Privacy Policy | Stengths Inc

Effective Date: [01 October 2025]

1. Introduction
Strengths Inc. (“we”, “us”, “our”) is committed to protecting your privacy and ensuring that your personal data is handled in a lawful, transparent and secure manner. This Privacy Policy explains how we collect, use, store, disclose, and otherwise process your personal data in compliance with the Data Protection Act 2022 of Eswatini (“the Act”).

2. Scope
This policy applies to all personal data we process about individuals who use our services, visit our website, contact us, or otherwise provide their information in connection with our operations. It covers data collected directly from you, or via third parties, whether in person, online, by phone, or in writing.

3. Definitions

Personal data: any information relating to an identified or identifiable person.
Data subject: you, the individual whose personal data we hold.
Data controller: the entity (Strengths Inc.) determining the purposes and means of processing personal data.
Data processor: an entity processing personal data on behalf of the data controller.

4. Legal Basis for Processing
We will only process your personal data where we have a lawful basis, including:

your consent;
to perform a contract with you;
to comply with a legal obligation;
to protect your vital interests;
for the purposes of legitimate interests of Strengths Inc. provided such interests are not overridden by your rights under the Act.

5. Types of Personal Data We Collect
We may collect the following categories of personal data:

Identifiers (e.g. name, national ID or passport number, contact details)
Contact information (email, telephone, address)
Records of communication (e.g. emails, calls)
Usage data (website visits, IP address, browser type)
Payment information (where applicable)
Any other data you voluntarily provide (e.g. feedback, survey responses)

6. Purposes of Processing
We collect and use your personal data for the following purposes:

to provide and manage our services;
to communicate with you about your account, services, offers, and updates;
to respond to your enquiries and requests;
for marketing and promotional purposes, with your consent where required;
to comply with legal and regulatory obligations;
to improve our services, website, and user experience;
to protect against fraud and misuse of our services.

7. Data Minimisation & Accuracy
We will only collect personal data that is adequate, relevant, and not excessive in relation to the purposes for which it is processed. We strive to ensure that your personal data is accurate, complete, and kept up to date.

8. Retention of Personal Data
We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Once the data is no longer needed, or you request deletion (if permitted by law), we will securely dispose of or anonymize it.

9. Security Measures
We implement appropriate technical and organizational security measures to protect your personal data from unauthorized access, loss, alteration, disclosure or destruction. These may include encryption, access control, secure servers, staff training, and contractual obligations with processors.

10. Disclosure to Third Parties
We may share your personal information with:

third-party service providers who perform services for us (e.g. payment processors, hosting providers) under confidentiality obligations;
regulatory, legal or law enforcement authorities, if required by law;
other parties with your consent.

If a third party is located outside Eswatini, we will ensure adequate safeguards are in place to protect your personal data in accordance with the Act and any applicable cross-border transfer rules.

11. Data Subject Rights
Under the Act, you have the following rights:

Right to access your personal data;
Right to rectify inaccurate or incomplete data;
Right to erasure (delete) in certain circumstances;
Right to object to or restrict processing;
Right to data portability where applicable;
Right to withdraw consent (where processing is based on your consent);
Right to lodge a complaint with the Eswatini Data Protection Authority (EDPA).

12. Data Breach Notification
In case of a personal data breach, we will notify the EDPA within 72 hours of becoming aware of the breach, if required under the Act. We will also notify you if the breach is likely to result in a high risk to your rights and freedoms.

13. Cookies and Tracking Technologies
Our website may use cookies or similar technologies to collect usage data. You may choose to disable cookies via your browser settings. However, disabling cookies may affect your experience or access to certain services.

14. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will post the updated policy on our website and indicate the effective date. Your continued use of our services after changes means you accept the updated policy.

15. Contact Information
If you have any questions, wish to exercise your rights, or make a complaint about how we process your personal data, please contact us at:

Strengths Inc.
Email: info@strengthsinc.com
Phone: +26876947409

You also have the right to contact the Eswatini Data Protection Authority (EDPA):
Eswatini Communications Commission (EDPA)
Email: info@edpa.org.sz