Privacy Statement

This Website Privacy Statement applies to the personal data of all website visitors, existing and prospective customers, existing and prospective employees, and other individuals who provide their Personal Data to Mascom Wireless, and all such individuals are hereinafter referred to as “Data Subject”.

This Website Privacy Statement is intended to inform you on how we gather, define, and use Personal Data that you provide to Mascom Wireless through online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to https://www.mascom.bw/ (hereinafter the “website” or “platform”).

This Privacy Statement will also help you understand:

1. The nature of the personal data we collect from you.
2. The sources from where your data is collected (In cases where personal data is not directly collected from you).
3. The way your data is collected.
4. The purpose of collecting your data.
5. The way your data is stored, used, and processed.
6. The Data Subject Rights that can be exercised by you.
7. The process to contact Mascom Wireless for any issues regarding the collection or use of your personal data or to exercise rights of the Data Subject.

4.1 We collect this information from the following sources:

1. Basic Information: To access certain features of the Platform, such as to recharge your mobile SIM, buy products from our platform, etc., you will need to create an account and register with us. We ask for basic information which may include your Full Name, MSISDN (Mobile Station Integrated Services Digital Network), National ID Card, Email ID, Date of Birth (DOB), Gender, Full Address, Bank Domain, and Visa Details.
2. Information when you communicate with us: When you voluntarily write to us with a question or to ask for assistance, we will keep that correspondence, and the Email Address/ Postal Address, for future reference; this may also include any Phone/ Mobile Numbers if you have provided us the same as part of your communication either in writing (emails included), over a phone call or otherwise.
3. Information when you register for different events, or other outreach efforts by us: When you register with us for our outreach efforts, we ask for basic information which may include your Full Name, Email ID, Gender, Full Address, Date of Birth, and Phone/ Mobile Number.

4.2 Information we collect automatically:

1. Device and Log information: When you access our Platform, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Platform — for example, when you create or make changes to your account information on the Platform.
2. Usage information: We collect information about your usage of our Platform. We also collect information about what happens when you use our Platform (g., page views, clickstream data when you visit any of our website(s), support document searches, features enabled for your account, interactions with other parts of our Services) along with information about your Supported Device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to provide our Platform to you, get insights on how people use our Platform so that we can make our Platform better, and understand and make predictions about user retention and interest showcased.
3. Information from Cookies & other technologies:We may collect information about you through the use of cookies and other similar technologies. A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns.

4.3 Information we collect from other sources:

1. We collect relevant information from third parties/ vendors/ referral(s) which may include Full Name, Email ID, and Phone/ Mobile Number.
2. Recording of your image via CCTV cameras when you visit our branches.
3. Your mobile phone location (to determine the closest Mascom Wireless ‘s network connection point to enable connection to our network to make calls and/or access our mobile internet services).

We may collect and use personal information from you or from the category of third parties identified in this Privacy Statement, for one or more of the following purposes:

1. To verify your identity
2. To assess and process your application(s) /request(s) for our Products and/or Services
3. To provide you with the Products and/or Services you have requested
4. To administer and manage the Products and/or Services we provide you (including charging, billing, facilitating payments and collecting debts)
5. To investigate and resolve any service issues, billing queries, complaints, or other enquiries that you submit to us regarding our network, Products and Services with our customer relations teams
6. To assess and/or verify credit worthiness
7. To detect and prevent fraudulent activity
8. To manage our networks
9. To keep in contact with you and provide you with any information you have requested
10. To engage in business transactions in respect of Products and/or Services to be offered and provided to you
11. To establish and better manage any business relationship we may have with you
12. To process any communications, you send us (for example, answering any queries and dealing with any complaints and feedback)
13. To help us monitor and improve the performance of our network, Products and Services, our customer relations teams and service providers and the Site and to make these more efficient
14. To maintain and develop our business systems and infrastructure, including testing and upgrading of these systems
15. To manage staff training and quality assurance
16. To notify you about benefits and changes to the features of our Products and/or Services
17. To determine how can we improve services to you
18. To produce data, reports and statistics which shall be anonymized or aggregated in a manner that does not identify you as an individual
19. To investigate, respond to, or defend claims made against, or involving Mascom Wireless
20. To conduct marketing activities (for example, market research)
21. To maintain records required for security, claims or other legal purposes
22. To comply with legal and regulatory requirements
23. For any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities; or
24. For any other lawful business purpose as may be necessary.

We may combine voluntarily provided and automatically collated personal data with general information or research data we receive from other trusted sources. For example, our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our website as a medium for solicit information.

We will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis, which allows Mascom Wireless to do so.

Please note that we may process your personal data without knowledge or consent, in compliance with the above rules, where it is required or permitted by law.

Please note that if you wish to opt out of any such processing activities for purposes other than the original purpose, you can reach out to us by writing to us at <email ID>.

We may use your email address to send our newsletters and/or marketing communications. If you no longer wish to receive these communications, you can opt out by following the instructions contained in the emails you receive or by sending us an SMS at “insert phone number”.

We will send you announcements related to the Service(s) on occasions when it is necessary to do so. For instance, if our Service is suspended for maintenance, we might send you an email.

We do not collect or process personal data of individuals below the age of 18.

We use “cookies” to collect information about you and your activity across our website. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.

We uphold the principle of retaining your personal information only for the duration necessary to fulfil its intended purpose, as outlined in our privacy statement. For instance, if you have provided personal information while creating an account, we may retain this data as long as your account remains active on our system. If your personal information is no longer required for such purposes, we will promptly delete it or anonymize it by removing any identifiable details.

Nevertheless, there are certain circumstances where we may need to retain your personal information for legitimate business or legal reasons or provide substantial evidence of record. These may include obligations related to compliance with applicable laws, accounting or reporting requirements, statistical analysis, which also includes case studies etc. Additionally, certain data may be retained for extended periods to fulfil purposes such as ensuring security, preventing fraud and abuse, or maintaining financial records.

Per Data Protection Act (DPA), 2024, Data Subjects have certain statutory rights in relation to their personal data:

1. Right to Access Information about Personal Data: The right to obtain confirmation of whether personal data is being processed and, if so, to access that data.
2. Right to Withdraw Consent: The right to withdraw consent given for the processing of personal data at any time.
3. Right to Rectification: The right to request the correction or amendment of inaccurate or incomplete personal data.
4. Right to Erasure: The right to request the deletion or removal of personal data under certain circumstances. Please note that this right is subject to statutory limitations.
5. Right to Object Direct Marketing: The right to stop their data being used for direct marketing.
6. Right to Restriction of Processing of Data: The right to obtain from the data controller restriction of processing under certain circumstances.
7. Right to Data Portability: The right to receive personal data from a data controller in a structured, commonly used, machine-readable format and to transmit it to another data controller, provided that the processing is based on consent or contract and is conducted by automated means, with direct transmission where technically feasible.
8. Right against Automated Decision Making, including Profiling: The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects the data subject.
9. Right to Grievance Redressal: The right to easily access grievance resolution mechanisms against any action or failure on the part of Mascom Wireless related to their responsibilities concerning the personal data.
10. Right to lodge complaint with Commission: The right to file a complaint with the Commission if the data subject believes that the processing of their personal data violates this Act.
11. Right to compensation and liability: Any individual who experiences material or non-material harm due to a violation of this Act has the right to receive compensation from the data controller or data processor for the damage incurred.

When responding to requests for personal data, Mascom will communicate with the Data Subject in a reasonable period of time depending on the nature of the DSR request made.

At Mascom Wireless, the security of your data is of utmost importance. We take extensive measures to safeguard the information you provide, ensuring protection against loss, unauthorized access, disclosure, and misuse. These measures are designed to align with the sensitivity of the data we collect, process, and store, as well as the current advancements in technology.

However, it is important to note that due to the inherent nature of communication and information processing technology, we cannot guarantee absolute security against external intrusions while transmitting data over the Internet or when it is stored in our systems. Additionally, when you click on a link leading to a third-party website, please be aware that you will be leaving our site, and we do not have control over or endorse the content found on such third-party sites.

If you become aware of any suspected data breach involving our systems, please report it immediately “here [link of the incident reporting form]” or to our Data Protection Officer to ensure prompt investigation and resolution.

We may disclose personal information to:

1. Our parent and subsidiary company, affiliate, or collaborated institutions
2. Third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, maintenance or problem-solving providers, professional advisors, lawyers, insurance partners/service providers, auditors, payment systems operators, and financial institutions
3. Our employees and senior management of our Company
4. Our existing or potential agents or business partners
5. 03^rd Party Risk Management via Advisory Partner lobby
6. Regulatory authorities in the event you fail to pay for goods or services we have provided to you
7. Government agencies
8. Companies and/or organizations that act as our agents, contractors, service providers and/or professional advisers
9. Companies and/or organizations that assist us in processing and/or otherwise fulfilling transactions and providing you with Products and/or Services that you have requested or subscribed for
10. Our business associates and other parties for purposes that are related to the purpose of collecting and using your personal information
11. Other parties in respect of whom you have given your express or implied consent
12. Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise, or defend our legal rights
13. Third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
14. Third parties to collect and process data
15. An entity that buys, or to which we transfer all or substantially all our assets and business
16. For any other lawful business purpose.

It may be necessary for us to transfer your personal information outside Botswana if any of our service providers or strategic partners (overseas entities) who are involved in providing part of our Products and/or Services are in countries outside Botswana or if you use the Products and/or Services from a country other than Botswana (for example, international roaming). Per DPA, we shall only transfer your personal data to third countries basis an adequacy decision by the Data Protection Commission and/ or subject to ensuring appropriate technical and organization safeguards.

You consent to us transferring your personal information outside Botswana in these instances. Rest assured, we shall take reasonable steps to ensure that any such overseas entities are contractually bound not to use your personal information for any reason other than to provide the Products and/or Services they are contracted by us to provide and to adequately safeguard your personal information.

You consent to us using your personal information to provide you with details about our services and products, as well as those from third parties, which we believe may interest or benefit you, unless you have specifically requested otherwise. In certain circumstances, we may share your personal information with our selected merchants and strategic partners.

However, we will only disclose your personal information to these merchants and partners if you have subscribed to services or products that necessitate such disclosure and/or have provided your consent. You may, at any point, restrict or opt out of processing of your data for direct marketing services.

If you have any questions about this Statement, wish to exercise your rights, have concerns about the privacy of your data or any privacy-related grievances in respect of the Website, then please write an SMS to the Data Protection Representative (DPR) of Mascom Wireless at “insert phone number”.

At our discretion, we may change our privacy statement to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes, and inclusion/ exclusion of target audience and stakeholders. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this Website Privacy Statement.
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If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.