Introduction

This Privacy Policy explains how Destiny Brothers Private Limited, trading as Snowtrack Private Limited, collects, uses, discloses, and protects personal data when you use Snowtrack services, including the website, mobile apps, seller dashboards, Snowtrack Payments, AI-assisted listing tools, and buyer protection services.

This Policy supplements and should be read together with any other Snowtrack terms and notices posted on the site.

1. Scope and Legal Framework

Scope This Policy applies to personal data Snowtrack collects from users including buyers, sellers, and visitors, and from third parties in connection with the Services. It covers data collected through Snowtrack web properties, mobile apps, APIs, customer support channels, and partner integrations.

Governing Law and Compliance Snowtrack processes personal data in compliance with applicable law, including the Zimbabwe Cyber and Data Protection Act (CDPA) and implementing guidance on cross-border transfers, and with internationally recognized standards where relevant, such as the EU General Data Protection Regulation framework and adequacy mechanisms affecting cross-border flows. Snowtrack implements measures required by these laws when transferring personal data across borders.

2. Categories of Personal Data Collected

Snowtrack may collect the following categories of personal data:

• •Account and Identity Data: name, email, phone number, government ID where required for verification, profile photos, business registration details for sellers.
• •Transaction Data: order history, payment and refund records, shipping addresses, invoices, tax identifiers.
• •Device and Usage Data: IP address, device identifiers, browser and app telemetry, cookies, logs, and analytics.
• •Communications: messages between buyers and sellers, call recordings and transcripts for support or dispute resolution, and customer service interactions.
• •Content and Listings: product descriptions, images, videos, and metadata you upload.
• •Risk and Fraud Data: verification results, device risk signals, chargeback and dispute history, and third-party fraud scores.

3. Purposes of Processing and Legal Bases

Primary Purposes

• •Service Delivery: to create and manage accounts, process orders and payments, arrange shipping, and provide customer support.
• •Security and Fraud Prevention: to detect and prevent fraud, abuse, and other unlawful activity.
• •Platform Operations and Improvements: to operate, maintain, and improve features including AI-assisted listing suggestions, search ranking, and personalization.
• •Dispute Resolution and Buyer Protection: to investigate claims, administer buyer protection programs, and enforce policies.
• •Communications and Notifications: to send transactional messages, account alerts, and legally required notices.
• •Marketing and Promotions: where you consent and as permitted by law, to send promotional offers and personalized advertising.

Legal Bases Snowtrack relies on contractual necessity for order processing, legitimate interests for platform security and service improvement, consent for marketing where required, and legal obligations for compliance and recordkeeping. For users in jurisdictions with specific data-protection regimes, Snowtrack will apply the appropriate legal basis and safeguards.

4. Cross-Border Transfers and International Data Flows

Snowtrack may transfer personal data to service providers, affiliates, and partners located outside Zimbabwe and the user country. Transfers are governed by applicable law and implemented safeguards such as adequacy decisions where available, standard contractual clauses, binding corporate rules, or other lawful transfer mechanisms.

Snowtrack monitors international developments affecting transfers and updates safeguards accordingly. Guidance and regulatory frameworks for cross-border transfers under the CDPA and international instruments inform Snowtrack approach.

5. Sharing and Disclosure

Snowtrack shares personal data only as necessary and under contract with:

• •Payment processors and financial institutions to complete transactions and manage payouts.
• •Logistics and delivery partners to fulfill orders.
• •Fraud prevention and analytics vendors to detect abuse and improve safety.
• •Legal and regulatory authorities when required by law or to protect rights and safety.
• •Affiliates and service providers performing services on Snowtrack behalf under written agreements requiring confidentiality and security.

Snowtrack may also disclose aggregated or de-identified data that does not reasonably identify individuals.

6. Cookies and Tracking Technologies

Snowtrack uses cookies, local storage, pixels, and similar technologies for essential site functionality, analytics, personalization, and advertising.

Users can manage cookie preferences through the cookie banner and account settings. Essential cookies required for core functionality cannot be disabled without affecting the Services.

7. AI Features and Automated Decision Making

Snowtrack provides AI-assisted tools such as listing title suggestions, category recommendations, and relevance scoring. These tools are advisory and users remain responsible for the content they publish.

Where automated decisions materially affect users, such as automated listing removals, account restrictions, or eligibility for certain programs, Snowtrack will provide notice and, where required by law, meaningful information about the logic involved and how to request human review.

Snowtrack applies technical and organizational safeguards to reduce bias and to monitor AI outputs.

8. Data Retention

Snowtrack retains personal data only as long as necessary for the purposes described in this Policy, to comply with legal obligations, to resolve disputes, and to enforce agreements.

Retention periods vary by data category and legal requirement. Snowtrack publishes retention schedules where required by law.

9. Security Measures

Snowtrack implements reasonable technical, administrative, and organizational measures to protect personal data against unauthorized access, disclosure, alteration, and destruction.

Measures may include encryption in transit and at rest where appropriate, access controls, monitoring, incident response procedures, and regular security assessments.

No system is completely secure. Snowtrack will notify affected users and authorities as required by law in the event of a qualifying data breach.

10. Data Subject Rights and How to Exercise Them

Depending on your jurisdiction, you may have rights including access, correction, deletion, restriction of processing, objection, portability, and the right to withdraw consent.

To exercise rights, contact Snowtrack using the contact details published on the site or use in-app or account tools where provided.

Snowtrack will verify requests and respond within applicable statutory timeframes. Where legal exceptions apply or cross-border requests require additional handling, Snowtrack will explain any limitations.

11. Children’s Data

Snowtrack Services are not intended for children below the applicable minimum age.

Snowtrack does not knowingly collect personal data from children. If Snowtrack becomes aware that it has collected such data, it will take steps to delete it in accordance with applicable law.

12. Third-Party Services and Links

Snowtrack may integrate with third-party services such as social logins, analytics, and advertising networks. Those third parties have their own privacy practices and Snowtrack is not responsible for their policies or practices.

Snowtrack requires third parties to process data under contract and to maintain appropriate safeguards where applicable.

13. Changes to This Policy

Snowtrack may update this Policy to reflect changes in the Services, legal requirements, or industry practices.

Material changes will be posted with an effective date and, where required by law, users will be notified in advance.

14. Contact Information and Supervisory Authority

For privacy inquiries, to exercise data rights, or to lodge complaints, contact Snowtrack using the contact details published on the site.

Users in Zimbabwe may also contact the national data protection authority or other supervisory bodies as provided under the CDPA.

Snowtrack cooperates with supervisory authorities and will comply with lawful inquiries.