Effective Date: 21 August 2026
Last Updated: 21 August 2026

Gringo Innovations Limited (“Gringo Innovations”, “Gringo”, “we”, “us”, or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, store, protect, disclose and otherwise process personal information when you:

visit our website;
submit an enquiry or contact form;
request information about our services;
request a quotation;
interact with our advertisements;
submit information through our Google Ads lead forms;
communicate with us by email, telephone or other electronic means;
engage us for technology, consulting, procurement, support or other services; or
otherwise interact with Gringo Innovations online or in connection with our business activities.

This Privacy Policy should be read together with any specific privacy notices or consent notices that we may provide when collecting your personal information.

1. Who We Are

Gringo Innovations Limited is a technology and innovation company providing technology solutions, consulting, IT infrastructure, managed IT support, cybersecurity and security systems, website and digital solutions, industrial automation, technology procurement and related business services.

For personal information that Gringo collects and determines the purposes and means of processing, Gringo may act as a Data Controller.

Where Gringo processes personal information on behalf of a client under the client’s instructions, Gringo may act as a Data Processor.

Our primary privacy contact is:

Gringo Innovations Limited
Email: info@gringoinnovations.com
Website: gringoinnovations.com

2. Data Protection and Regulatory Compliance

Gringo Innovations is committed to complying with applicable data protection and privacy laws in Zambia, including the Data Protection Act, 2021 (Act No. 3 of 2021) and applicable regulations, guidelines and requirements issued by the Zambia Data Protection Commission.

Gringo Innovations is currently not registered with the Zambia Data Protection Commission as a Data Controller or Data Processor. We are undertaking the necessary steps to establish and complete our applicable registration and data protection compliance requirements.

The Zambia Data Protection Commission states that persons and organisations controlling or processing personal data are required to register as applicable under the Data Protection Act.

We will update this Privacy Policy where necessary when our regulatory status, processing activities or legal obligations change.

3. Personal Information We Collect

Depending on how you interact with Gringo, we may collect different categories of personal information.

3.1 Contact Information

This may include:

full name;
email address;
telephone or mobile number;
company or organisation name;
job title or position;
business address;
city;
province/state;
country; and
other contact information you voluntarily provide.

3.2 Business and Enquiry Information

When you contact us about our services, we may collect:

the technology solution or service you are interested in;
information about your organisation;
project requirements;
procurement requirements;
quotation or proposal requirements;
technical requirements;
budget or commercial information where voluntarily provided;
preferred method of communication;
information contained in your enquiry; and
other information necessary to respond to your request.

3.3 Website Information

When you visit our website, certain technical information may be collected automatically, including:

IP address;
browser type;
device type;
operating system;
approximate geographic information;
pages visited;
referring website;
date and time of visits;
interactions with the website;
website performance information; and
other technical information generated through your use of the website.

3.4 Information Submitted Through Lead Forms

When you submit a lead form through one of our advertisements, including Google Ads, we may receive information such as:

name;
email address;
telephone number;
company name;
job title;
country;
city;
province/state;
selected service or solution;
information provided in questions or responses; and
other information you voluntarily submit.

We use this information primarily to respond to your enquiry and determine how we may assist your organisation.

3.5 Client, Supplier and Business Information

If you become a client, supplier, business partner, contractor or other business contact, we may collect additional information necessary to manage the business relationship.

This may include:

contact information;
company information;
billing and invoicing information;
procurement information;
contract information;
correspondence;
project information;
service records;
account information; and
information necessary for legal, financial, tax, security or administrative purposes.

4. How We Collect Personal Information

We may collect personal information:

directly from you;
when you complete a website form;
when you submit a Google Ads lead form;
when you contact us by email;
when you contact us by telephone;
when you request a quotation;
when you communicate with our employees or representatives;
when you engage our services;
when you communicate with us through social media or other online platforms;
automatically through cookies and similar technologies;
from publicly available business information; and
from third parties where legally permitted and appropriate.

Where we collect personal information from another person or organisation, we will take reasonable steps to ensure that the information is handled lawfully and appropriately.

5. How We Use Personal Information

We may use personal information for legitimate business and operational purposes, including:

Providing Services

To:

provide technology services;
provide IT support;
provide website and digital services;
provide cybersecurity and security solutions;
provide industrial automation services;
provide consulting services;
provide procurement and technology supply services;
manage projects;
provide technical support; and
fulfil contractual obligations.

Responding to Enquiries

We may use your information to:

respond to enquiries;
contact you regarding a requested service;
provide quotations;
prepare proposals;
arrange meetings;
arrange demonstrations;
provide technical information; and
follow up on requests.

Business Development and Marketing

Where permitted by applicable law, we may use contact information to:

communicate information about Gringo’s services;
provide relevant business updates;
send marketing communications;
conduct business development;
invite you to events or demonstrations;
follow up on previous enquiries; and
understand interest in our services.

You may request that we stop sending direct marketing communications at any time.

Website and Advertising

We may use information to:

operate and maintain our website;
understand website usage;
measure advertising performance;
improve our website;
understand which services are of interest to visitors;
improve our marketing campaigns; and
prevent fraudulent or abusive activity.

Legal and Administrative Purposes

We may process personal information to:

comply with legal obligations;
maintain business records;
resolve disputes;
enforce agreements;
protect our rights;
prevent fraud;
investigate security incidents;
respond to lawful requests from authorities; and
meet accounting, tax and regulatory requirements.

6. Legal Basis for Processing

Depending on the circumstances, we may process personal information on the basis of:

your consent;
performance of a contract or steps taken at your request before entering into a contract;
compliance with a legal obligation;
protection of legitimate business interests, where permitted by law;
protection of vital interests where applicable; or
another lawful basis recognised under applicable law.

Where we rely on consent, you may withdraw that consent where applicable.

Withdrawal of consent does not necessarily affect the lawfulness of processing that occurred before the withdrawal.

7. Website Forms

Our website may contain contact, enquiry, quotation, service request and other forms.

When you submit information through these forms, the information may be transmitted to Gringo Innovations and stored or processed using our website infrastructure and relevant service providers.

We use submitted information for the purpose for which it was provided and for reasonable related business purposes.

You should not submit sensitive personal information through a general website enquiry form unless specifically requested by Gringo and appropriate security measures have been established.

8. Google Ads and Lead Generation

Gringo Innovations may use online advertising platforms, including Google Ads, to promote its services.

Some advertisements may contain lead forms that allow prospective customers to submit information without immediately visiting our website.

Information submitted through such forms may include your name, email address, telephone number, company name, job title, location and information regarding the service or solution you are interested in.

We use lead information to:

respond to enquiries;
contact prospective customers;
understand the prospect’s requirements;
provide information about relevant Gringo services;
prepare quotations or proposals where appropriate; and
manage our sales and business development process.

Google and other advertising providers may process information in accordance with their own privacy policies and terms.

We do not sell personal information collected through our lead-generation activities.

9. Cookies and Similar Technologies

Our website may use cookies and similar technologies.

Cookies are small files stored on your device that help websites operate, remember preferences and understand how visitors interact with websites.

We may use cookies for purposes including:

essential website functionality;
security;
remembering preferences;
website performance;
analytics;
advertising measurement;
conversion tracking;
understanding website traffic; and
improving user experience.

Where required, we will seek consent before placing non-essential cookies.

You may be able to control or disable cookies through your browser settings. Disabling certain cookies may affect website functionality.

Our website may use a cookie consent management system to help manage applicable cookie preferences.

10. Analytics

We may use analytics technologies, including Google Analytics or similar services, to understand how visitors use our website.

Analytics information may include:

pages viewed;
traffic sources;
device information;
browser information;
approximate location;
interaction data;
session information; and
website performance information.

Analytics information helps us understand website performance and improve our services and online presence.

Where applicable, analytics providers may process information in accordance with their own privacy policies.

11. Advertising and Conversion Tracking

We may use advertising technologies to measure the effectiveness of our marketing campaigns.

These technologies may help us understand:

whether an advertisement was viewed or interacted with;
whether a visitor subsequently visited our website;
which services generate enquiries;
advertising conversion rates; and
general campaign performance.

Where required, we will obtain appropriate consent before using non-essential advertising or tracking technologies.

12. Third-Party Service Providers

We may use trusted third-party service providers to support our business operations.

Depending on our specific systems and services, these may include providers of:

website hosting;
cloud infrastructure;
email services;
productivity and collaboration services;
analytics;
advertising;
cybersecurity;
payment services;
customer relationship management;
communication services;
backup and storage;
website forms; and
other technology services.

Third-party providers may process personal information on our behalf or may independently process information in accordance with their own legal obligations and privacy policies.

Where a third party processes personal information on our behalf, we seek to use appropriate contractual, technical and organisational safeguards.

13. Microsoft and Google Services

Gringo Innovations may use technology and cloud services provided by companies such as Microsoft and Google for business operations, productivity, communications, analytics, advertising, cloud services and other technology functions.

Where these services involve personal information, the relevant provider may process or store information on its infrastructure in accordance with its applicable terms and privacy policies.

The location of cloud infrastructure may be outside Zambia.

14. International Transfers and Storage

Some of our technology and service providers may store or process personal information outside Zambia.

This may occur because we use cloud-based, advertising, analytics, communications, hosting or other technology services that operate internationally.

Where personal information is transferred or stored outside Zambia, Gringo will take reasonable steps to ensure that such processing is conducted in accordance with applicable Zambian data protection requirements and any required safeguards, contractual arrangements, approvals or authorisations.

The Zambia Data Protection Act contains specific requirements concerning transfers of personal data outside Zambia.

15. Sharing of Personal Information

We may disclose personal information where reasonably necessary for the purposes described in this Privacy Policy.

This may include sharing information with:

employees and authorised representatives;
technology service providers;
cloud and hosting providers;
professional advisers;
auditors;
legal advisers;
payment and financial service providers;
business partners where appropriate;
contractors and suppliers;
government authorities where legally required; and
other parties where you have authorised or requested the disclosure.

We do not sell your personal information to third parties.

We only seek to disclose information that is reasonably necessary for the relevant purpose.

16. Data Security

Gringo Innovations takes reasonable technical and organisational measures to protect personal information against:

unauthorised access;
unauthorised disclosure;
accidental loss;
destruction;
alteration;
misuse; and
other unlawful or unauthorised processing.

Security measures may include:

access controls;
authentication;
password controls;
system permissions;
secure hosting;
backups;
software updates;
monitoring;
administrative controls;
employee awareness and procedures; and
other appropriate technical and organisational safeguards.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

You should also take reasonable precautions when submitting information online.

17. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Retention periods may depend on:

the nature of the information;
the purpose for which it was collected;
whether we have an ongoing business relationship with you;
contractual obligations;
legal requirements;
accounting and tax requirements;
dispute resolution;
security requirements; and
legitimate business needs.

When personal information is no longer required, we will take reasonable steps to securely delete, destroy or anonymise it where appropriate.

18. Your Data Protection Rights

Subject to applicable law and any applicable limitations, you may have rights concerning your personal information, including the right to:

request access to personal information we hold about you;
request correction of inaccurate or incomplete information;
request deletion or erasure where applicable;
object to certain processing;
request restriction of processing where applicable;
withdraw consent where processing is based on consent;
object to direct marketing;
request information about how your personal information is being processed; and
exercise other rights provided under applicable data protection legislation.

The Zambia Data Protection Commission identifies rights including access, correction and erasure, prevention of processing for direct marketing, rights relating to automated decision-making and the right to complain about breaches or non-compliance.

Some rights may be subject to legal exceptions or limitations.

19. Direct Marketing

If you receive marketing communications from Gringo Innovations, you may request that we stop sending them.

You may do this by:

using an unsubscribe option where provided;
replying to the relevant communication; or
contacting us at info@gringoinnovations.com.

We will take reasonable steps to process your request.

Please note that even if you opt out of marketing communications, we may still send necessary service-related, transactional, security or administrative communications.

20. How to Request Access, Correction or Deletion

To make a privacy or data protection request, contact:

Email: info@gringoinnovations.com

Your request should, where reasonably possible, include:

your full name;
contact information;
the nature of your request;
relevant information that will help us identify the records concerned; and
any other information reasonably necessary to process your request.

We may need to verify your identity before providing access to personal information or processing certain requests.

We will respond to requests within the timeframe required by applicable law.

21. Complaints

If you have concerns about how Gringo Innovations handles your personal information, we encourage you to contact us first at:

info@gringoinnovations.com

We will review and address privacy concerns in accordance with our internal procedures and applicable law.

Where you believe your rights have not been adequately addressed, you may also contact the Zambia Data Protection Commission, the regulatory authority responsible for data protection in Zambia. The Commission provides registration, compliance and data protection resources for organisations and data subjects.

22. Personal Information Relating to Children

Our services and website are primarily intended for businesses, organisations and adults.

We do not knowingly seek to collect personal information from children through our general marketing and business enquiry activities.

Where the processing of a child’s personal information is required, we will take appropriate steps consistent with applicable law, including obtaining appropriate consent from a parent, guardian or person exercising parental responsibility where required.

23. Third-Party Websites

Our website may contain links to websites or services operated by third parties.

These websites are not controlled by Gringo Innovations.

We are not responsible for the privacy practices, content, security or policies of third-party websites.

We encourage you to review the privacy policy of any third-party website before providing personal information.

24. Social Media

Gringo Innovations may maintain profiles or pages on social media and other online platforms.

When you interact with us through those platforms, the relevant platform may collect and process information according to its own privacy policy and terms.

Information that you voluntarily submit to us through social media may be used to respond to your enquiry or for other legitimate business purposes.

25. Business Communications

If you communicate with Gringo Innovations by email, telephone or other electronic communication, we may retain relevant correspondence and contact information for legitimate business, administrative, security, legal and record-keeping purposes.

This may include communications relating to:

enquiries;
quotations;
proposals;
contracts;
projects;
procurement;
support;
payments;
complaints; and
other business activities.

26. Data Processed on Behalf of Clients

In providing certain technology services, Gringo Innovations may process personal information on behalf of its clients.

In such circumstances, the client may determine the purposes and means of processing, while Gringo acts as a Data Processor.

Examples may include certain:

IT support activities;
cloud administration;
system administration;
database services;
website services;
managed services;
backup services;
cybersecurity services; and
technology implementation services.

Where Gringo acts as a Data Processor, we will process personal information in accordance with the applicable contractual arrangements and lawful instructions of the relevant Data Controller, subject to applicable law.

27. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Changes may be made to reflect:

changes to our services;
changes to our technology;
changes to our data processing activities;
changes to legal or regulatory requirements;
changes to third-party service providers; or
improvements to our privacy practices.

When we make material changes, we will update the Last Updated date at the top of this Privacy Policy.

We encourage you to periodically review this page.

28. Contact Us

If you have questions, concerns or requests relating to this Privacy Policy or the processing of your personal information, please contact:

Gringo Innovations Limited

Privacy & Data Protection Contact
Email: info@gringoinnovations.com
Website: gringoinnovations.com