Privacy
Privacy Notice
Effective date: 25 September 2026
This Privacy Notice explains how PacyNet Technologies Limited ("PacyNet", "we", "us" or "our"), as the developer and operator of the public PacyEdu website, processes personal data obtained through pacyedu.com. PacyEdu is a product of PacyNet Technologies Limited.
For personal data processed through this public website, PacyNet acts as a data controller to the extent that it determines the purposes and means of that processing. We process personal data in accordance with applicable data protection law, including the Data Protection Act No. 3 of 2021 of the Republic of Zambia, where applicable.
1. Scope of this Notice
This Notice applies to the public PacyEdu website, including contact, waiting-list and pilot-enquiry features. It does not govern the processing of learner, teacher, parent, staff or institutional records within the authenticated PacyEdu platform. Such processing is subject to separate institutional agreements, product privacy documentation, access controls and other terms applicable to the relevant school, institution or authorised user.
2. Personal Data We May Collect
Depending on how you use the public website, we may collect or receive:
- Identity and contact information: such as your name, email address and other contact details that you choose to provide.
- Professional and institutional information: such as your school, organisation, position, role or relationship to an educational institution.
- Enquiry and communication information: including the contents of messages, pilot requests, waiting-list submissions and correspondence with us.
- Technical and security information: such as IP address, browser or device information, request metadata, timestamps, security events and server logs that may be generated when the website is accessed.
Sensitive information and learner records
The public website forms are not intended for the submission of learner records, passwords, authentication credentials, health information, financial account information, examination records or other sensitive personal data. You should not submit such information through a public website form unless we expressly provide an authorised and appropriately protected channel for that purpose.
3. How We Obtain Personal Data
We obtain personal data directly from you when you complete a form, send an email or otherwise communicate with us. We may also receive limited technical information automatically from the systems and service providers used to operate, secure and deliver the website.
4. Purposes for Which We Process Personal Data
We may process personal data for the following purposes:
- to receive, assess and respond to enquiries, requests and correspondence;
- to manage waiting-list registrations and expressions of interest;
- to discuss school pilots, institutional deployments, partnerships and related matters;
- to maintain records of our communications and relationship with prospective users or partners;
- to administer, maintain, protect and secure the website and associated systems;
- to detect, prevent and investigate misuse, fraud, abuse or security incidents;
- to comply with applicable law, lawful requests, regulatory requirements and legal obligations; and
- to establish, exercise or defend legal rights and claims.
5. Lawful Basis for Processing
The lawful basis relied upon will depend on the circumstances and applicable law. We may process personal data where the processing is necessary to take steps at your request, to pursue legitimate and lawful business interests that do not improperly override your rights, to comply with a legal obligation, or where you have given valid consent. Where consent is the basis for processing, you may withdraw that consent subject to applicable law and without affecting the lawfulness of processing undertaken before withdrawal.
6. Communications and Marketing
We may use the contact information you provide to respond to your enquiry and to continue a conversation that you have requested or that is reasonably connected to your stated interest in PacyEdu. We will not treat submission of a general enquiry as unlimited consent to unrelated marketing. Where applicable law requires consent for promotional communications, we will seek the appropriate consent and provide a lawful means to opt out.
7. Service Providers and Other Recipients
We may disclose personal data only where reasonably necessary for the purposes described in this Notice. Recipients may include:
- authorised PacyNet personnel who require access for legitimate business purposes;
- hosting, cloud, email-delivery, cybersecurity and other technology service providers that support the operation of the website;
- professional advisers, auditors, insurers or consultants where access is reasonably necessary and subject to appropriate duties of confidentiality; and
- courts, regulators, law-enforcement bodies or other public authorities where disclosure is required or permitted by law.
We do not sell personal data obtained through the public PacyEdu website to advertisers or data brokers.
8. International and Cross-Border Processing
Some technology providers supporting the website may operate infrastructure in more than one country. Where personal data is transferred or made accessible across borders, we will take measures required by applicable law to ensure that the transfer is lawful and that appropriate safeguards are applied having regard to the nature of the data and the circumstances of the processing.
9. Data Retention
We retain personal data for no longer than is reasonably necessary for the purposes for which it was collected, including responding to enquiries, maintaining appropriate business records, complying with legal or regulatory obligations, resolving disputes and enforcing agreements. Retention periods may differ according to the nature of the information, the relationship concerned and applicable legal requirements. Information may be retained for longer where required for an active legal hold, investigation or lawful regulatory purpose.
10. Data Security
We apply reasonable administrative, organisational and technical safeguards designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. These measures may include access restrictions, secure communications, service-provider controls, logging and other security practices appropriate to the relevant processing. No internet transmission, electronic storage system or security measure can be guaranteed to be completely secure, and users should exercise appropriate care when transmitting information online.
11. Cookies and Similar Technologies
The public website may use technical storage, cookies or similar mechanisms where necessary for functionality, security, fraud prevention or service delivery. If we introduce non-essential analytics, advertising or other tracking technologies that require notice or consent under applicable law, we will provide the relevant information and controls.
12. Children and Young Persons
PacyEdu is an education-focused product, but the public website is principally intended to provide product and institutional information and to facilitate legitimate enquiries. The public website forms should not be used to submit a child's learner record or other sensitive information about a child. Where a minor provides personal data through the public website, any consent or authorisation required by applicable law should be obtained from the appropriate parent, guardian or other authorised person.
13. Your Data Protection Rights
Subject to applicable law and any lawful limitations or exemptions, you may have rights in relation to your personal data, including rights to request access to personal data held about you, to request correction of inaccurate or incomplete data, to request deletion or restriction in appropriate circumstances, to object to certain processing, to withdraw consent where processing is based on consent, and to lodge a complaint with the competent data protection authority.
We may need to verify your identity before acting on a rights request and may request additional information reasonably necessary to locate the relevant records or determine whether a request can lawfully be fulfilled.
14. Third-Party Websites and Services
The website may contain links to third-party websites, platforms or services. Those third parties operate under their own terms and privacy practices. PacyNet is not responsible for the privacy practices of an independent third party merely because the public PacyEdu website contains a link to that third party.
15. Changes to this Privacy Notice
We may amend this Privacy Notice where necessary to reflect changes in law, technology, our website, our processing activities or our organisational practices. The revised version will be published on this page with an updated effective date. Material changes may be communicated by additional means where required by applicable law.
16. Questions, Rights Requests and Complaints
Privacy questions, rights requests and concerns relating to the public PacyEdu website may be sent to info@pacynet.com. Please provide sufficient information for us to identify the matter and respond appropriately.
Where applicable, you may also have the right to raise a complaint with the Data Protection Commission of Zambia or another competent supervisory authority with jurisdiction over the relevant processing.