Fresh2Go Privacy Policy

The entity responsible for collecting, storing, and processing your personal data is Tomile Solutions Limited (PACRA Registration No. 120261044289), a company incorporated under the laws of the Republic of Zambia, registered at No. 3 Palm Drive, Chelstone, Lusaka, Zambia. Tomile Solutions Limited operates the Fresh2Go platform and is the Data Controller for the purposes of the Data Protection Act (No. 3 of 2021).

Data Protection Contact: Kazhila Ndonji, Co-Founder
Email: hello@fresh2go.app
Telephone: +260 77 490 4560

When you access, register, or interact with the Fresh2Go platform, we collect specific categories of personal data required to operate the marketplace. Without this information, we cannot process orders or enable pickup. This data includes:

• Profile details: Full name, telephone number, email address, gender (where provided), and date of birth.
• Transactional data: When you place an order, we do not store card numbers or PINs. We collect verified gateway responses from authorised payment aggregators and mobile network operators, including mobile money reference numbers, transaction status codes, and order identification records.
• Device and location data: Real-time geographic coordinates from your mobile device, collected strictly to identify nearby participating suppliers and calculate collection distances. Location capture operates entirely on the basis of your express consent, which may be granted or withdrawn at any time through your device privacy settings.
• Preferences and usage: Selected food category preferences and past ordering activity.
• Communications: Information you provide when raising support queries, reporting issues, participating in surveys, or contacting our team.

• Contractual necessity: Processing profile details, transaction references, and order history is necessary to perform our agreement with you, including reserving a Surprise Bundle and enabling collection from the supplier.
• Express consent: Device location capture and marketing communications are governed by your voluntary consent, which you may modify or withdraw at any time.
• Legitimate interests: Processing usage analytics, system diagnostics, and aggregated feedback is necessary for our legitimate interests in maintaining, securing, and improving the Fresh2Go platform.

To manage relationships with participating food businesses (including supermarkets, bakeries, restaurants, hotels, canteens, and delis), we process business-related personal data belonging to store owners, managers, and authorised personnel. This includes:

• Commercial profile details: Full names, business email addresses, direct contact numbers, outlet locations, business category, and the role of the relevant point of contact.
• Financial and statutory identifiers: Bank account details, authorised payment routes, and tax identifiers (such as TPIN issued by the Zambia Revenue Authority) required to process settlement payments.

Certain supplier information (including the supplier's trading name and outlet location) is displayed to consumers on the Fresh2Go platform to enable order placement and pickup. Supplier pricing, inventory volumes, and internal commercial terms are not disclosed to consumers.

Fresh2Go does not sell, rent, or otherwise permit the unauthorised distribution of personal data. We use selected third-party data processors to deliver specific platform functions, including payment processing, cloud hosting, and analytics. These processors act under written contractual obligations that restrict them from using your data for any purpose other than providing services to Fresh2Go.

Personal data collected through the Fresh2Go platform is hosted on cloud infrastructure operated by our database provider, with servers located in Cape Town, South Africa. South Africa maintains comprehensive data protection legislation (the Protection of Personal Information Act, 2013) that provides a comparable standard of protection to the Data Protection Act (No. 3 of 2021) of Zambia. This cross-border transfer is conducted in accordance with Section 59 of the Data Protection Act, on the basis that (a) the transfer is necessary for the performance of the contract between you and Fresh2Go, including processing orders, managing accounts, and enabling pickup; and (b) the receiving jurisdiction maintains adequate data protection safeguards.

The Fresh2Go website and application may use cookies, local storage, or similar technologies to maintain session state, remember preferences, and collect aggregated usage statistics. Where tracking is used for analytics or marketing purposes, it operates on the basis of your consent and may be managed through your browser or device settings.

Under the Data Protection Act (No. 3 of 2021) of Zambia, you have the following rights over your personal data:

• Right of access. Request confirmation of whether your personal data is being processed, and receive a clear record of the specific data held.
• Right to rectification. Request correction of any incomplete, inaccurate, or outdated personal data associated with your account.
• Right to erasure. Request deletion of your personal data, provided it is no longer required to fulfil a contractual obligation or a mandatory financial or regulatory record-keeping requirement.
• Right to restrict or object to processing. Object to processing based on legitimate interests, or withdraw consent to analytics tracking and direct marketing, at any time.
• Right to data portability. Request a copy of your personal data in a structured, commonly used, and machine-readable format. You can do this yourself at any time from Profile → Download my data.

To exercise any of these rights, contact us at hello@fresh2go.app or through the in-app support channel.

The Fresh2Go platform uses your location and stated preferences to surface relevant Surprise Bundles from nearby suppliers. This is a recommendation feature, not automated decision-making with legal or similarly significant effects.

Fresh2Go is not directed at individuals under the age of 18. We do not knowingly collect or process personal data from minors. If we become aware that a user is under 18, we will take steps to delete their data and close their account.

In the event of a security breach affecting personal data, Tomile Solutions Limited will notify the Office of the Data Protection Commissioner within twenty-four hours of becoming aware of the breach. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify affected users without undue delay.

Tomile Solutions Limited maintains appropriate physical, technical, and organisational security measures to protect personal data. Personal data is retained only for as long as necessary to fulfil the purpose for which it was collected, or as required under applicable Zambian record-keeping obligations, after which it is securely deleted or permanently anonymised.

We may update this Policy to reflect changes in our practices, technology, or legal requirements. Where changes are material, we will notify users through the Fresh2Go application or by email before the changes take effect.

Email: hello@fresh2go.app
Telephone: +260 77 490 4560
Post: Tomile Solutions Limited, No. 3 Palm Drive, Chelstone, Lusaka, Zambia

If your query remains unresolved, you retain the right to lodge a complaint with the Office of the Data Protection Commissioner of Zambia.