Privacy Policy

Intercept Investments (Private) Limited, trading as Lux Liquor (“Lux Liquor”, “we”, “us”, or “our”), operates the Lux Liquor mobile application, website, and delivery marketplace service in Zimbabwe. We are committed to safeguarding the privacy and personal data of our customers, delivery partners, and merchant retailers.

This Privacy Policy explains how we collect, process, share, retain, and protect your personal information when you access or use our mobile applications, website, and related delivery services. It also informs you of your privacy rights under applicable laws, including the Cyber and Data Protection Act [Chapter 12:07] of Zimbabwe.

1. Information We Collect

We collect information that you provide directly to us, information collected automatically through app usage, and information from third-party partners:

A. Information You Provide Directly

• Account Registration: Full name, mobile telephone number, email address, password, and date of birth.
• Delivery Details: Physical delivery address, residential complex/flat numbers, landmark instructions, and recipient contact name/number.
• Age Verification Records: Date of birth and, when required, confirmation of government-issued photo identification (National ID card, Driver's Licence, or Passport) shown at point of delivery to confirm legal age (18+).
• Communications: Messages sent via customer support, in-app driver chat, order feedback, ratings, and dispute submissions.

B. Information Collected Automatically

• Precise Location Data: With your permission, we collect precise GPS coordinates from your mobile device while the app is running in the foreground or background to enable address auto-detection, order dispatch, nearby store discovery, and real-time courier tracking.
• Device & Usage Information: Device model, operating system version, unique device identifiers (e.g., IMEI or advertising ID), network carrier, IP address, app crashes, and session timestamps.
• Order & Transaction History: Records of items purchased, merchant bottle store details, order values, delivery times, and payment confirmations.

C. Payment Information

Payments are processed securely through licensed third-party payment gateways (including EcoCash, InnBucks, local Zimbabwean banking switches, and international card processors). Lux Liquor does not store your full payment card numbers, PINs, or banking passwords on our servers. We receive only transaction tokens, payment status, and transaction reference numbers.

2. How We Use Your Information

We use your personal data for the following lawful purposes:

• Order Fulfilment: Transmitting your order items to partner liquor retailers and dispatching independent delivery couriers to deliver products to your specified location.
• Age Compliance: Verifying that customers meet the statutory age threshold of 18 years under the Liquor Act [Chapter 14:12].
• Real-time Tracking & Logistics: Allowing you and the assigned delivery driver to track the delivery route and coordinate drop-off.
• Customer Care: Resolving customer complaints, handling refunds, missing item claims, or order disputes.
• Platform Security & Fraud Prevention: Detecting fraudulent transactions, unauthorized account access, fake accounts, or abuse of promotion codes.
• Legal & Tax Obligations: Maintaining statutory accounting, VAT, and fiscal records as required by the Zimbabwe Revenue Authority (ZIMRA) and other regulatory authorities.

3. How We Share Your Information

We do not sell your personal data. We disclose your information only under the following circumstances:

• With Delivery Drivers: We share your first name, delivery address, phone number (or masked phone number), and delivery instructions with the assigned courier partner strictly to complete your delivery.
• With Merchant Retailers: We share order contents and order reference numbers with licensed bottle stores so they can pick and pack your order.
• With Service Providers: Third-party technology vendors providing cloud hosting, map/routing APIs (e.g., Google Maps), SMS verification delivery, and payment gateway infrastructure.
• With Regulatory & Law Enforcement Bodies: Where required by law, subpoena, or court order under the laws of Zimbabwe, including requests by the Zimbabwe Republic Police (ZRP) or POTRAZ.

4. Data Retention

We retain your personal information for as long as your account remains active or as needed to provide our services. If you delete your account:

• Your profile data, authentication credentials, and saved addresses are purged or irreversibly anonymized within 30 days of confirmed deletion.
• Certain historical transaction records, tax invoices, and payment receipts are retained for up to six (6) years strictly to comply with Zimbabwean statutory tax (ZIMRA), audit, and commercial legal obligations.

5. Data Security

We implement industry-standard technical and organizational security controls to protect your data, including:

• Encryption of data in transit using Transport Layer Security (TLS/HTTPS).
• Hashed passwords using strong cryptographic functions.
• Role-based access controls limiting customer data access exclusively to authorized operational personnel.

6. Your Rights & Choices

Under the Cyber and Data Protection Act [Chapter 12:07], you have rights regarding your personal information:

• Access & Rectification: You can view and update your account details directly within the mobile app settings.
• Location Permissions: You can enable or disable GPS location permissions at any time via your device operating system settings (disabling location may require manual address entry).
• Marketing Opt-Out: You may unsubscribe from promotional push notifications or marketing emails at any time.
• Account & Data Deletion: You have the right to request the complete deletion of your account and associated personal data. Visit our Account Deletion Page for complete instructions and our online deletion request form.

7. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our operational practices or legal requirements. Material updates will be communicated through the Lux Liquor app or by updating the “Last Updated” date at the top of this document.

8. Contact Our Data Protection Officer

For any privacy-related queries, data access requests, or regulatory questions, please contact our team:

• Email: privacy@luxliquor.co.zw
• Mailing Address: Intercept Investments (Private) Limited t/a Lux Liquor, Data Protection Office, Harare, Zimbabwe