Adopted pursuant to the Personal Data Protection Act, 2022 (United Republic of Tanzania) and applicable laws.

1. PREAMBLE

This Privacy Policy is issued by Evermark Company Limited (hereinafter referred to as “Evermark”, “the Company”, “we”, “our” or “us”), an online land and property listing platform operating within the United Republic of Tanzania.

This Policy sets out the principles and procedures governing the collection, processing, storage, disclosure, and protection of personal data of customers in compliance with the Personal Data Protection Act, 2022 and other applicable laws and regulations.

2. INTERPRETATION AND DEFINITIONS

For purposes of this Policy:

1. “Personal Data” means any information relating to an identified or identifiable natural person.
2. “Data Subject” means a natural person whose personal data is processed.
3. “Processing” includes collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, transmission, or destruction of personal data.
4. “Customer” means any individual accessing the Evermark platform for purposes of inquiry, registration, or land transaction.
5. “Third Party” means any natural or legal person other than the data subject, controller, processor, or authorized persons.

3. PRINCIPLES OF DATA PROCESSING

Evermark shall ensure that personal data is processed lawfully, fairly, and transparently. Processing shall be limited to specific, explicit, and legitimate purposes. Data collected shall be adequate, relevant, and not excessive. Appropriate security measures shall be implemented to prevent unauthorized access, alteration, disclosure, or destruction.

4. CATEGORIES OF PERSONAL DATA COLLECTED

Evermark may collect and process the following categories of personal data:

1. Identity Data: Full name, National Identification Number (NIDA), date of birth.
2. Contact Data: Telephone number, email address, physical address.
3. Transaction Data: Property preferences, purchase history, payment confirmations.
4. Technical Data: IP address, browser type, device identifiers, usage analytics.
5. Communication Data: Records of correspondence, inquiries, and customer service interactions.

5. LAWFUL BASIS FOR PROCESSING

Personal data shall be processed on lawful grounds including:

1. Consent of the data subject.
2. Necessity for performance of a contract.
3. Compliance with legal obligations.
4. Protection of legitimate interests of the Company.
5. Protection of vital interests of the data subject.

6. PURPOSES OF PROCESSING

Personal data shall be processed strictly for:

1. Facilitating land inquiries and transactions.
2. Verifying identity for fraud prevention and compliance.
3. Enabling communication between customers and brokers.
4. Processing payments and complying with regulatory requirements.
5. Improving the functionality and security of the platform.

7. DATA SHARING AND DISCLOSURE

Personal data may be disclosed to verified brokers, financial institutions, payment processors, professional advisors, regulatory authorities, and contracted IT service providers, strictly on a need-to-know basis subject to confidentiality obligations. Evermark shall not sell personal data.

8. DATA SECURITY MEASURES

Evermark shall implement appropriate technical and organizational measures including:

1. Encrypted data transmission.
2. Secure servers and restricted access controls.
3. Periodic security assessments.
4. Staff confidentiality obligations.

9. DATA RETENTION

Personal data shall be retained only for as long as necessary to fulfill the purposes for which it was collected or as required by law. Upon expiration, data shall be securely deleted, destroyed, or anonymized.

10. RIGHTS OF DATA SUBJECTS

Subject to applicable law, data subjects have the right to:

1. Access their personal data.
2. Request correction of inaccurate data.
3. Request erasure where legally permissible.
4. Object to certain processing activities.
5. Withdraw consent where processing is based on consent.

11. CROSS-BORDER TRANSFERS

Where personal data is transferred outside the United Republic of Tanzania, Evermark shall ensure that adequate safeguards are implemented in accordance with applicable data protection laws.

12. CHILDREN’S DATA

The Evermark platform is not intended for persons under the age of eighteen (18) years. The Company does not knowingly collect personal data from minors.

13. POLICY REVIEW AND AMENDMENTS

This Policy may be reviewed and amended periodically. Updated versions shall be published on the Company’s website.