Privacy Policy

Gleinna Group is a freight forwarding company incorporated in the Republic of Zimbabwe. Our head office is located in Harare, and we operate satellite offices and authorised agents in other countries within the SADC region.

For any privacy-related enquiries, you may contact us at:

We may collect and process the following categories of personal information:

2.1 Information you provide directly

• Name, job title, and company name
• Email address and telephone numbers
• Postal or business address
• Cargo details, shipment instructions, and trade documentation
• Identification documents required for customs clearance (e.g. passport, national ID, business registration)
• Payment and billing information
• Communications and correspondence with our team

2.2 Information collected automatically

• IP address and browser type when visiting our website
• Pages visited and time spent on our website
• Device information and operating system
• Referring website or search terms used to find us

2.3 Information from third parties

• Business contact details from partner organisations or referrals
• Regulatory or customs information required by law for freight clearance

2.4 Sensitive information

Gleinna Group does not routinely collect sensitive information such as information revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, health, genetic or biometric data, or criminal history. Where processing of sensitive information becomes necessary — for example, copies of identity documents for customs clearance, or health declarations required for certain categories of cargo — we will obtain your consent, unless an exemption under applicable law applies.

We use your personal information for the following specified, explicit, and legitimate purposes:

• Service delivery — to arrange, manage, and track freight forwarding, customs clearance, and logistics services on your behalf
• Communication — to respond to enquiries, provide quotes, send shipment updates, and maintain client relationships
• Billing and payments — to process invoices, manage accounts, and comply with financial obligations
• Legal and regulatory compliance — to meet customs, import/export, tax, and international trade regulatory requirements in Zimbabwe and other jurisdictions
• Service improvement — to analyse how our services and website are used and to improve our offerings
• Marketing — with your consent, to send relevant service updates, industry news, or promotional information (you may withdraw consent at any time)

We will not further process your personal information for any purpose incompatible with those listed above without your prior consent.

We do not sell, rent, or trade your personal information. We may share it with the following categories of recipients, only to the extent necessary for the purposes set out in Section 3:

• Shipping lines, airlines, and transport providers — to arrange and execute shipments
• Customs authorities and government bodies — as required by law for import/export clearance in Zimbabwe and any transit or destination country
• Port and warehouse operators — for cargo handling, storage, and distribution
• Gleinna Group satellite offices and authorised agents — operating in SADC and other jurisdictions, under equivalent confidentiality and data-protection obligations
• Professional advisers — including lawyers, auditors, and insurers, where necessary
• Technology and service providers — such as email, cloud storage, and accounting platforms, bound by written contracts that include appropriate security and confidentiality obligations

By the nature of freight forwarding, delivering our services requires personal information to be transferred across borders — including to origin, transit, and destination countries, as well as to our satellite offices and agents. Transfers may occur to countries within and outside the SADC region.

Accordingly, where we transfer personal information outside Zimbabwe, we rely on one or more of the following:

• the transfer is necessary for the performance of a contract between you and Gleinna Group, or for pre-contractual steps taken at your request;
• the transfer is necessary for the conclusion or performance of a contract concluded in your interest between Gleinna Group and a third party (for example, a shipping line or customs agent);
• the transfer is required on important public interest grounds, or for the establishment, exercise, or defence of legal claims (for example, customs and trade compliance); or
• the transfer is necessary to protect your vital interests.

We retain your personal information only for as long as is necessary to fulfil the purposes described in this policy, including:

• for the duration of our business relationship with you;
• for a minimum of five (5) years after the conclusion of a transaction, to comply with legal, tax, and customs record-keeping obligations in Zimbabwe and, where applicable, in other countries where we operate;
• for longer periods where required by Zimbabwean law or other applicable law.

When personal information is no longer required, we will securely delete, destroy, or anonymise it.

Subject to applicable law, you have the following rights in relation to your personal information:

• Right to be informed — to be told how your personal information is used
• Right of access — to request a copy of the personal information we hold about you
• Right to correction — to request that inaccurate, misleading, or incomplete information be corrected
• Right to deletion — to request deletion of false or misleading data, or of data that is no longer necessary for the purposes for which it was collected
• Right to object — to object to the processing of all or part of your personal information, including processing for direct marketing
• Right to withdraw consent — where processing is based on your consent, you may withdraw it at any time, free of charge, without affecting the lawfulness of processing before withdrawal

To exercise any of these rights, please contact us at compliance@gleinna.co.zw. We aim to respond within 30 days, or sooner where reasonably practicable. We may need to verify your identity before acting on your request.

Gleinna Group does not make decisions that significantly affect individuals (such as service approval or pricing decisions) on a solely automated basis. Where automation is used to support operational processes (for example, shipment tracking or routing), a human reviewer is involved before any decision with legal or similarly significant effect is taken.

We apply appropriate technical and organisational measures to protect your personal information against negligent or unauthorised destruction, negligent loss, unauthorised alteration or access, and any other unauthorised processing. These measures include:

• secure communication channels for transmitting sensitive information;
• access controls limiting data to authorised personnel only, on a need-to-know basis;
• written contracts with all data processors, requiring them to apply equivalent security measures;
• staff training on data protection and confidentiality;
• regular review of our data handling and security practices.

While we take reasonable precautions, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to continuously improving our safeguards.

In the event of a security breach affecting your personal information, Gleinna Group will take the following steps:

• Regulatory notification — we will notify the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ) within 24 hours of becoming aware of the breach;
• Notification to affected individuals — where, in our assessment, a breach is likely to result in a high risk to your rights or freedoms, we will notify you without undue delay, describing the nature of the breach, the likely consequences, and the measures taken or proposed to address it (this is a voluntary best-practice step, additional to what the Act expressly requires);
• Containment and remediation — we will take immediate steps to contain the breach, assess its impact, and implement measures to prevent recurrence;
• Record-keeping — we will maintain an internal record of all breaches, including those not required to be notified, for accountability purposes.

If you become aware of, or suspect, a data security incident involving your personal information held by us, please contact us immediately at compliance@gleinna.co.zw.

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected such information, please contact us immediately and we will delete it promptly.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will update the "Last Updated" date at the top of this page.

We encourage you to review this policy periodically. Continued use of our services after any changes constitutes your acceptance of the updated policy.

This Privacy Policy is governed by and construed in accordance with the laws of Zimbabwe. Any disputes arising in connection with this policy shall be subject to the exclusive jurisdiction of the courts of Zimbabwe.

The designated Data Protection Authority in Zimbabwe is the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ):

If you believe your data protection rights have been infringed and we have not resolved your concern to your satisfaction, you have the right to lodge a complaint with POTRAZ directly.