1. Introduction
Welcome to Property267 Academy (“we,” “us,” “our,” or “Property267”). Your privacy is important to us. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use our website p267.academy (the “Site”) and any related services (together, the “Services”).
By using the Site or Services, you agree to the collection and processing of your personal data as described in this Privacy Policy.
We are committed to the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality, and accountability.
3. What Data We Collect
We collect personal data from you when you interact with our Site or Services, for example:
- Contact Information: name, email address, phone number.
- Account Information: username, password (if you register).
- Payment Information: (if applicable) payment method, billing address, transaction details.
- Usage Data: information about how you use the Site and Services (e.g., pages visited, time spent, IP address, browser type).
- Communications: any messages, feedback, or correspondence you send to us.
- Other Data: any other personal data you actively provide, such as in forms or surveys.
4. How We Use Your Data
We use your personal data for the following purposes:
- To provide and maintain the Services;
- To process your registration, and manage your account;
- To process payments (if relevant) and send invoices;
- To respond to your inquiries, questions, or support requests;
- To send you updates, newsletters, and marketing communications (only if you consent, where required);
- To analyze and improve the Site and Services (for example, via usage data);
- To comply with legal obligations.
5. Legal Basis for Processing
We rely on the following lawful grounds (as per the Data Protection Act 18 of 2024) to process your data:
- Consent: for any optional processing (e.g., marketing communications).
- Contractual necessity: processing necessary for performance of a contract with you (e.g., providing paid courses).
- Legitimate interests: where appropriate (for example, to improve the Service), provided these do not override your rights.
- Legal obligation: to comply with applicable laws or regulatory requirements.
6. Data Sharing and Disclosure
We may share your personal data in the following situations:
- With third-party service providers who help us operate the Site (e.g., payment processors, hosting providers, analytics).
- With our partners or affiliates, where necessary to provide the Services.
- If required by law or legal process (e.g., to comply with a court order).
- In connection with a merger, acquisition, or sale of all or part of our business (we will ensure buyer protects your data).
- With your consent, where we ask for it.
We will not sell your personal data to third parties.
7. International Transfers
If we transfer your personal data outside Botswana (for example, to service providers abroad), we will ensure appropriate safeguards are in place, as required under the Data Protection Act, to protect your data.
8. Data Retention
We retain your personal data only for as long as necessary:
- To fulfil the purposes for which it was collected;
- To comply with legal, regulatory, or accounting obligations;
- To resolve disputes and enforce our agreements.
When your data is no longer needed, we will securely delete or anonymise it.
9. Security
We implement reasonable and appropriate technical and organizational security measures to protect your personal data from unauthorized access, disclosure, loss, or alteration. Access to personal data is limited to those employees, contractors, or third parties who need to know the data to perform their roles.
10. Your Rights
Under Botswana’s Data Protection Act, you have a number of rights as a “data subject,” including:
- Right of access: you can request access to the personal data we hold about you.
- Right to correction: you may ask us to correct or update inaccurate or incomplete data.
- Right to deletion (“right to be forgotten”): in certain circumstances, you may request deletion of your personal data.
- Right to restrict processing: you may ask us to limit how we use your data.
- Right to object: you may object to our processing under particular conditions (e.g., direct marketing).
- Right to data portability: where technically feasible, you may request your data in a structured, commonly used, machine-readable format.
- Right to withdraw consent: where we process based on consent, you may withdraw that consent at any time.
- Right to lodge a complaint: with the Information and Data Protection Commission (or relevant authority) if you believe we are not respecting your rights.
To exercise these rights, please contact us using the details in the “Contact Us” section below.
11. Cookies and Tracking
We use cookies and similar tracking technologies (e.g., web beacons) to:
- Allow the Site to function properly;
- Analyze usage of the Site and improve our Services;
- Personalize content;
- Support marketing efforts (if you consent).
You can control cookie settings via your browser, but disabling cookies may affect how well the Site works for you.
12. Children’s Data
Our Services are not specifically directed to children under 18. We do not knowingly collect personal data from minors without parental consent. If we learn we have collected data from a child under 18 without appropriate consent, we will take steps to delete that data.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time (for example, when the law changes or as our Services evolve). When we make changes, we will update the “Effective Date” at the top, and where appropriate, notify you (for example, via email or a notice on the Site).