Privacy Notice

Where registration with the Information and Data Protection Commission is required of us, our registration reference is [Data protection registration reference - to be inserted].

You may contact us about this Notice or about your personal information using the contact details set out in the "How to Contact Us and Exercise Your Rights" section below.

This Notice does not govern the practices of third parties who receive your information from us and then use it for their own purposes, such as an employer to whom your job application is forwarded, or a property lister or agent to whom your enquiry is sent. Once those recipients receive your information they act as independent controllers and are responsible for their own handling of it under the Data Protection Act, 2018.

Where our website links to external websites or services, this Notice does not apply to those websites, which are governed by their own privacy notices.

Directly from you, when you create an account, place an order or check out as a guest, complete an intake form or upload a document, send us a service request, contact message or property enquiry, apply for a vacancy, or post a property listing or vacancy.

Automatically, through strictly-necessary cookies and standard server logs generated as you use the website, which are needed to keep you signed in and to operate and secure the platform. See the "Cookies" section below and our Cookie Policy.

From third parties, such as an employer who posts a vacancy you apply to, or a property lister or agent whose listing you enquire about, and from our service providers, our payment gateway and the regulatory authorities involved in performing a service for you.

To create and administer your account, process and fulfil your orders, perform the services you have requested, and respond to your enquiries and messages - on the basis that this is necessary for the performance of a contract with you, or to take steps at your request before entering into a contract.

To process and forward your job application to the relevant employer, and to forward your property enquiry to the relevant lister or agent - on the basis of the consent you give when you choose to submit the application or enquiry for that very purpose, supported by our legitimate interest in operating the vacancy board and property marketplace.

To meet our legal, regulatory, tax and record-keeping obligations, including filings with the relevant authorities required to perform a service and the retention of transaction and accounting records - on the basis of compliance with a legal obligation to which we are subject.

To secure and improve the platform, prevent fraud and misuse, maintain our audit trail, send service-related acknowledgements and notifications, and operate our AI assistant - on the basis of our legitimate interests in running a safe, reliable and efficient service, balanced against your rights and interests.

To send you optional direct-marketing communications, where you have chosen to receive them - on the basis of your consent, which you may withdraw at any time.

Where the processing of certain personal information is necessary to enter into or perform a contract with you, or to comply with a legal or regulatory requirement, providing that information is a condition of our being able to supply the relevant service. If you do not provide it, we may be unable to create your account, accept your order, or perform the service concerned.

Uploaded documents are stored in private, access-controlled storage. They are never made publicly accessible.

Access to these documents is provided only through short-lived signed links that expire after a limited period, and access is restricted to authorised personnel and processors who need it to perform the service (a least-access approach).

We use these documents only for the purpose for which you provided them - to perform the requested service and to meet any associated legal or regulatory filing requirement - and we retain them only as described in the "Retention of Your Information" section below.

Recruitment: when you apply for a vacancy, your application - including your name, contact details, CV and cover letter - is shared with the relevant employer. That employer becomes a recipient and an independent controller of your application and is responsible for its own use of it. We forward your application and send you an automated acknowledgement; the employer's own privacy practices then apply to its handling of your data.

Property enquiries: when you enquire about a property, your enquiry - including your name, contact details and message - is shared with the lister or agent who posted that property, so that they can respond to you. That lister or agent becomes a recipient and an independent controller of your enquiry and is responsible for its own use of it.

Listings and vacancies are reviewed by us before they are published and may be declined, edited for compliance, or removed at our discretion, as described in our Acceptable Use Policy and Terms & Conditions.

Information you choose to include in a published listing or vacancy (for example a contact name or email for applications) will be visible to other users of the platform. You should not include personal information in such content that you do not wish to be made public.

Your card or payment-instrument details are entered on, and handled by, the payment gateway. We never receive or store your full card or payment-instrument data on our systems.

We receive and store only the transaction outcome associated with your order - such as the gateway transaction reference, the payment status and the timestamp of payment - which we use to confirm and fulfil your order and for our financial records.

Orders are re-priced on our server by the service code (SKU) at checkout, so the amount charged is the price set by The Secretary and not any amount supplied by your browser. Guest checkout, using your name, email address and telephone number, is permitted.

Nothing in this Notice or in our handling of payments affects the statutory rights you may have as a consumer under the Consumer Protection Act, 2018, which are preserved and not excluded.

We do not use advertising cookies and we do not use third-party analytics or tracking cookies.

Because these cookies are essential, disabling them in your browser will prevent you from signing in and from using parts of the platform. Further detail is set out in our Cookie Policy.

The assistant uses content embeddings (a retrieval technique) drawn from our own service and informational content to find relevant material and help formulate answers. It is not used to make decisions about you.

We do not carry out any solely-automated decision-making that produces legal effects concerning you, or that similarly significantly affects you. Decisions about your matters are made with human involvement.

We require our service providers to process personal information only on our instructions and to keep it secure. We do not sell your personal information.

We may also disclose personal information where we are required to do so by law, by a court order, or by a competent authority, or where disclosure is necessary to establish, exercise or defend legal claims, or to protect the rights, safety or property of any person.

Where personal information is transferred outside Botswana, we take reasonable steps to ensure that it remains protected to a standard consistent with the Data Protection Act, 2018, including by engaging reputable providers and putting appropriate contractual and technical safeguards in place. We make any such transfer only where it is necessary for the purposes described in this Notice and on a lawful basis under that Act.

This section is provided so that you are informed of such cross-border processing. If you would like further information about the safeguards we apply, you may contact us using the details below.

Account and profile information is retained for as long as your account remains active and for a reasonable period afterwards.

Order, payment and transaction records, and records relating to services performed, are retained for the period required by the applicable tax, accounting and statutory record-keeping laws of Botswana.

Intake answers and uploaded identity documents are retained for as long as needed to perform and support the service and to meet any associated regulatory or record-keeping requirement, after which they are deleted or anonymised.

Service requests, contact messages and property enquiries are retained for as long as needed to handle and follow up on them and to maintain our records of the interaction.

Recruitment applications are retained for the duration of the relevant recruitment process and a reasonable period afterwards; the recipient employer applies its own retention to the copy it receives.

Our audit and operational records are retained for governance, security and compliance purposes for as long as reasonably required.

Where we are legally required to retain certain information, we will not delete it on request until the applicable retention period has expired.

These measures include passwordless sign-in (so that no passwords are stored), encrypted connections, private and access-controlled file storage, time-limited signed links for access to documents, access restricted to authorised personnel on a need-to-know basis, and an audit trail of key events.

While we take reasonable steps to protect your information, no method of transmission or storage is completely secure. You are responsible for keeping access to your email account and sign-in link secure, since sign-in is by a magic link sent to your email.

If a personal-information breach occurs that affects your personal information, we will assess it and respond in accordance with the Data Protection Act, 2018, including notifying the Information and Data Protection Commission and affected individuals where, and to the extent, the Act requires.

We would, however, appreciate the opportunity to address your concerns before you approach the Information and Data Protection Commission, so we encourage you to contact us first.

We may need to verify your identity before acting on a request, and certain rights are qualified - for example, we may decline a deletion request to the extent that we are legally required to retain the information concerned.

We will only send you direct-marketing communications where you have chosen to receive them. You can opt out of marketing at any time, using the unsubscribe mechanism in the message or by contacting us, and we will stop sending it.

We do not knowingly collect personal information from a child except where it is provided by a parent or guardian, or as part of a service lawfully requested on the child's behalf. If you believe a child has provided us with personal information without appropriate authority, please contact us so that we can take appropriate action.

We are not responsible for the privacy practices or content of those third-party websites. We encourage you to review their own privacy notices before providing them with your personal information.

When we make changes, we will post the updated Notice on this page. Where a change is material, we will take reasonable steps to bring it to your attention. Your continued use of the platform after an update takes effect indicates your awareness of the revised Notice; the update does not, of itself, constitute your consent to any processing that requires consent under the Data Protection Act, 2018.

Please tell us which right you wish to exercise and provide enough detail for us to locate your information and verify your identity. We will respond within the period required by the Data Protection Act, 2018.

If you are not satisfied with how we have handled your personal information or a request, you have the right to lodge a complaint with the Information and Data Protection Commission of Botswana.