Privacy & Policy

Shifting Frames Incorporated Private Limited ("we," "our," "us," or "Shifting Frames") is committed to protecting your privacy and ensuring the security of your personal information in full compliance with global data protection regulations. As a licensed Data Controller, we operate under a robust framework governed by our appointed Data Protection Officers and internal policies that adhere to the data protection laws of Zimbabwe, Africa, Asia, Europe, and the Americas.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services, including the Shifting Frames Logistics and Courier services, the SwiftFrame Marketplace, and any related platforms.

By accessing or using our services, you consent to the practices described in this policy.

1. Information We Collect

A. Personal Information You Provide Directly:

  • Contact & Identity Details: Name, email address, phone number, physical/delivery address, National ID, passport details.

  • Financial Information: Billing address and payment method details. (Sensitive payment data is processed by secure, compliant third-party processors).

  • Account Information: Username, password, and preferences.

  • Commercial & Content Data: Shipment details, item descriptions, customer communications, and feedback.

B. Information Collected Automatically:

  • Technical & Usage Data: IP address, browser/device type, operating system, and interaction data with our platforms.

  • Location Data: GPS and IP-based location data for tracking, route optimization, and delivery verification.

  • Tracking & Log Data: Unique tracking numbers, shipment status, and system access logs.

C. Information from Third Parties:
We may receive information from business partners, advertising networks, and analytics providers, subject to their own legal compliance.

2. Legal Basis for Processing (For GDPR and Similar Laws)

We process your personal data on one or more of the following legal bases:

  • Performance of a Contract: To fulfill our shipping, freight, and e-commerce agreements with you.

  • Legitimate Interests: For operational management, security, fraud prevention, and service improvement.

  • Legal Obligation: To comply with customs, tax, freight, and other regulatory requirements across different jurisdictions.

  • Consent: Where required by law, we will obtain your explicit consent for specific processing activities (e.g., certain marketing communications). You may withdraw consent at any time.

3. How We Use Your Information

In line with our mission, we use your information to:

  • Provide, manage, and optimize our logistics and e-commerce services.

  • Process transactions and send tracking/service notifications.

  • Personalize your experience and improve our platforms.

  • Prevent fraud and ensure the security of our operations.

  • Communicate promotional offers, subject to your preferences and consent where required.

  • Comply with legal and regulatory obligations across all regions we operate in.

4. International Data Transfers & Safeguards

As a global logistics provider, your personal information may be transferred to and processed in countries outside of your home country, including Zimbabwe, South Africa, Zambia, the United States, Asia, and the European Union.

We ensure all such international transfers are performed in compliance with the requisite data protection laws. Our safeguards include:

  • Processing data only in countries deemed "adequate" by the European Commission.

  • Implementing Standard Contractual Clauses (SCCs) approved by the European Commission for transfers from the EEA.

  • Relying on other legally recognized mechanisms, such as a company's Binding Corporate Rules (BCRs) or your explicit consent, where necessary and appropriate.

5. How We Share Your Information

We share your data with strict Integrity and only where necessary:

  • Service Providers: Carefully vetted partners (e.g., for payment processing, cloud storage, customer support) bound by strict data protection contracts.

  • Logistics Partners: Delivery agents, partner couriers, and customs authorities to complete your shipment.

  • Legal and Regulatory Bodies: When required by the laws of Zimbabwe, Europe, America, or other relevant jurisdictions.

  • Business Transfers: In connection with a merger, acquisition, or sale of assets, with notice to you.

6. Data Subject Rights (Your Rights)

In accordance with applicable law (such as GDPR, Zimbabwe's Data Protection Act, CCPA/CPRA, etc.), you have the right to:

  • Access and receive a copy of your personal data.

  • Rectify inaccurate or incomplete data.

  • Erasure ("Right to be Forgotten") under certain conditions.

  • Restrict or Object to our processing of your data.

  • Data Portability.

  • Withdraw Consent at any time, without affecting the lawfulness of prior processing.

  • Lodge a Complaint with a supervisory authority in your jurisdiction.

To exercise any of these rights, please contact our Data Protection Officer using the details below.

7. Data Security

Our commitment to Safety is upheld through industry-standard technical and organizational measures, including encryption, access controls, secure server infrastructure, and regular security assessments, designed to protect your data from unauthorized access, loss, or destruction.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, including to meet legal, accounting, freight, or reporting requirements. Retention periods are defined in our internal data retention policy, which is aligned with global legal standards.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance platform functionality and analyze usage. You can control cookie preferences through your browser settings.

10. Changes to This Privacy Policy

We may update this policy to reflect legal or operational changes. We will notify you of significant changes by posting the new policy on our platform and updating the "Last Updated" date.

11. Contact Us & Our Data Protection Officers

For any questions, concerns, or to exercise your data subject rights, please contact our dedicated Data Protection Officer team. We are committed to resolving any issues promptly and in accordance with global data protection laws.

📧 Email: dpo@shiftingframes.co.zw (Recommended for privacy-specific inquiries)
📞 Phone: +263 771769108