We know that you care about your personal data and how it is used, and we want you to trust that Sentle uses your personal data carefully. This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it.
As you read our Notice, please keep in mind that it applies to all Sentle companies.
Please take a moment to familiarise yourself with our privacy practices and let us know if you have any questions by sending us an email to the email address listed under customer support on our website.
We have tried to keep this Notice as simple as possible, but if you’re not familiar with terms, such as cookies, IP addresses, and browsers, then please read about these key terms first.
You have the right to object to certain uses of your personal data including the use of your personal data for direct marketing. See what your rights are and how you can exercise them here.
• Who Is Collecting It?
Any personal data provided to or collected by Sentle is controlled by Sentle, the data controller.
This Privacy Notice applies to personal data collected by Sentle in connection with the services and products we offer. References to “Sentle” in this Notice means Sentle and any company directly or indirectly owned and/or controlled by Sentle that you are interacting with or have a business relationship with.
This Privacy Notice also applies to Sentle’s marketing content, including offers and advertisements for Sentle products and services, which we (or a service provider acting on our behalf) send to you on third-party websites, platforms and applications based on your site usage information. These third-party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.
• What Personal Data Is Being Collected?
Personal data means any information that can be used to identify directly or indirectly a specific individual.
You are not required to provide Sentle the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have. In addition, Sentle and its affliated companies, their agents and employees accept no responsibility and shall not be held liable for any damages that you may suffer as a result of the loss of confidentiality of the information that you provide us with on the platform.
We may collect personal data from a variety of sources. This includes:
o Personal data you give us directly,
o Personal data we collect automatically, and
o Personal data we collect from other sources.
Personal data means any information that can be used to identify directly or indirectly a specific individual. This definition includes personal data collected offline through our Consumer Engagement Centres, direct marketing campaigns, sweepstakes and competitions and online through our websites, applications and branded pages on third-party platforms and applications accessed or used through third-party platforms.
You may be asked to provide your personal data when you are in contact with us. Sentle Botswana Proprietary Limited and its affiliated companies that you may transact with on or through our platform may share your personal data with each other and other Sentle Group companies and use it in a manner consistent with this Privacy Notice. We may also combine it with other information to improve our products, services, content, and advertising.
You are not required to provide Sentle the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.
Ways in which we collect your personal data
We may collect personal data from a variety of sources. This includes:
o Personal data you give us directly. We collect data about how you use our services and products, such as the types of content you view or engage with, or the frequency and duration of your activities. We also collect personal data you provide us when you sign up for a marketing newsletter, complete a survey or register for an account. In so doing, we may ask for personal data, such as your name, gender, date of birth, address, email address or telephone number. Some Sentle brands may collect “special categories of personal data” about you with your explicit consent. For more information on the special categories of data we collect and how we use it, please refer to the relevant section below.
o Personal data we collect from other sources. We collect personal data from other sources including our trusted partnerships with third-parties and where we operate Sentle accounts on third-party platforms: For example, when you use the “like” functionality on Facebook or the +1 functionality on Google+. Additionally, we receive information about you and other visitors’ interactions with our advertising to measure whether our advertising is relevant and successful. We also collect information about you and your activities from a third-party when we jointly offer services or products, or from third-party data enrichment providers (to find out more see our privacy key terms) who may deliver insights to Sentle about the personal data we hold.
When and why we collect “special categories of personal data”
Certain categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as “special categories of data” and benefit from additional protection under the European data protection legislation.
We limit the circumstances where we collect and process these special categories of data.
Sentle only collects and uses this personal data where you have provided us with your consent for us to do so.
To illustrate circumstances where Sentle collects and processes special categories of data we have provided the following examples:
• What Purpose Do We Use Your Data For?
We collect, process and disclose your personal data only for specific and limited purposes. For example, to process your loans, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, to provide personalised products, communications and targeted advertising as well as product recommendations to you.
We also create profiles by analysing the information about your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments.
Additionally, Sentle processes your personal data also using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data.
We collect, process and disclose your personal data for the following purposes:
o To process your applications, if you apply for a loan, to provide you with your loan status, deal with your enquiries and requests, and assess and handle any complaints;
o To process and answer your inquiries or to contact you to answer your questions and/or requests;
o To develop and improve our products, services, communication methods and the functionality of our websites;
o For the purposes of competitions or promotions that you have entered;
o To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;
o To manage our everyday business needs regarding your participation in our contests, sweepstakes or promotional activities or request;
o To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise;
o For internal training and quality assurance purposes;
o To understand and assess the interests, wants, and changing needs of consumers, to improve our website, and our services, and/or developing new products and services; and
o To provide personalised products, communications and targeted advertising as well as product recommendations to you.
When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection.
Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.
In some cases, we rely on legitimate interest for processing your personal data. A legitimate interest could exist for example, when you apply for a loan from us and we use the personal data collected to conduct data analytics to improve our products or services. This ground will only be used where it is necessary to achieve a legitimate interest, for example to assist in the performance of a contract, or to optimise a service, and does not outweigh your rights as an individual. This legal basis will only be relied upon where there is no less intrusive way to process your personal data. We can assure you that if legitimate interest is used as a ground for processing your personal data, we will keep a record of this and you have the right to ask for this information.
We process your personal data to perform a contract to which you are or will be a party. For example, we need to process your personal data to deliver a service to you, to allow you to take part in one of our competitions, or to send you information that you have requested.
We also process your personal data when we have a legal obligation (e.g., tax or social security obligations) to perform such processing. For example, a court order or a subpoena may require us to process personal data for a particular purpose, or we may be compelled to process personal data to report suspicious transactions under the local anti-money laundering rules.
• Who Will It Be Shared With?
Sentle shares your personal data within the Sentle Group and with selected third-parties in the following circumstances:
o Third-party service providers. In order to carry out your requests, respond to your inquiries, process your loans, provide you with information, enable you to participate in sweepstakes or competitions or make various other features, services and materials available to you through our websites we share your personal data with third-party service providers that perform functions on our behalf, such as companies that: host or operate Sentles websites, process payments, analyse data, provide customer service, postal or delivery services, and sponsors or other third-parties that participate in or administer our promotions. They have access to personal data needed to perform their functions but may not use it for other purposes. Further, they must process this personal data in accordance with this Privacy Notice and as permitted by applicable data protection laws and regulations.
o Other third-parties. Your personal data will also be used by us or shared with our sponsors, advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third-parties in connection with marketing, promotional, data enrichment (to find out more about our privacy key terms follow the link) and other offers, as well as product information.
o Business transfers. Your personal data will be used by us or shared with the Sentle Group, primarily for business and operational purposes. As Sentle Group continues to develop the business, it may sell or purchase assets, subsidiaries or business units. In such transactions, your personal data generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, you consent otherwise). If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to Sentle’s websites, your personal data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such personal data will be considered an asset of ours and as such it is possible they will be sold or transferred to third-parties.
o Legal disclosure. We may transfer and disclose your personal data to third-parties:
To comply with a legal obligation;
When we believe in good faith that an applicable law requires it;
At the request of governmental authorities conducting an investigation;
To detect and protect against fraud, or any technical or security vulnerabilities;
To respond to an emergency; or otherwise
To protect the rights, property, safety, or security of third-parties, visitors to Sentle websites, Sentle or the public.
International data transfers
Sentle shares personal data within the Sentle Group or with third-parties for purposes described in this Privacy Notice.
Sentle will only send personal data collected within a restricted legal framework, such as e.g. the European Economic Area (EEA) or Asian Pacific Economic Cooperation (APEC), to countries which do not have data protection laws that are considered to provide appropriate levels of protection in the restricted legal framework in circumstances such as:
o To follow your instructions;
o To comply with a legal duty; or
o To work with our agents and advisers who we use to help run our business and services.
If we do transfer personal data to outside of the restricted legal framework, Sentle will make sure that it is protected in the same way as if it was being used in that restricted legal framework. We’ll use one of the following safeguards:
o Transfer to another Country whose privacy legislation ensures an adequate level of protection of personal data similar or equivalent to the country it was collected in;
Put in place a contract with the third-party that means they must protect personal data to the same standards as in the country the data was collected in.
• How Do We Protect Your Personal Data?
Sentle takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure.
Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise and anonymise personal data wherever possible.
Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties.
• How Long Do We Keep Your Personal Data For?
We will keep your personal data for as long as we need it for the purpose it is being processed for. For example, where you apply for a loan with us online we will keep the data related to your application, so we can perform the specific contract you have entered and after that, we will keep the personal data for a period which enables us to handle or respond to any complaints, queries or concerns relating to the application.
Your data may also be retained so that we can continue to improve your experience with us.
We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.
We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained.
• What Are Your Rights?
Your rights in relation to your personal data how it is processed. You can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email to Sentle using the email address listed under customer support on our website.
Where we process your personal data, you have a number of rights over how the data is processed and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email to the email address listed under customer support on our website.
o The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. Therefore, we’re providing you with the information in this Notice.
o The right to access and rectification. You have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us.
o The right to data portability. The personal data you have provided us with may be portable. This means it can be moved, copied or transmitted electronically under certain circumstances.
o The right to be forgotten. Under certain circumstances, you have right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.
o The right to restrict processing. Under certain circumstances, you have the right to restrict the processing of your personal data.
o The right to object. Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving emails from us notifying you or being contacted with varying potential opportunities).
o The right to lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint directly with any local Supervisory Authority about how we process your personal data.
o The right to withdraw consent. If you have given your consent to anything we do with your personal data (i.e., we rely on consent as a legal basis for processing your personal data), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal data at any time by contacting us with the details provided under customer service on our website.
o Rights related to automated decision-making. You have the right not to be subject to a decision which is based solely on automated processing and which produces legal or other significant effects on you. In particular, you have the right:
to obtain human intervention;
to express your point of view;
to obtain an explanation of the decision reached after an assessment; and
to challenge such a decision.
Further information and advice about your rights can be obtained from the data protection Regulator in your Country.
• How Do You Contact Us?
Visit our main office at:
Plot 20, Old Mall Maun, Botswana or call us on +267 680 0000 or send an email to firstname.lastname@example.org.
If you have any questions or concerns about Sentle Privacy Notice or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please do so by sending an email to the email address above or the email address listed under customer support on our website.
When a privacy question or access request is received, we have a dedicated team which triages the contacts and seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant Supervisory Authority in your Country. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
• How Do We Keep This Notice Up To Date?
We will update this Privacy Notice when necessary to reflect customer feedback and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the top of this Notice. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes). We will also keep prior versions of this Privacy Notice in an archive for your review.
We will not reduce your rights under this Privacy Notice without your consent.
Additional Privacy Terms or Notices
In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or notices will be made prominently available to you.
Last updated July 2020