Privacy Policy

Last Updated: December 2025

1. INTRODUCTION

Welcome to Auckmund Investment CC ("Company", "we", "our", "us").

Auckmund Investment CC operates https://auckmund.com (hereinafter referred to as "Service" or "Website") and provides SMS broadcasting, AI solutions, software development, hosting, and IT consultation services.

This Privacy Policy governs your use of our Service and explains how we collect, safeguard, and disclose information that results from your use of our services, particularly in relation to SMS broadcasting services where we handle personal contact information including mobile phone numbers, names, and identification details.

We are committed to protecting your privacy and handling your data in an open and transparent manner. By using our Service, you agree to the collection and use of information in accordance with this policy.

2. DEFINITIONS

SERVICE means the https://auckmund.com website and all related services operated by Auckmund Investment CC, including SMS broadcasting, AI solutions, software development, hosting, and IT consultation.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). This includes but is not limited to names, mobile phone numbers, email addresses, physical addresses, and identification numbers.

CONTACT DATA means information collected for the purpose of SMS broadcasting services, including mobile phone numbers, names, identification numbers, and any other information provided for communication purposes.

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers (including MTC Namibia for SMS delivery) in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

USER is the individual or business entity using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

CLIENT means any business or individual who engages Auckmund Investment CC to provide services, particularly SMS broadcasting services on their behalf.

RECIPIENT means any individual whose contact information is provided to us by a Client for the purpose of receiving SMS messages or other communications.

3. INFORMATION WE COLLECT

We collect several different types of information for various purposes to provide and improve our Service to you.

3.1 Personal Data Collected Directly from Clients

When you use our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). This may include, but is not limited to:

• Full name (first name and last name)
• Email address
• Phone number (mobile and/or landline)
• Physical address (street address, city, postal code, country)
• Company name and registration details
• Tax identification number
• Banking details (for payment processing)
• Identification documents (where required by law)

3.2 Contact Data for SMS Broadcasting Services

IMPORTANT: When you engage our SMS broadcasting services, you provide us with contact lists containing personal information of your customers or employees (Recipients). This Contact Data typically includes:

• Mobile phone numbers
• Full names of recipients
• Identification numbers (where provided)
• Email addresses (where provided)
• Physical addresses (where provided)
• Date of birth (where provided)
• Gender (where provided)
• Any other information included in your contact database

By providing us with Contact Data, you warrant that:

• You have obtained proper consent from Recipients to share their information with us
• You have informed Recipients that their data will be processed for SMS broadcasting purposes
• You have the legal right to share this information with us
• Recipients have been informed about their right to opt-out of communications

3.3 Usage Data

We may collect information that your browser sends whenever you visit our Service or when you access Service by or through any device ("Usage Data"). This Usage Data may include:

• Your computer's Internet Protocol address (IP address)
• Browser type and version
• Pages of our Service that you visit
• Time and date of your visit
• Time spent on pages
• Unique device identifiers
• Device operating system
• Internet browser type
• Diagnostic data

3.4 Location Data

We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service and to improve and customize our Service. You can enable or disable location services when you use our Service at any time through your device settings.

3.5 Tracking & Cookies Data

We use cookies and similar tracking technologies to track activity on our Service and hold certain information.

Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

Types of Cookies we use:

• Session Cookies: To operate our Service
• Preference Cookies: To remember your preferences and settings
• Security Cookies: For security purposes
• Analytics Cookies: To analyze Service usage

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

4. HOW WE USE YOUR DATA

Auckmund Investment CC uses the collected data for various purposes:

4.1 General Service Purposes

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features when you choose to do so
• To provide customer support
• To gather analysis or valuable information to improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To fulfill any other purpose for which you provide it
• To provide you with news, special offers and information about our services (unless you opt out)

4.2 SMS Broadcasting Services

For our SMS broadcasting services specifically, we use Contact Data to:

• Broadcast SMS messages to Recipients on behalf of our Clients
• Configure custom sender addresses
• Schedule and automate message delivery
• Generate delivery reports and analytics
• Maintain opt-out lists
• Ensure compliance with telecommunications regulations
• Process failed delivery notifications

4.3 AI Solutions & Software Development

For AI solutions and software development services:

• To develop and train AI models and chatbots
• To provide customer service automation
• To build and maintain custom software applications
• To integrate systems and APIs

4.4 Legal Compliance

• To comply with legal obligations under Namibian law
• To comply with Communications Regulatory Authority of Namibia (CRAN) regulations
• To comply with the MTC Code of Conduct for Wireless Application Service Providers
• To respond to lawful requests from public authorities

5. DATA SHARING AND DISCLOSURE

5.1 Service Providers

We may share your Personal Data and Contact Data with third-party service providers to facilitate our Service, including:

• MTC Namibia: We partner with MTC Namibia to deliver SMS messages. Contact Data (mobile phone numbers and message content) is transmitted to MTC's network for message delivery. MTC Namibia is bound by their own privacy policies and the CRAN Code of Conduct.
• Hosting Providers: We use third-party hosting services to store data securely.
• Payment Processors: We use third-party payment processors to handle financial transactions. We do not store your complete payment card details.
• Analytics Providers: We may use third-party analytics services to monitor and analyze Service usage.

These service providers have access to your Personal Data only to perform tasks on our behalf and are obligated not to disclose or use it for any other purpose.

5.2 Business Transfers

If we or our subsidiaries are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

5.3 Legal Requirements

We may disclose your Personal Data in good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of Auckmund Investment CC
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of users of the Service or the public
• Protect against legal liability
• Respond to lawful requests by public authorities, including law enforcement

5.4 What We DO NOT Do

We will NEVER:

• Sell your Personal Data or Contact Data to third parties
• Share your contact databases with other clients or competitors
• Use Contact Data provided for SMS broadcasting for our own marketing purposes
• Disclose Contact Data to unauthorized parties
• Send unsolicited messages to Recipients using data provided to us

6. DATA RETENTION

6.1 Client Personal Data

We will retain your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to:

• Comply with our legal obligations
• Resolve disputes
• Enforce our legal agreements and policies
• Provide ongoing services

6.2 Contact Data for SMS Broadcasting

Contact Data provided for SMS broadcasting services is handled as follows:

• During Active Service: Contact Data is retained for the duration of your engagement with us and for a reasonable period thereafter to provide delivery reports and analytics.
• After Campaign Completion: Contact Data used for completed SMS campaigns may be retained for up to 12 months for record-keeping, dispute resolution, and compliance purposes.
• Opt-Out Lists: Recipients who opt out of SMS communications will have their mobile numbers retained indefinitely in our opt-out database to ensure they do not receive future messages.
• Deletion Requests: You may request deletion of Contact Data at any time. We will delete data within 30 days of your request, except where retention is required by law or for legitimate business purposes (such as maintaining opt-out lists).

6.3 Inactive Accounts

If you do not access your account for 12 consecutive months, we reserve the right to:

• Deem the account inactive
• Expire any unused credits
• Remove or archive your personal details
• Close the account

We will provide reasonable notice before taking these actions.

7. DATA SECURITY

The security of your data is important to us. We implement appropriate technical and organizational measures to protect Personal Data and Contact Data against unauthorized or unlawful access, processing, disclosure, alteration, or destruction.

7.1 Security Measures

Our security measures include:

• Encryption of data in transit using SSL/TLS protocols
• Secure storage of data on protected servers
• Access controls limiting who can view and process data
• Regular security audits and updates
• Employee training on data protection
• Secure backup procedures

7.2 Security Limitations

However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

7.3 Your Responsibility

You are responsible for:

• Maintaining the confidentiality of your account credentials
• Ensuring the security of devices used to access our Service
• Notifying us immediately of any unauthorized access to your account
• Ensuring that Contact Data you provide to us is obtained and shared lawfully

8. YOUR DATA PROTECTION RIGHTS

Under Namibian law and international data protection principles, you have certain rights regarding your Personal Data:

8.1 Right of Access

You have the right to request copies of your Personal Data. We may charge a small fee for this service.

8.2 Right to Rectification

You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

8.3 Right to Erasure

You have the right to request that we erase your Personal Data, under certain conditions.

8.4 Right to Restrict Processing

You have the right to request that we restrict the processing of your Personal Data, under certain conditions.

8.5 Right to Object

You have the right to object to our processing of your Personal Data, under certain conditions.

8.6 Right to Data Portability

You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

8.7 Right to Opt-Out

For Recipients of SMS Messages:

• Recipients have the right to opt out of receiving SMS messages at any time
• Opt-out mechanisms are included in all commercial SMS messages (reply "STOP")
• We maintain comprehensive opt-out lists and honor all opt-out requests immediately
• Recipients can contact us directly to be removed from specific or all SMS lists

For Marketing Communications:

• You may opt out of receiving marketing communications from us by following the unsubscribe link in emails or contacting us directly

8.8 Exercising Your Rights

To exercise any of these rights, please contact us at:

• Email: admin@auckmund.com
• Phone: +264 (081) 803-1157
• Physical Address: C3QH+249, Dr. Frans Indongo Street, Windhoek, Namibia

We will respond to your request within 30 days.

9. CHILDREN'S PRIVACY

Our Service is not intended for individuals under 18 years of age.

We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us immediately.

If we become aware that we have collected Personal Data from children under 18 without verification of parental consent, we take steps to remove that information from our servers.

For SMS Broadcasting Services: Clients must ensure they do not provide Contact Data for individuals under 18 without proper parental consent.

10. COMPLIANCE WITH REGULATIONS

10.1 CRAN Compliance

Auckmund Investment CC operates in compliance with the Communications Regulatory Authority of Namibia (CRAN) regulations governing telecommunications services.

10.2 MTC Code of Conduct

As a service provider utilizing MTC Namibia's network, we adhere to the MTC Code of Conduct for Wireless Application Service Providers, including provisions related to:

• Privacy and confidentiality
• Commercial communications
• Prevention of spam
• Customer relations
• Data protection

10.3 Anti-Spam Measures

We are committed to preventing spam and unsolicited commercial communications:

• We only send SMS messages on behalf of clients who have obtained proper consent
• All commercial SMS messages include opt-out mechanisms
• We maintain and honor comprehensive opt-out lists
• We do not send messages between 20:00 and 06:00 unless explicitly agreed by recipients
• We take immediate action on spam complaints

11. INTERNATIONAL DATA TRANSFERS

Your information, including Personal Data, may be transferred to and maintained on computers located outside of Namibia where data protection laws may differ.

If you are located outside Namibia and choose to provide information to us, please note that we may transfer the data to Namibia and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

12. LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site.

We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13. CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by:

• Posting the new Privacy Policy on this page
• Updating the "Last Updated" date at the top of this Privacy Policy
• Sending you an email notification (for significant changes)
• Displaying a prominent notice on our Service

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Your continued use of the Service after any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide by the modified Privacy Policy.