Privacy Policy

Leaf-Note Financial Services & Real Estate Ltd

Last Updated: 21 January 2026

1. Introduction

Leaf-Note Financial Services & Real Estate Ltd ("Leaf-Note," "we," "us," or "our") is committed to maintaining the highest standards of data privacy and financial security. This Privacy Policy outlines how we collect, process, and protect personal data through our Automated Facebook Messenger Service ("the Service").

By interacting with the Service, you consent to the data practices described in this policy.

2. Legal Framework for Processing

We process personal data in strict accordance with the Zambian Data Protection Act, No. 3 of 2021. Our processing is based on the following lawful grounds:

Consent: Your voluntary initiation of a conversation via Facebook Messenger.
Contractual Necessity: Data required to facilitate real estate transactions or financial advisory services.
Legal Obligation: Compliance with Zambian Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations.
Legitimate Interests: To maintain the security of our platform and improve our service delivery.

3. Categories of Information Collected

To provide accurate financial and property assistance, we may collect:

Identity Data: Facebook display name, profile picture (publicly available), and unique Facebook User ID (PSID).
Contact Data: Phone numbers, email addresses, or physical addresses provided during consultation.
Financial & Asset Data: Budget ranges, financing requirements, asset portfolios, or property preferences.
Interaction Data: Chat history, timestamps, and metadata for auditing and quality control.

Note: We do not collect sensitive personal data (e.g., health, religious beliefs, or political affiliation) unless legally mandated for financial regulatory assessments.

4. Purpose of Data Use

Your information is used exclusively for legitimate business operations:

Service Delivery: Providing real-time property listings and financial guidance.
Verification: Confirming identity for secure financial inquiries.
Regulatory Compliance: Adhering to Zambian financial reporting standards.
AI Optimization: Enhancing the accuracy of automated responses.

We do not sell, rent, or trade your data to third-party marketers.

5. Technology & Security Safeguards

A. AI Processing (Google Gemini API)

Our Service utilizes the Google Gemini API to process queries. Leaf-Note uses enterprise-grade configurations ensuring that personal chat data is excluded from global model training. Your data remains within our controlled environment.

B. Security Infrastructure

Encryption: All data in transit is protected using Transport Layer Security (TLS).
Access Control: Restricted access on a strict need-to-know basis.
Infrastructure: Secure servers with regular vulnerability assessments.

6. Your Rights Under Zambian Law

Under the Data Protection Act (2021), you have the following rights:

Right of Access

Right to Rectification

Right to Erasure ("Right to be Forgotten")

Right to Human Intervention for automated decisions

7. Data Retention & Deletion

Data is retained only as long as necessary to fulfill service purposes or to comply with statutory obligations (typically 7–10 years for financial records).

To exercise deletion: Type "DELETE" in the Messenger chat or contact our Data Protection Officer directly.

8. Contact Information

Data Protection Officer

Leaf-Note Financial Services & Real Estate Ltd

Email: info@leafnote.xyz

Location: Zambia