaenergy.com
If you are dissatisfied with Puma Energy’s response, you have the right to escalate the matter to the applicable data protection authority in Zimbabwe.