How We Handle What You Give Us
The short version
The FBI Virus Audit and The Dzungu Index take no name and no address. Your answers are scored on your own device and the reading is written there. The Foundation receives the result itself so that it can see how the instruments are behaving, and it arrives with no address attached unless you ask for your own copy. The Sales Fit Audit asks for contact details before it starts, because a fit reading is of no use to anybody who cannot be contacted about it.
Who is responsible
Kufunga Foundation is the responsible party for everything described on this page. Write to info@kufunga.africa with any request about your own information, including a request to have it removed, and a person will answer you. This page is a starting document rather than legal advice, and the Foundation's own counsel governs where the two differ.
What Is Collected, And Why
Set out instrument by instrument, so you can see exactly what leaves your device at each point. Where a row says nothing is collected, nothing is collected.
| Where | What is collected | Why | How long |
|---|---|---|---|
| The FBI Virus Audit | Your answers and the score they produce. No name, no address, no account. | So the Foundation can see how the instrument is behaving across the people taking it. | 24 months |
| The Dzungu Index | Your ratings on the twelve dimensions and the band they produce. No name, no address, no account. | The same reason, and to keep the banding honest as more readings arrive. | 24 months |
| The Sales Fit Audit | Your name, email address and your thirty choices. | A fit reading is written to be discussed with the person it describes, so it is sent to them. | 24 months |
| Asking for your own copy | The email address you type into the band under the result. | To send you the result, and to attach the address to the copy already held so the two are one record rather than two. | 24 months |
| The contact form | Nothing is posted to us by the page. The form opens your own mail program with the message already written, and you send it yourself. | So that nothing leaves your device until you press send in your own mail program. | Held as ordinary correspondence |
| Writing or calling directly | Whatever is in your email, your WhatsApp message or your call. | To answer you. | Held as ordinary correspondence |
What we do not do
There is no advertising tracker on this site, no analytics product, no pixel, no cross-site identifier and no profiling of visitors. Nothing here is sold, rented or passed to a data broker. No result is shown to a sponsor, a partner or an employer with a name attached to it, and no institutional engagement changes that: where Kufunga works inside an organisation, the individual reports stay with the individuals and the organisation receives an aggregate, under a reporting protocol agreed with everyone before a single instrument is administered.
The cookies and the storage on your device
This site sets no cookies of its own. Two things are stored on your device rather than on a server. The service worker keeps a copy of the pages, the stylesheet, the scripts and the icons so that the app opens when you have no signal, and you can clear it at any time by removing the site data in your browser or uninstalling the app. While an instrument is open, your answers are held in the page's own memory so that the score can be worked out; closing the tab discards them.
The third parties in the page
The brand typeface is loaded from Google Fonts, which means your browser asks Google's servers for the font files and Google can see the internet address making the request. The results are mailed and recorded through Google Workspace, which is where the Foundation's own mail and control sheet sit. The share buttons at the foot of every page are ordinary links: nothing is sent to WhatsApp, Facebook, LinkedIn or X unless you press one, and pressing one opens that service with the address of the page you were reading.
Where the law sits
The Foundation operates across four countries and takes the highest standard among them rather than the lowest. In Botswana the Data Protection Act applies. In Zimbabwe the Data Protection Act applies and the Foundation's registration and correspondence are held accordingly. In South Africa the Protection of Personal Information Act applies. In Zambia the Data Protection Act applies. Where a person writes to us from the European Union or the United Kingdom, the General Data Protection Regulation applies to that correspondence, and where a person writes from California, the California Consumer Privacy Act applies.
The lawful basis is consent for everything an instrument records, because nothing is recorded until a person chooses to take one, and legitimate interest for ordinary correspondence, because a person who writes to the Foundation expects an answer.
What you can ask for
- A copy of whatever is held about you.
- A correction to anything that is wrong.
- Deletion of your record, which the Foundation carries out unless it is obliged to keep it.
- A restriction on what is done with it while a question about it is being settled.
- Withdrawal of consent, which stops any further use from the moment it is received.
- A complaint to the data protection authority in your own country, which you may make without going through the Foundation first.
Write to info@kufunga.africa and say plainly which of those you want. A request is answered within thirty days. Because two of the instruments take no identifier at all, a result from The FBI Virus Audit or The Dzungu Index usually cannot be traced back to a person, and where that is the case the Foundation says so rather than pretending to a search it cannot perform.
Children
The instruments are written for adults and the guided programme is run with adults. The Foundation does not knowingly hold information about anyone under eighteen, and where it learns that it has, the record is removed.
Where the information sits and who can reach it
Records are held in the Foundation's Google Workspace account, on servers operated by Google, and are reachable only by the named people at the Foundation who work the control sheet. Access is by account rather than by a shared password. Where a result has to cross a border to reach one of the Foundation's own offices in Botswana, Zimbabwe, South Africa or Zambia, it travels inside that same account rather than being exported to a third party.
Changes to this page
When what the system does changes, this page changes on the same day, and the date below moves with it. The Foundation does not describe a practice it has stopped and it does not delay a disclosure until a review cycle.
Last updated[CLIENT FILLS: the Foundation's registered office address for service, and the registration number to cite in a data request.]
Ask A Person, Not A Form
A request about your own record is read by somebody at the Foundation and answered in plain words. You do not need to quote a clause or use a particular form.
