CareConnect Training Hub

1. Introduction

CareConnect (“we”, “us”, “our”) is a free, community-based caregiver training initiative operating from Zimbabwe. This Privacy Policy explains how we collect, use, store, and protect personal information in accordance with the Cyber and Data Protection Act [Chapter 11:12] of 2021 (the “Act”) and subsidiary regulations administered by the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ).

2. Data Controller

The data controller is CareConnect, operated by R. Jamison. For data-related enquiries, contact us at [email protected].

3. What Data We Collect

We collect only the minimum data necessary to deliver our training service:

Account registration: Name, email address, and a hashed password (we never store passwords in plain text).
Training progress: Module completion status, quiz scores, and certificate records.
Contact & error reports: Subject, message, and optionally your name and email (only if you choose to provide them).
Module feedback: Your usefulness rating and optional improvement suggestions, linked to an anonymous browser session identifier.
Technical data: Basic server logs (IP address, browser type, timestamps) necessary for security and site reliability.

4. Lawful Basis for Processing

Under Section 14 of the Act, we process your data on the following lawful bases:

Consent: You voluntarily create an account and provide contact details.
Legitimate interest: Delivering training content, improving our materials, and ensuring site security.
Legal obligation: Retaining records where required by applicable law.

5. How We Use Your Data

To authenticate and manage your training account.
To track module progress and issue completion certificates.
To respond to contact form messages (only if you provide your email).
To improve training content based on aggregated, anonymised feedback.
To maintain site security and prevent misuse.

We do not use your data for marketing, advertising, profiling, or any commercial purpose.

6. Data Sharing

We do not sell, trade, or share your personal data with third parties, except:

With infrastructure service providers (hosting, email delivery) who process data solely on our behalf under contractual safeguards.
Where required by law or a valid order of a court or regulatory authority in Zimbabwe.

7. Cross-Border Transfers

Our hosting infrastructure may be located outside Zimbabwe. In accordance with Section 29 of the Act, any cross-border transfer of personal data is made only to jurisdictions that ensure an adequate level of data protection, or under contractual arrangements that provide equivalent safeguards.

8. Data Retention

We retain your account data for as long as your account is active. Anonymous feedback and contact messages are retained indefinitely in aggregate form. If you request account deletion, we will remove your personal data within 30 days, except where retention is required by law.

9. Your Rights

Under the Cyber and Data Protection Act, you have the right to:

Access: Request a copy of the personal data we hold about you.
Rectification: Request correction of inaccurate data.
Deletion: Request deletion of your data (subject to legal retention requirements).
Object: Object to any processing that is not based on consent or legal obligation.
Complaint: Lodge a complaint with POTRAZ if you believe your data rights have been violated.

To exercise any of these rights, contact [email protected].

10. Security Measures

We implement appropriate technical and organisational measures to protect your data, including encrypted connections (HTTPS), hashed passwords, and access controls. In the event of a data breach, we will notify POTRAZ within 24 hours and affected data subjects within 72 hours, as required by the Act.

11. Children's Privacy

This service is intended for adult caregivers. We do not knowingly collect personal information from children under the age of 18. If we become aware that a child has provided personal data, we will take steps to delete it promptly.

12. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated via this page. The “Last updated” date at the top indicates the most recent revision.

13. Contact

For any questions or concerns about this Privacy Policy or our data practices, please contact:
R. Jamison [email protected]