Legal centre

Terms and Conditions of Use

Version 3.0 · Effective 23 September 2026 · Laws of Zimbabwe

This document is the single combined agreement governing access to and use of the Efolite product-discovery and advertising platform. It contains the General Terms, Privacy and Data Protection Notice, Seller Terms, Buyer Terms, Prohibited Products and Conduct Policy, Payments and Refund Policy, Cookie Notice, and additional platform protections.

IMPORTANT CONSUMER AND USER NOTICE

PLEASE READ THIS DOCUMENT CAREFULLY. Efolite is primarily an advertising and product-discovery platform. It does not ordinarily sell the goods advertised by independent sellers, does not take possession of those goods, and does not collect the purchase price of those goods. Transactions are generally concluded directly between buyer and seller. Certain clauses below limit Efolite’s liability, allocate risk, require users to indemnify Efolite in specified circumstances, and explain dispute procedures. Those clauses are subject at all times to rights that cannot lawfully be excluded under Zimbabwean law, including the Consumer Protection Act [Chapter 14:44].

Part A — General Terms Of Use

A1. Agreement, acceptance and legal capacity

These Terms and Conditions ("Terms") form a binding agreement between you and Efolite ("Efolite", "we", "us" or "our"). By creating an account, selecting an acceptance checkbox, submitting a listing, purchasing a platform service, accessing the platform after being presented with these Terms, or otherwise using Efolite, you confirm that you have read and accepted the parts of this agreement that apply to you.

Where a provision limits liability, imposes an indemnity, records an assumption of risk, or contains another term requiring special notice under applicable consumer law, Efolite may require a separate acknowledgement. A user’s acceptance does not waive any right that cannot lawfully be waived.

You must be at least 18 years old and have legal capacity to contract. If you use Efolite for a company, partnership, trust, shop or other organisation, you warrant that you are authorised to bind that entity. Efolite may request proof of authority.

A2. Definitions

For this agreement:

• "Buyer" means a user who searches for, enquires about or purchases goods advertised by a Seller.

• "Seller" means a user who creates a seller account, storefront or listing, whether acting formally or informally and whether as an individual or business.

• "Listing" means an advertisement, product page, vehicle advertisement, image, description, price or other offer-related content uploaded to Efolite.

• "Platform" means the Efolite website, web application, mobile application, databases, chat, seller dashboard, AI-assisted search and related services.

• "Paid Service" means a service purchased from Efolite, including a boost, premium placement, analytics package, additional listing entitlement or other paid platform feature.

• "User Content" means content submitted, uploaded, sent or published by a user, including listings, images, reviews, messages and profile information.

• "Verified Seller" means a seller whose required verification information has been reviewed under Efolite’s verification procedure. Verification is not an endorsement or guarantee.

• "AI Search" means any artificial-intelligence-assisted search, classification, ranking, matching, summarisation or recommendation feature used on the Platform.

A3. Nature of the Platform — advertising and discovery service

Efolite provides a searchable advertising and product-discovery environment through which Sellers may advertise goods and Buyers may discover listings and contact Sellers. Efolite is not ordinarily the seller, owner, manufacturer, importer, distributor, courier, insurer, escrow agent or payment collector for the purchase price of goods advertised by independent Sellers.

Unless Efolite expressly states otherwise for a particular service, all negotiation, inspection, payment, collection, delivery, returns, warranties and after-sale arrangements for an advertised product are concluded directly between the Buyer and Seller.

Nothing in these Terms excludes any duty that Zimbabwean law may impose on Efolite in its own capacity as a platform operator, service provider, supplier of Paid Services, hosting provider or intermediary. No wording in these Terms is intended to contract out of a statutory obligation that cannot lawfully be excluded.

Efolite currently does not operate checkout, escrow or collection of the purchase price of advertised goods. A person claiming to collect product purchase money on Efolite’s behalf is not authorised unless the Platform expressly identifies the payment as a payment to Efolite for a Paid Service.

A4. Accounts and account integrity

Users must provide accurate, current and complete registration information and must promptly update it. False identity, impersonation, forged documents, duplicate accounts used to evade enforcement, or unauthorised use of another person’s details constitutes a material breach.

You are responsible for activity carried out through your account, subject to applicable law, and must take reasonable steps to secure your password, device, email and mobile number. You must notify Efolite promptly if you suspect compromise. Efolite may temporarily lock an account where necessary to protect users, data or the Platform.

Accounts, badges and seller histories may not be sold, rented, transferred or shared in a manner that misleads users about the identity of the person operating the account.

A5. Seller identity verification

Before a Seller may publish listings, Efolite may require verification of the Seller’s mobile number and national identity document or another identity document accepted by Efolite. Business Sellers may also be required to provide business registration, tax, licensing, dealership or authority documents where reasonably necessary.

Verification confirms only that specified information or documents were submitted and reviewed. It does not certify ownership of a product, financial standing, honesty, product quality, legal compliance or the likelihood that a transaction will be completed.

Efolite may re-verify a Seller, request updated documents, apply enhanced verification to higher-risk categories, and suspend publication while verification is incomplete or inconsistent. Use of verification data is governed by Part B.

A6. User Content, licence and representations

You retain ownership of User Content that you lawfully own. You grant Efolite a non-exclusive, worldwide, royalty-free, transferable and sub-licensable licence to host, store, reproduce, resize, format, display, communicate, index, classify, promote and distribute User Content solely for operating, securing, marketing and improving Efolite and for preserving evidence or complying with law.

The licence continues after removal only to the extent reasonably necessary for backups, audit records, fraud prevention, legal compliance, dispute defence and historical service records.

You warrant that you have the necessary rights to upload the content; that it is accurate in all material respects; that it does not infringe copyright, trade marks, design rights, privacy, confidentiality or other third-party rights; and that publication is lawful. You remain responsible for claims arising from your own content.

A7. Search, ranking, AI and boosted placement

Search results may be ordered using relevance, category, location, price, freshness, listing quality, user preferences, popularity, verification status, safety signals and other platform factors. Paid boosts may increase visibility and must be identified as boosted, promoted or sponsored where appropriate.

AI Search is a discovery aid. It may interpret natural-language requests and convert them into search criteria, but it does not inspect products and must not be treated as professional, technical, legal, financial or safety advice. AI-generated summaries may be incomplete or inaccurate. The underlying Seller listing remains the Seller’s representation.

Efolite does not guarantee that AI Search will identify every matching product or that the order of results will be optimal for a particular user. Efolite will not knowingly use solely automated processing to make a decision producing legal or similarly significant effects on a data subject without a lawful basis and appropriate safeguards.

A8. Prohibited conduct

You must not:

• advertise, request or facilitate prohibited or unlawful items or services;

• publish deceptive, fraudulent, defamatory, threatening, hateful, discriminatory, obscene or unlawfully invasive material;

• use fake prices, bait advertisements, false urgency, fake stock, forged documents, advance-fee schemes or false payment proofs;

• manipulate views, favourites, chats, rankings, search results, reviews, verification status or analytics;

• scrape, harvest, crawl, copy or extract data by automated means without Efolite’s prior written permission, except to the extent a restriction is prohibited by law;

• reverse engineer, probe, attack, overload, bypass, introduce malware into, or interfere with the Platform or its security;

• circumvent fees, limits, suspension measures or verification controls;

• collect, sell or use personal information obtained through Efolite for spam, profiling, harassment or any purpose unrelated to a genuine transaction or another lawful purpose;

• use Efolite for money laundering, sanctions evasion, unlicensed financial activity, unlawful foreign-currency dealing or any criminal purpose;

• impersonate Efolite staff, a bank, courier, public authority or another user; or

• request or disclose passwords, PINs, one-time passwords, card details or other authentication credentials.

A9. Intellectual-property complaints and notice procedure

A rights holder who reasonably believes that a Listing infringes copyright, trade mark, design or another proprietary right may report the Listing through Efolite’s designated reporting channel and should provide sufficient information to identify the work, the allegedly infringing content, the basis of the claim and the complainant’s contact details.

Efolite may temporarily restrict content while reviewing a credible complaint and may request further evidence from either party. Efolite does not determine final ownership disputes and may require parties to obtain an order from a competent authority or court where the dispute cannot reasonably be resolved on available information.

A10. Moderation, illegal content and cooperation

Efolite may review, reformat, classify, restrict, hide, refuse, suspend, expire or remove User Content where it reasonably believes that the content breaches these Terms, presents a safety or fraud risk, infringes rights, violates law, or could expose Efolite or users to material risk.

Where Efolite becomes aware of information that appears illegal, it may preserve evidence, restrict access, make an appropriate report, and comply with lawful court or regulatory orders. Efolite’s actions are intended to be consistent with obligations applicable to hosting and service providers under Zimbabwean law.

Efolite is not required to pre-screen every listing or message and does not warrant that moderation systems will identify every violation.

A11. Paid Services, pricing and activation

Paid Services may include boosts, premium placement, analytics, additional listing capacity and other digital platform services. Prices, duration, taxes and material service features will be displayed before an order is finally placed.

Efolite may change future prices and packages. A change does not retrospectively alter a Paid Service already purchased, except where required by law or agreed with the user.

Payment may be made through payment methods displayed on the Platform, which may include EcoCash, bank transfer or an authorised payment provider. Activation may be subject to confirmation of cleared or verified payment.

Paid Services do not guarantee views, enquiries, messages, sales, revenue or any specific commercial result.

A12. Consumer cancellation, refunds and service failures

Nothing in these Terms removes a refund, cancellation, repair, replacement, re-performance or other remedy that applies by law. In particular, where the Consumer Protection Act [Chapter 14:44] applies to an electronic transaction, Efolite will honour the statutory cooling-off and refund rights applicable to its own Paid Services.

Subject to mandatory law, a user requesting cancellation of an eligible electronic transaction within the statutory period may do so through the support channel. Where the law requires a refund, Efolite will process it within the period required by law and may request information reasonably necessary to verify the payment and recipient.

Outside mandatory cancellation or refund rights, Efolite may decline discretionary refunds where the Paid Service was supplied substantially as described, but may re-credit, extend or re-perform a service where a verified technical failure materially prevented delivery.

A13. Suspension, restriction and termination

Efolite may issue warnings, restrict features, hide listings, require re-verification, suspend an account or terminate access where reasonably necessary because of suspected fraud, illegal activity, safety concerns, repeated complaints, payment abuse, security risk or material breach.

Except where immediate action is reasonably necessary, Efolite may provide notice and an opportunity to respond. Users may submit an appeal through the designated support channel. Fraudulent documents, illegal goods, threats to safety, repeat evasion of enforcement or other serious misconduct may justify immediate restriction.

Termination does not erase accrued payment obligations, legal claims, evidence-preservation duties or provisions that by their nature are intended to survive.

A14. Third-party services and links

Efolite may provide links or integrations to WhatsApp, banks, fintech providers, couriers, mapping services, hosting providers or other third parties. Those services are operated independently and may have separate terms, privacy notices, charges and availability conditions.

A link, integration or commercial relationship does not by itself make Efolite responsible for the third party’s acts or omissions, nor does it amount to endorsement of a particular Seller or product. Nothing in this clause excludes liability that cannot lawfully be excluded.

A15. Safety and user due diligence

Users are responsible for taking reasonable precautions before meeting strangers, handing over goods, releasing title documents or making payment. Efolite recommends public meeting places during daylight, independent inspection of high-value items, verification of ownership documents, written confirmation of key terms, and refusal to share authentication credentials.

For motor vehicles, Buyers should independently verify identity, ownership, registration, duty status, encumbrances, roadworthiness and any other relevant documentation before payment. For phones, laptops and electronics, Buyers should verify serial or device identifiers where possible and test functionality.

A16. Platform warranties and availability

Subject to rights that cannot lawfully be excluded, Efolite does not warrant that every listing is accurate, genuine, lawful, available or fit for a particular purpose; that every user is solvent or honest; or that the Platform will be uninterrupted or error-free. Efolite does not physically inspect or authenticate ordinary listings unless it expressly states otherwise.

Efolite may perform maintenance, change features, discontinue categories, impose technical limits or suspend services where reasonably necessary for security, compliance, maintenance or business continuity.

A17. Limitation of liability — important

THIS CLAUSE LIMITS EFOLITE’S LIABILITY. IT DOES NOT EXCLUDE LIABILITY OR CONSUMER RIGHTS THAT ZIMBABWEAN LAW DOES NOT PERMIT EFOLITE TO EXCLUDE.

To the fullest extent permitted by law, Efolite will not be liable for indirect, special, incidental, punitive or consequential loss, or loss of profit, revenue, opportunity, goodwill, anticipated savings or business interruption, where such loss does not arise from a liability that cannot lawfully be limited.

Efolite is not responsible merely because a Buyer or Seller suffers loss caused by another user’s fraud, non-payment, non-delivery, misdescription, counterfeit or stolen goods, defective goods, unsafe meetings, or a third-party bank, payment provider, courier or communications service, provided that this exclusion does not apply to loss caused by Efolite’s own fraud, wilful misconduct, gross negligence, breach of a non-excludable statutory duty, or another liability that may not lawfully be excluded.

Where Efolite may lawfully limit but not exclude liability arising solely from a Paid Service supplied by Efolite, its aggregate liability for direct loss will not exceed the greater of the amount paid by the user for the affected Paid Service in the three months preceding the event or US$100, unless a higher amount is required by law. This cap does not apply to liability that cannot lawfully be capped.

A18. Indemnity — important

THIS CLAUSE MAY REQUIRE A USER TO REIMBURSE EFOLITE FOR CERTAIN THIRD-PARTY CLAIMS CAUSED BY THAT USER’S OWN WRONGFUL CONDUCT.

To the fullest extent permitted by law, a Seller or other user acting in the course of business indemnifies Efolite and its officers, employees and contractors against third-party claims, regulatory costs, losses and reasonable legal costs arising directly from that user’s unlawful listings, infringement of third-party rights, fraud, material breach of these Terms, or failure to comply with legal obligations applicable to that user’s own goods or trading activity.

This indemnity does not require a consumer to indemnify Efolite for Efolite’s own negligence, gross negligence, fraud, wilful misconduct or breach of a non-excludable statutory duty, and it will be interpreted only to the extent permitted by the Consumer Protection Act and other applicable law.

A19. Communications and notices

You agree to receive account, service, security, moderation, payment, verification and legal notices through the Platform and through the contact details registered to your account. Marketing communications will be sent only as permitted by law and may be opted out of where applicable.

Users must keep contact details current. A notice is treated as sent when dispatched to the latest contact details provided, but this clause does not override any mandatory legal rule prescribing another method of service.

A20. Changes to these Terms

Efolite may amend these Terms to reflect changes in law, regulation, security, functionality, pricing or business operations. Material changes will be communicated through the Platform or registered contact details and, where appropriate, renewed acceptance will be required.

Changes do not retrospectively remove accrued rights or statutory remedies. The current version and effective date will be displayed on the Platform.

A21. Force majeure

Subject to mandatory law, Efolite is not liable for delay or failure caused by events outside its reasonable control, including load-shedding, widespread telecommunications or hosting outages, fibre cuts, cyber-attacks, natural disasters, civil disorder, strikes, currency or exchange-control measures, governmental action or failures of essential third-party infrastructure, provided Efolite takes reasonable steps appropriate to the circumstances.

A22. Complaints, dispute resolution, governing law and jurisdiction

A user with a complaint against Efolite should first submit it through the designated support or legal channel with sufficient details and supporting documents. Efolite will seek to investigate and respond within a reasonable period.

Nothing in these Terms prevents a consumer from exercising a statutory right to approach the Consumer Protection Commission, another competent regulator or a court, or from seeking urgent relief where appropriate.

Where both parties agree after a dispute arises, they may attempt mediation in Harare or, for an arbitrable commercial dispute, arbitration under the Arbitration Act [Chapter 7:15]. Unless the parties validly agree otherwise, disputes are governed by the laws of Zimbabwe and may be brought before a Zimbabwean court having competent jurisdiction.

No contractual provision in these Terms shortens a statutory prescription period or prevents a remedy that the law does not permit the parties to exclude.

A23. General legal provisions

These Terms and any documents expressly incorporated by reference constitute the agreement between Efolite and the user concerning the Platform. No failure or delay in enforcing a right is a waiver. If a provision is unlawful or unenforceable, it will be read down or severed to the minimum extent necessary and the remainder will continue.

Efolite may assign or transfer its rights and obligations as part of a genuine restructuring, financing or sale of the business, subject to applicable law and data-protection obligations. A user may not transfer an account or rights under these Terms in a way that misleads other users or defeats verification requirements.

Part B — Privacy And Data Protection

B1. Data controller and applicable law

Efolite determines the purposes and means of processing personal information described in this Part and acts as a data controller to that extent. Efolite intends to process personal information in accordance with the Cyber and Data Protection Act [Chapter 12:07], the Cyber and Data Protection (Licensing of Data Controllers and Appointment of Data Protection Officers) Regulations, 2024 (S.I. 155 of 2024), applicable POTRAZ/Data Protection Authority guidelines, and other applicable Zimbabwean law.

Before public launch, Efolite must insert its current data-controller licence number or lawful exemption basis, and the contact details of its Data Protection Officer or responsible privacy contact.

B2. Information collected

• Account data: name, display name, store name, email, mobile number, WhatsApp number, city, suburb, account type and authentication information.

• Seller verification data: national identity or other accepted identity-document information, verification images or documents, mobile verification records, and, where applicable, business registration or licensing information.

• Listing data: product titles, descriptions, price, condition, location, category, quantity, images, delivery information and listing status.

• Communications data: in-platform chats, reports, complaints, support messages and attachments.

• Activity data: searches, saved searches, favourites, listing views, clicks, chat starts, seller analytics events and login events.

• Payment data for Efolite Paid Services: payer name where available, amount, date, method, payment reference, transaction status and proof of payment. Efolite does not ask users to disclose PINs, OTPs or banking passwords.

• Technical data: IP address, browser and device information, session identifiers, logs, security events, approximate location derived from account or network data, and cookie/local-storage identifiers.

B3. Purposes and lawful grounds

Efolite processes information only for specified and legitimate purposes, including account creation, seller verification, publication and search of listings, chat, customer support, fraud and abuse prevention, payment confirmation, analytics, security, moderation, legal compliance and improvement of the Platform.

Depending on the processing activity, Efolite relies on the user’s consent, contractual necessity, compliance with a legal obligation, protection of vital interests, or legitimate interests that are not overridden by the data subject’s rights, as recognised by applicable law.

B4. Seller verification and identity data

Seller identity verification is a condition of publishing listings where Efolite requires it. Identity information is collected for account integrity, fraud prevention, enforcement, safety and compliance purposes. Access must be restricted to authorised personnel and approved processors with a need to know.

Efolite should avoid retaining complete identity-document images longer than reasonably necessary for verification, fraud prevention, legal claims or a legal requirement. Where technically feasible and appropriate, Efolite may retain a verification result, audit reference or masked document information instead of a full image.

B5. Information visible to other users

Because Efolite is a marketplace, certain Seller information is intended to be public, including display/store name, city or suburb, category, listings, product images, verification status and reviews. A Seller’s WhatsApp or contact number may be disclosed where the Seller enables direct contact.

Users should not place private information, identity documents, banking credentials or confidential personal information in public listing descriptions or product images.

B6. Sharing with service providers and authorities

Efolite may share personal information with carefully selected processors and service providers providing hosting, storage, communications, identity verification, analytics, security, payment verification, customer support and related infrastructure, only to the extent reasonably necessary for their functions.

Efolite will maintain written contractual or other legally recognised arrangements with data processors where required, including appropriate confidentiality and security obligations.

Information may also be disclosed to courts, the Zimbabwe Republic Police, POTRAZ/Data Protection Authority, the Consumer Protection Commission and other competent authorities where lawfully required or where lawful disclosure is reasonably necessary to report suspected crime, fraud or a serious safety threat.

B7. Cross-border processing and cloud hosting

Some infrastructure or service providers may process data outside Zimbabwe. Efolite will not transfer personal information across borders unless the transfer is permitted under Zimbabwean law and an adequate level of protection or another lawful safeguard is in place, taking account of applicable guidance from the Data Protection Authority.

B8. Security

Efolite will use technical and organisational measures proportionate to the nature and risk of the data, which may include encryption in transit, access controls, role-based permissions, audit logging, password hashing, secure backups, vulnerability management, staff confidentiality controls, and separation of verification documents from public marketplace data.

No online service can guarantee absolute security. Users are responsible for protecting their own devices and credentials and should report suspected compromise promptly.

B9. Security-breach response

Efolite will maintain an incident-response process. Where a security breach affecting personal data triggers statutory notification obligations, Efolite will notify the Data Protection Authority within the period required by Zimbabwean law and will notify affected users where required or reasonably appropriate.

B10. Automated processing and AI

Efolite may use automated systems to classify listings, detect suspected abuse, improve search relevance, identify duplicate or prohibited listings and produce seller analytics. Where an automated decision would produce legal effects or similarly significantly affect a data subject, Efolite will apply the safeguards required by law, including any required consent or human review.

B11. Retention

Efolite retains personal information only for as long as reasonably necessary for the purpose for which it was collected, the operation and security of the Platform, enforcement, fraud prevention, accounting, tax, legal claims, regulatory compliance and backup integrity.

Indicative periods may be published in Efolite’s retention schedule and may differ by data type. Chat records, listing histories, verification audit records and payment records may be retained longer where they are relevant to a live complaint, investigation, chargeback, fraud pattern, legal claim or regulatory requirement.

B12. Data-subject rights

Subject to applicable law and lawful exceptions, a data subject may request access to personal information, correction of inaccurate information, deletion where information is no longer lawfully required, restriction or objection to certain processing, withdrawal of consent where processing is based on consent, and other rights recognised by Zimbabwean law.

Requests must be submitted through the privacy/support channel. Efolite may verify the requester’s identity and may refuse or limit a request where necessary to comply with law, protect another person’s rights, preserve evidence, prevent fraud or defend legal claims.

B13. Children

Efolite is intended for persons aged 18 years and over. Efolite does not knowingly permit children to create trading accounts. If Efolite becomes aware that an under-18 account was created contrary to these Terms, it may restrict the account and take appropriate steps concerning the data.

B14. Marketing

Efolite may send service messages necessary for account operation. Promotional or direct-marketing messages will be sent only as permitted by law and with any consent required. Where an opt-out right applies, the user may exercise it through the communication or account settings.

B15. Privacy complaints

Privacy questions or complaints should first be sent to the DPO/privacy contact displayed in the Legal Centre. A data subject may also exercise any right to complain to the Data Protection Authority/POTRAZ or another competent authority.

Part C — Seller Terms

C1. Application and independent status

These Seller Terms apply whenever a user creates a Seller account, storefront, listing or purchases a Seller Paid Service. Sellers trade independently and are not employees, agents, franchisees, partners or representatives of Efolite.

C2. Compliance, licences and tax

A Seller is responsible for obtaining and maintaining all licences, permits, registrations, certifications and clearances required for the Seller’s trade and goods, and for complying with applicable consumer protection, competition, standards, product safety, import, customs, tax, exchange-control and sector-specific requirements.

The Seller is responsible for its own invoices, receipts, tax returns and tax obligations. Efolite does not provide tax advice or assume a Seller’s tax obligations unless a law expressly requires Efolite to do so.

C3. Accurate, specific and genuine listings

Each Listing must relate to a specific product the Seller owns or has lawful authority and genuine capacity to supply. The Seller must state a genuine price, the correct condition, location, category and material characteristics.

A Seller must disclose known material defects, accident or flood damage, non-original material components, missing parts, significant repair history where relevant, outstanding finance, encumbrances, restrictions or other facts that would materially affect a reasonable Buyer’s decision.

Photos must fairly represent the actual item unless the Listing clearly identifies an image as illustrative and the use of an illustrative image is lawful and not misleading.

C4. Ownership, authenticity and lawful supply

A Seller warrants that it has lawful title or authority to sell the advertised item, that the goods are not stolen, counterfeit, unlawfully imported, subject to undisclosed finance, recalled, prohibited or otherwise unlawful, and that the Listing does not infringe another person’s rights.

Efolite may require proof of ownership, import documents, dealership authority, serial or device information, vehicle documents, invoices or other evidence reasonably relevant to a listing.

C5. Prices, stock and availability

The price shown must not be a bait price. Hidden compulsory charges are prohibited. Where the Seller states that a price is negotiable, the Listing must still contain a genuine starting price unless Efolite permits another format.

Sellers must keep availability status reasonably current and should promptly mark an item reserved, sold or unavailable. Persistent use of unavailable listings to attract Buyers may be treated as misleading conduct.

C6. Consumer obligations and after-sale responsibility

Where the Consumer Protection Act or another law applies to a Seller’s transaction, the Seller must comply with the Buyer’s non-excludable rights, including applicable rights relating to fair dealing, accurate descriptions, quality, safety, warranties, delivery, returns, refunds, repairs or replacement.

A Seller must not use wording such as "no refund", "no returns" or "no exchanges" where that wording would unlawfully deny a consumer a statutory right.

C7. Buyer contact information

Buyer contact details obtained through Efolite may be used only for responding to a genuine enquiry, completing a transaction, providing lawful after-sale service, preventing fraud, or another purpose for which the Buyer has lawfully consented. Unsolicited marketing, sale of contact lists, harassment or unrelated profiling is prohibited.

C8. Meetings, payment and delivery

Because Efolite ordinarily does not handle the purchase price, the Seller bears the commercial risks of payment arrangements with Buyers, including counterfeit cash, false proofs of payment, reversals and chargebacks. A Seller should independently confirm cleared funds before releasing goods or title documents.

Where the Seller uses a courier or delivery partner, responsibility for packing, instructions, insurance, risk transfer and delivery terms must be agreed between the Seller, Buyer and relevant provider. An Efolite integration does not automatically make Efolite the carrier or insurer.

C9. Boosts and analytics

A boost affects placement or visibility only. Analytics are estimates based on Platform events and may be affected by fraud filtering, ad blockers, network behaviour and technical limitations. Neither feature guarantees enquiries or sales.

C10. Seller reviews

A Seller must not submit or procure fake reviews, offer undisclosed inducements for positive reviews, retaliate against a reviewer, or attempt to suppress lawful criticism through threats. Efolite may remove reviews that are fraudulent, irrelevant, abusive, unlawful or otherwise breach policy.

C11. Seller breach and enforcement

Where a Seller breaches these Terms, Efolite may remove listings, require evidence, restrict publication, suspend the account, cancel boosts associated with unlawful content, preserve records and report suspected offences or regulatory breaches. Refund consequences remain subject to mandatory consumer law and Part F.

Part D — Buyer Terms

D1. Contract with Seller

Unless Efolite expressly identifies itself as the Seller for a particular item, the advertised goods are supplied by the independent Seller and any purchase contract is between Buyer and Seller.

D2. Due diligence before payment

Buyers should verify the Seller, inspect the item where reasonably possible, confirm ownership and supporting documents, test functionality, confirm the final price and delivery terms, and obtain appropriate proof of payment and a Seller receipt.

Buyers should treat advance-payment requests, unusually low prices, pressure to move off-platform immediately, requests for OTPs or banking details, and inconsistent identity or ownership information as potential warning signs.

D3. High-value items

For vehicles, Buyers should independently confirm identity, registration, ownership, chassis or vehicle identifiers, duty/import status, encumbrances and roadworthiness as relevant. For phones, laptops and electronics, Buyers should verify serial or device identifiers where possible, test the item and consider evidence of lawful ownership.

D4. Remedies

A Buyer’s product-related remedies ordinarily lie against the Seller, including any rights provided by the Consumer Protection Act and other applicable law. Efolite may provide records or account assistance where appropriate but does not guarantee recovery of money or compel a Seller to perform unless legally required.

D5. Buyer conduct

Buyers must not harass, threaten, defraud or spam Sellers; misuse Seller details; publish knowingly false reviews; abuse reporting tools; submit false payment proofs; or attempt to purchase prohibited goods.

D6. Reporting suspected fraud or prohibited content

Buyers should report suspected scams, prohibited goods, impersonation, suspicious payment requests or abusive conduct using the in-app reporting tools. A report assists Efolite’s review but does not guarantee a particular result, reimbursement or law-enforcement action.

Part E — Prohibited Products And Conduct Policy

E1. Prohibited categories

Users must not advertise, request, sell, buy or facilitate through Efolite any item or service that is unlawful or prohibited by Efolite policy, including:

• stolen, hijacked, unlawfully obtained or fraudulently acquired goods;

• counterfeit, pirated, replica or trade-mark-infringing goods where the sale or advertisement infringes another person’s rights;

• firearms, ammunition, explosives, prohibited weapons or weapon components where listing is unlawful or contrary to Efolite policy;

• illegal drugs, narcotics, psychoactive substances, drug paraphernalia, unlawfully supplied prescription medicines or unregistered medicines;

• human beings, human remains, organs, body parts or unlawfully traded bodily material;

• sexual services, unlawful pornography, sexual exploitation material or any sexual content involving a child;

• endangered or specially protected wildlife, ivory, rhino horn, pangolin products or protected plants traded contrary to law;

• gold, diamonds, precious minerals or other controlled commodities traded outside lawful licensing and channels;

• unlicensed banking, forex, lending, insurance, securities, investment, pyramid, Ponzi, money-doubling or similar financial schemes;

• forged identity documents, licences, certificates, permits, official number plates, government documents or unlawfully traded public property;

• malware, hacking credentials, stolen accounts, stolen personal information, card data, passwords or access credentials;

• alcohol, tobacco, nicotine or other age-restricted goods sold or advertised contrary to licensing, age or other legal requirements;

• hazardous, radioactive, toxic, recalled or unlawfully supplied chemicals or products;

• goods whose importation, possession, sale or advertisement is prohibited by Zimbabwean law or applicable sanctions or regulatory restrictions; and

• any product, service or content Efolite reasonably prohibits to protect users, comply with law or manage material platform risk.

E2. Restricted categories requiring evidence

Efolite may permit certain regulated or higher-risk categories only where the Seller provides satisfactory evidence of lawful ownership, licensing, registration, importation, certification or compliance. This may include motor vehicles, certain electronics, food, cosmetics, supplements, electrical goods, second-hand goods and other categories designated by Efolite.

E3. Prohibited listing and chat practices

Bait pricing, hidden compulsory charges, keyword stuffing, duplicate spam, fake stock, phishing, advance-fee scams, impersonation, OTP requests, threats, harassment, doxxing, hate speech, unlawful discriminatory content and publication of another person’s private information are prohibited.

E4. Enforcement

Efolite may restrict or remove suspected prohibited content, request proof, preserve relevant records and report suspected illegality to competent authorities. Immediate suspension may be used where reasonably necessary to protect users or evidence.

Part F — Payments, Cancellations And Refunds For Efolite Services

F1. Scope

This Part governs money paid to Efolite for Efolite’s own digital platform services, such as boosts, analytics and paid listing capacity. It does not govern the purchase price of goods sold by independent Sellers.

F2. Information before purchase

Before the user finally orders a Paid Service, Efolite will display the service description, full price or pricing basis, duration where applicable, payment method, material limitations and applicable cancellation/refund information. The user must have a reasonable opportunity to review and correct the order before final submission.

F3. Payment methods and verification

Available payment methods may include EcoCash, bank transfer or authorised payment providers. The user must use the payment reference and amount displayed by Efolite. A Paid Service may remain Pending until payment is verified or confirmed.

Submitting altered, forged or false proof of payment is prohibited and may result in restriction, evidence preservation, recovery action and reporting to competent authorities.

F4. Electronic-transaction cooling-off and refunds

Where the Consumer Protection Act [Chapter 14:44] gives a consumer a right to cancel an electronic transaction without reason within the statutory cooling-off period, Efolite will honour that right. Where a refund is legally due, Efolite will make the refund within the statutory period, subject to reasonable payment verification and anti-fraud controls.

A user may submit a cancellation request through the support channel. A user should identify the Paid Service, transaction reference, payment method and the reason where relevant, although a reason is not required where the law permits cancellation without reason.

F5. Non-performance and technical failures

If Efolite fails to provide a Paid Service materially as described because of a verified Efolite-side technical failure, Efolite may re-perform, extend, credit or refund the affected service as required by law or as otherwise appropriate.

F6. Mistaken, duplicate and reversed payments

Duplicate or mistaken payments will be investigated on request. Efolite may require proof and may refund, credit or apply the payment in accordance with law and the user’s instructions where appropriate.

A fraudulent reversal or chargeback after a service was supplied may lead to account restriction and lawful recovery action. Nothing in this clause prevents a user from disputing an unauthorised or genuinely incorrect payment through lawful channels.

F7. Taxes and charges

Efolite will disclose taxes it is legally required to charge. Bank, mobile-money or payment-provider charges imposed directly on the user may be separate. A Seller remains responsible for taxes arising from the Seller’s own sale of goods.

F8. Receipts and records

Efolite will maintain reasonable transaction records for its Paid Services and may provide electronic confirmations or receipts containing the service, amount, date, method and reference. Records will be retained as required for accounting, tax, audit, fraud prevention and legal purposes.

Part G — Cookies And Similar Technologies

G1. Necessary technologies

Efolite may use strictly necessary cookies, session identifiers and local storage to authenticate users, protect forms, maintain security, prevent fraud and remember essential settings. Blocking these technologies may prevent login, chat, favourites or seller functions from working.

G2. Functional and analytics technologies

Subject to applicable consent requirements, Efolite may use functional and analytics identifiers to remember preferences, understand aggregate Platform use, measure listing performance and identify errors.

G3. User controls

Where consent is required for non-essential technologies, Efolite will provide an appropriate consent mechanism. Users may also control cookies through browser settings, although disabling necessary technologies may impair Platform functionality.

G4. Third-party technologies

Third-party infrastructure, analytics or communications providers may process identifiers in accordance with their own legal obligations and contractual arrangements with Efolite. Efolite does not authorise third parties to sell personal information obtained solely through providing services to Efolite.

Part H — Additional Protections, Evidence And Interpretation

H1. No agency, partnership or endorsement

Nothing in these Terms creates an employment, partnership, franchise, fiduciary or agency relationship between Efolite and a user. A user may not represent that Efolite endorses the user, product or transaction.

Verification, boosts, popularity indicators, search placement, reviews and recommendations are informational or platform features and are not guarantees of identity, solvency, honesty, product quality or transaction success.

H2. Assumption of ordinary marketplace risk — important

USERS ACKNOWLEDGE THAT DIRECT DEALINGS WITH STRANGERS AND SECOND-HAND OR INDEPENDENT SELLERS CARRY RISKS, INCLUDING FRAUD, MISDESCRIPTION, NON-DELIVERY, DEFECTIVE OR STOLEN GOODS AND PERSONAL-SAFETY RISKS.

Users are responsible for reasonable due diligence and safety precautions. This acknowledgement does not waive liability that Efolite cannot lawfully exclude and does not remove statutory rights against a Seller or Efolite.

H3. Platform availability and user backups

Users should keep copies of important listing content, receipts and transaction records. Subject to mandatory law, Efolite is not responsible for loss caused solely by events outside its reasonable control or by a user’s failure to retain records that the user reasonably should have retained.

H4. Recovery of amounts lawfully due

Where a user owes Efolite a lawful and undisputed amount, Efolite may take reasonable recovery steps permitted by law. Interest and legal costs may be claimed only where and to the extent permitted by law or ordered by a competent court.

H5. Electronic records

Efolite may maintain electronic logs, acceptance records, payment records, verification events, messages and audit trails. Such records may be produced in legal or regulatory proceedings subject to applicable rules of evidence. No internal Efolite certificate is conclusive merely because Efolite created it; evidential weight remains subject to applicable law.

H6. Cooperation with authorities

Efolite may preserve and disclose information to a competent authority where lawfully required or where disclosure is otherwise permitted by law for investigation of suspected crime, fraud, illegal content or a serious threat to safety. Efolite will seek to limit disclosure to information reasonably relevant to the lawful purpose.

H7. Electronic contracting

A user’s electronic acceptance, account action and associated audit records may evidence agreement to these Terms. Efolite will maintain a method for users to access the current Terms and, where reasonably practicable, retain or retrieve the version accepted.

H8. Interpretation and priority

These Parts must be read together. A specific Seller, Buyer, Payment or Privacy provision prevails over a general provision only to the extent of a genuine inconsistency concerning that subject. All provisions are subject to mandatory Zimbabwean law, and no clause is interpreted to waive a non-excludable consumer or data-protection right.

H9. Severability and no waiver

If any clause is unlawful, invalid or unenforceable, it will be severed or read down to the minimum extent necessary, and the remaining provisions continue. A delay or indulgence by Efolite does not waive a right.

H10. Domicilium and legal notices

Efolite’s chosen address for formal legal notices is the physical address published in the Legal Centre and completed in the Operator Details section above. A user’s contact information is the information recorded in the account, subject to any mandatory rule governing formal service.

H11. Survival

Provisions that by their nature should survive termination continue after account closure, including accrued fees, intellectual-property rights, lawful content licences, confidentiality, data retention, fraud prevention, legal claims, indemnities to the extent enforceable, liability provisions, evidence, dispute provisions and governing law.

Schedule 1 — Platform-Specific Safety and Compliance Rules

1. Motor vehicles

• Seller must have lawful authority to sell and must disclose known finance or encumbrances.

• Listing must not misstate model, year, condition, mileage, accident history or legal status.

• Efolite may request ownership, registration, import/duty or dealership evidence.

• Buyers remain responsible for independent verification before payment.

2. Phones, computers and electronics

• Seller must not list stolen, blacklisted or unlawfully acquired devices.

• Material faults, locks, missing parts and material non-original components must be disclosed.

• Efolite may request serial/device identifiers or proof of purchase where risk indicators justify it.

3. Fashion and branded goods

• Counterfeit or trade-mark-infringing goods are prohibited.

• A Seller describing goods as authentic must have a reasonable basis for that representation.

• Efolite may request invoices or other authenticity evidence for high-risk brands or repeat complaints.

4. Repeat offenders and linked accounts

Efolite may use lawful technical, account, payment and verification signals to identify accounts reasonably believed to be linked to a previously suspended user. A user must not create or operate another account to evade lawful enforcement.

5. Fraud prevention holds

Where reasonable fraud indicators exist, Efolite may temporarily hold publication, verification, account changes or Paid Service activation while completing proportionate checks. Efolite should document the reason for the hold and resolve it within a reasonable time.