RGL PRIVACY POLICY

1. INTRODUCTION

This privacy policy is issued by and on behalf of Rabasha Golekanye Lawyers (“RGL”).

2. PURPOSE

RGL is committed to protecting your personal data. We promise to use your personal data only in ways that are compatible with this privacy policy.

  • RGL is committed to protecting your privacy and recognizes its obligations to collect and process your Personal data in accordance with the provisions and principles in the Data Protection Act, 2018 (“the DPA”) and any other applicable law when you use this website. We understand the importance of protecting your personal data and as such we subscribe to the principles, outlined in section 30 of the DPA
  • The aim of this privacy policy is to give you notice and inform you how RGL collects and processes your personal data through your use of this website.
3. INTERPRETATION
The use of terms like ‘we’, ‘us’, or ‘our’ must be understood as references to RGL and its affiliated structures. The privacy policy set out herein includes any additional documents incorporated by reference (“privacy policy”), and applies to any person who uses, accesses, refers to, or views any part of this website (“you” or “your”, including cognitive terms Cookies (browser or tracking cookies) are small, often encrypted text files, located in browser directories which are placed on your device when you visit a website. They are used to help users navigate their websites efficiently and perform certain functions.

Data means data and vice versa.
Process of personal data (and processing) means and includes the collection, recording, organization, storage, alteration, retrieval, gathering, disclosure, dissemination, erasure, destruction, blocking etc. of personal data.

  • This privacy policy is not to be read and interpreted in isolation – it is to be read in line with the terms of use located on our website, and any other further notices which we may post on our website from time to time.
  • This privacy policy must be interpreted as supplemental to other notices located on this website, and must not be understood as overriding.
4. WHAT IS PERSONAL DATA (Personal data)?

  • Personal data (which includes “sensitive personal data”) includes data that identifies or is specific to any person. It includes, a person’s name, address, age, telephone number, e-mail address, online identifier; race and others. And includes, factors specific to a person’s physical, physiological, mental, economic, cultural or social identity.

Sensitive Personal data is personal data that relates to a person’s: ethnicity; gender; age; religious or philosophical beliefs; trade union membership; health; sexual life; filiation; financial data; criminal history; genetic data; biometric data and personal data of minors

5. WHAT PERSONAL DATA DO YOU COLLECT AND HOW?

The manners and form and amount of data collected depends on the purpose for which it is collected. Data collected may be personal data generally or sensitive personal data. We collect personal data from various sources which include the following:

Business
We collect personal data about prospective clients, owners, and directors as part of business development initiatives and our business acceptance processes.

Legal services and marketing
We collect personal data you provide to us directly, or, for example, through your use of our Apps or other online services, and from your dealings with us, our clients and from third parties.

Recruitment
We collect personal data from you if you apply to us for work or from recruitment agencies or recruitment websites and apps or other third parties.

  • Every computer connected to the internet is given a domain name and a set of numbers that serve as its IP address. When you visit a page on any website within our network, our web servers recognize your domain name and IP address.
  • RGL automatically receives your IP address, cookie data or data on any web pages that you review and records this data onto our server. This data is gathered to be used in the process of customizing our website contents.
  • We use this data to examine our traffic in aggregate, but do not collect and evaluate the data of individuals.
  • When RGL collects the personal data you submit to this website, RGL clearly indicates its purpose, and so does within its necessary limitation.
  • If you prefer not to provide your personal data to RGL, you can deny the submission on your own decision. However, please note that by denying your personal data submission, you may not be able to utilize some of the services on this website that require the submission of your personal data
  • We also collect, use and share aggregated data, such as statistical data, for any purpose deemed necessary by RGL or its affiliated structures.
  • Aggregated data refers to data that is incapable of revealing your personal data and is used for the purposes of answering various market- related questions. We undertake to never mass your personal data, i.e., data which can reveal your exact identity, with aggregated data.

6. HOW WE USE YOUR PERSONAL DATA

  • RGL will and only uses your personal data for the specific purpose for which it was originally or primarily collected. We will inform you beforehand if an occasion arises where we will need to use your personal data beyond the purpose originally collected for. If you do not agree, you can deny the usage of your personal data.
  • We will treat your personal data with the utmost confidentiality and will only share your data with our officers, directors, members, employees, agents and services providers required to be given access to the data.

The purposes for which personal Data which we may collect may be used for, amongst others, are the following:

  • The provision of legal advice/services and response to inquiries.;
  • Management of our business operations and administration of our client relationships;
  • Enhancing the functionality of our website.;
  • Fraud and security monitoring purposes
  • Data analysis, to improve the efficiency of our Services and identify trends;
  • Auditing internal process for proper functioning;
  • To provide relevant marketing materials; and
  • Compliance with legal and regulatory obligations.

To evaluate and consider individuals for employment and manage on-boarding procedures.

  • We may aggregate and/or anonymize Personal Data so it is no longer considered Personal Data. We do this to generate other data for our use, which we may use and disclose for any purpose.
7. RESTRICTED DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

  • RGL does not disclose, transfer or lend the personal data you submit to our website to any third parties, save:
  • when we obtain your permission;
  • when we find it necessary to disclose it to RGL-affiliated companies, subsidiaries, distributors or agencies in order to answer any inquiries from you;
  • when we find it necessary to disclose data to other companies or persons with which RGL contracts, that have confidentiality agreements with RGL, in order to implement what was indicated to you;
  • when such data is required to protect our legitimate business interests, such as the processes of recording-keeping or debt collection;
  • when such data is processed into non-personally-identifiable data as statistical data;
  • in cases of urgent circumstances to protect people’s life, body or property.
  • in cases of being required by law to disclose such data or to conform to the edicts of the law or comply with a legal process served on RGL;
  • to protect and defend the rights or property of the RGL network of websites.
  • to identify people who may be violating the law, a legal notice or the rights of third parties; and
  • to co-operate with the investigation of purported unlawful activities.
  • We use reasonable precautions to keep the data disclosed to us secure. When you submit your personal data on this website, we will use SSL (Secure Sockets Layer) or other equivalent methods in order to protect the transmission of data.

Accordingly, you submit your personal data at your own risk and we are not responsible for any breach of security or the actions of any third parties that receive such data.

  • Be aware that the security measures we take cannot be guaranteed to be safe from intrusion by all unauthorized persons and RGL can take no

    responsibility for unauthorized, unintended access to your personal data by third parties.

    8. TRANSFER OF DATA OUT OF BOTSWANA

    We will only transfer personal data out of Botswana in accordance with the Data Protection Act and or any applicable law.

    We will not transfer personal data to a country that has not been that is allowed by the Minister.

    9. INFORMATION THAT YOU ARE ENTITLED TO AND YOUR RIGHTS BEFORE/AT TIME OF DATA COLLECTION

    We RGL are the data controllers, our principal place of business (is herein).
    We will inform you the purpose of the processing for which your personal data is required.

    You have the right to object to the collection or processing of your personal data if it obtained for direct marketing.

    You have the right to be informed of the intended recipients or categories of recipients of your data.

    You have the right to be informed whether your reply to any question that you may be asked is obligatory or voluntary, and possible consequences of your failure to reply.

    You have the right to access, rectify, where applicable, the right to delete your data.

    10. YOUR RIGHT TO: KNOW; ACCESS; RECTIFICATION; ERASURE; RESTRICTION OF USE AND OBJECT

    You have the right under the law: to request as us to confirm if we have your personal data; to be informed about your personal data; if your request is refused to be given reasons for such; to challenge our refusal to confirm or

    refusal to inform you about your personal data by lodging a complaint with the Commissioner of the Data and Data Protection Commission. You also the right to challenge your personal data with the Commissioner and if successful, you have the right to have the personal data deleted; the rectified; the completed or amended. You may also have rights to object to your Personal Data being used, to ask for the transfer of Personal Data you have made available to us and to withdraw consent to the use of your Personal Data.

    11. MINORS (UNDER 18 YEARS OLDS) AND PROTECTION OF THEIR PERSONAL DATA

    • We are committed to protecting personal data of any visitors who are minors, are under the age of 18 years. Such data is sensitive personal data.
    • RGL recommends guardians to review the website when website visitors under the age of 18 access this website.
    • If you are under the age of 18, please provide your personal data with the consent of your parent/ guardian.
    • We will treat personal data of minors in accordance with the heightened protection required by the law.
    12. COOKIES AND STORAGE INFORMATION

    • RGL or its advertisers may from time to time make use of cookies. Cookies allows a web-server to collect information about the User, amongst other purposes, to identify which areas of RGL’ network of websites you have visited or customized, so the next time you visit, those pages are easily accessible..
    • Our advertisers may also use cookies to ascertain how many times you’ve seen an advertisement. We and our advertisers may use this data to personalize the content, banners and promotions that you see on our website..
    • You can set up the browser not to receive new Cookies, to arrange a warning to appear on the screen when Cookies are received or to void the cookie functions (please refer to help in your browser’s toolbar).
    • It will solely be on the discretion of the User to either accept or refuse cookies through the settings on its internet web browser or alternatively use a programme or application to control the use of cookies by any website.
    • If you choose not to accept these cookies, your experience at our website may be diminished and some features may not work as intended.
    • We also use Google Analytics, which uses cookies and similar technologies to collect and analyse data about the use of services and report on activities and trends. You can learn about Google’s practices here.
    13. OTHER DATA WE MAY REQUEST

    • We may request your email or postal address or phone number for the purpose of conducting a survey or to provide additional services.
    • Whenever we request your identity, we will indicate the purpose of the enquiry before the data is requested.
    • We maintain a strict “no-spam” policy – we will not give your email address to a third party without your consent. In addition, we will not send you an email that you have not agreed to receive, although we may from time to time send you an email announcing new products and services.
    • Wherever we collect data, we make an effort to include a link to this privacy policy on that page.
    14.THIRD-PARTY WEBSITES AND HYPERLINKS

    • The website may contain links to other websites. We are not responsible for the privacy policies adopted by these websites.
    • The inclusion of any links on our website does not imply recommendation or endorsement by us or any of our affiliates. Use of or reliance by you of any links on the website is at your own risk.
    • You are prohibited from creating any links to the website without the prior written consent from RGL.
    15.PROMOTIONAL EMAILS

    • In the event that you elect to be added to RGL’ mailing list or subscribe to a RGL newsletter we use the data we collect to better meet your needs by sending you data on latest news and new services which may be of interest to you.
    • From time to time we will email you data about us or our affiliates, if you do not wish to receive this e-mail you can opt out by unsubscribing or e- mailing us. Please refer to our contact e-mail addresses below.
    16.FRAUDULENT EMAILS

    • RGL will never request you to provide personal data such as credit card or debit card or banking details, ATM Pins, password etc., or ask you to verify or confirm your information by clicking on a link.
    • In the event that you receive an unsolicited e-mail that appears on the face of it to be from RGL which requests you to provide personal data such as credit card or debit card or banking details, ATM Pins, password etc., or asks you to verify or confirm your information by clicking on a link, it is not from RGL.
    • RGL would never ask for such information via an email, we strongly urge that you do not respond to these emails and does not click on any links to such an email.
    • Responding to such an email places your personal data at risk.
    • RGL shall not be held liable from any consequences arising from such fraudulent emails.
    17.WHAT ELSE SHOULD I KNOW ABOUT MY PRIVACY WHEN ONLINE?

    • We do not share with any of the websites to which we link any of the personal data you provide to us, although we may share aggregate data with such websites, such as data on how many people use our website. Please check with those websites to determine their privacy policies.
    • Keep in mind that whenever you voluntarily disclose personal data online, that data can be collected and used by others. In short, if you post personal data that is accessible to the public, you may receive unsolicited messages from other parties in return.
    • Ultimately, you are the one responsible for maintaining the secrecy of your personal data. Please be careful and responsible whenever you’re online.
    18.YOUR CONSENT TO THIS AGREEMENT

    • By using our websites, you consent to the collection and use of data by RGL as specified above.
    • We reserve the right without notice to change, modify, amend, add to or remove portions or whole parts of this Privacy Policy from time to time permanently or temporarily.
    • All updates and/or amendments to this Privacy Policy are effective on the date we publish them on the website.
    • The responsibility is on you to determine whether any updates and/or amendments have been made to this Privacy Policy.
    • Any major policy revisions will be posted on our website in an easy- to-find and timely manner.
    • The continued use of the website by you after the updates or amendments have been made to the Privacy Policy has the effect of you agreeing to be bound by the new terms of the Privacy Policy.
    19.INQUIRES, CORRECTIONS OR DELETIONS OF PERSONAL DATA

    • If you would like to inquire, make any corrections or request deletion of your personal data, please place your request by clicking on Contact Us.
    20. WHOLE AGREEMENT

    • The terms and conditions expressed above constitutes the whole agreement and RGL and you are bound by this privacy policy.
    21. SEVERIBILITY

    • In the event that only part of the terms of this Privacy Policy are found to be invalid, unlawful or unenforceable, such terms shall be severable from the remaining terms in this privacy policy, which shall remain valid and enforceable.
    22. INDULGENCE

    • Any indulgence, leniency or extension of time which RGL may give to you shall not operate as an estoppel or in any way prejudice RGL or preclude RGL from exercising any of its rights.
    23. QUERIES AND DISPUTES

    If you are dissatisfied with our resolution of your complaint, you have the right to refer it to the Commissioner of the Data and Data Protection Commission, the supervisory authority for data protection issues in Botswana.