Updated at 20-10-2021

SmartSwitch (“SmartSwitch,” ” “we,” “us,” or “our”) deeply believes in the importance of earning and maintaining your trust. As such, we are strongly committed to protecting your privacy rights. You should carefully read this Privacy Statement (“Statement”) to inform yourself on how Botswana Services collects, uses, shares, or otherwise processes information relating to individuals (“Personal Data”), and to learn about your applicable rights regarding such processing.

I.     About the Statement – Processing Activities

This Statement applies Personal Data processed by SmartSwitch when you:

• visit this website (www.smartswitch.co.bw) and/or any other SmartSwitch website(s) which reference or link to this Statement (collectively, “Website”);
• Use, download, access, as applicable, any of our various internet-based offerings, including any paid or non-paid subscriptions, newsletters, mobile platforms, webinars, briefings, programs, software, or applications (collectively, “Services”);
• Visit SmartSwitch branded social media sites;
• Receive communications from us, including emails, phone calls, or other electronic messages; or
• Attend or register for any of our events, conferences, networking/community offerings, etc.

It applies whether you have provided the information directly to us or if we have obtained such information from a different source, such as a third party. This Statement may be supplemented by additional privacy notices provided to you.

Notwithstanding the foregoing, if you or your organization have previously entered into a separate, written agreement with Botswana Services governing your existing use of the Services (“Subscriber Agreement”), any conflicting privacy terms of the Subscriber Agreement shall control as set forth therein.

It is important to understand that the Website and the Services may contain links to sites or offerings operated by individuals or entities other than Botswana Services. Such links, where applicable, are provided for your reference and convenience only. SmartSwitch is not responsible for the content or operation of such sites or offerings, nor the security or privacy of any information collected by such third parties. You are solely responsible for determining the extent to which you may use any such content, and you should review the corresponding privacy policies applicable to these third party sites or offerings.

II.     Information We Collect

We collect some information directly from you (for example, via forms you complete or products or Services you access, download, or otherwise obtain). Such information is generally limited to

• Personal Bio data, contact details, and company or organization;
• Your communications with SmartSwitch personnel;
• Content you post on our social media sites;
• Information you provide on the Website, such as online questionnaires, or feedback forms;
• Information you provide when you subscribe to email newsletters such as your interest in specific SmartSwitch research areas;
• Responses to surveys or other such best-practices studies;
• Information you provide when registering for a free account, log-in credentials and information about your use of and preferences for the Services; and
• Limited billing information, collected and used strictly for billing purposes only, is not shared or used for any other purposes, and is and will be processed in accordance with all applicable laws.

Other information is received indirectly from you via use of the Services or from your organization on your behalf (for example, from observing your actions on the Website or to provision you with account access). Such information is generally limited to:

• Information regarding usage of the Services or Website via web logs collected automatically and passively using various technologies, which generally will not specifically identify you or other individuals. Examples may include IP addresses, browser types, domain names, and other anonymous statistical data regarding aggregate usage;
• Download restrictions or other such consumption limits, where applicable, attributed to your SmartSwitch account, username, email address, registration, etc. Additionally, if you elect to download and use any optional third-party applications with various service, we will detect and store information necessary for you to effectively use the third-party application; and
• Information provided by your employer or organization, such as name, email, other contact information, job title, etc., in order to activate and manage your access to and use of the organization’s subscription to the Service.

 

III.     Use of Cookies, Tracking Technologies, and other Electronic Tools

A “cookie” is a small text file with a unique identifier placed on a browser or online device, used to collect limited information about your online preferences and increase website efficiency. When you visit the Website, SmartSwitch or one of our authorized third parties may place a cookie on your browser and/or device. We also use web beacons in some email communications. SmartSwitch uses such cookies and other tracking technologies to manage your preferences, customize and deliver content and advertising, provide social media features, and examine usage information pertaining to Website visits.

We may use both “session cookies” (which disappear once the browser is closed or computer is turned off) and “persistent cookies” (which remain in operation until deleted). You can manage website cookies in your relevant browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain Website or Services functions and features will not work as intended.

The following describes how we use or may choose to use different categories of cookies and similar technologies.

Required or essential cookies. These cookies are necessary for the Website’s basic operations and there are no options to disable. For example, session cookies needed to transmit the Website, authentication cookies, and security cookies.

Social media cookies. These cookies allow users to share our Website or materials on social media sites. Because these cookies are not within our control, you should refer to their respective privacy policies to understand how they work.

Advertising cookies. Advertising cookies track activity across websites in order to understand a viewer’s interests, and to direct specific marketing to them. CB Insights may now or in the future elect to contract with third-party advertising networks that collect IP addresses and other information from web beacons on our websites, from emails and on third-party websites.

Functionality cookies. These cookies help us customize our website content based on a user’s preferences. They remember the user’s choices, their language, the country pages visited and any changes the user makes to text size or other parts of our website pages. The information these cookies collect may be anonymized and they cannot track browsing activity on other websites.

At any time, you can prevent cookies from being set on your browser. For instructions on how to block, delete or disable any cookies, please consult your browser’s “Help” or “Support” section.

Lastly, we also collect Personal Data via other sources such as public records, publicly available sources or internet sites, vendors, data suppliers and service providers, commercially available marketing lists or registries, telephone directories, social networks (such as LinkedIn,Facebook,Twitter,Google), news outlets and related media. Such Personal Data collected via these sources is typically limited to business contact information, such as names, contact information, job titles, IP addresses, and LinkedIn and other social media profiles.

IV.     Use of Personal Data

SmartSwitch uses your Personal Data when: it is necessary to perform our obligations or exercise our contractual rights; we have a legitimate business interest to process such Personal Data; it is necessary to comply with applicable laws or regulations; we have your consent (where required under applicable law) to use your information (where we rely on your consent, you have the right to withdraw consent by contacting us as set forth below). Such legal reasons are identified for the following common instances:

Administering our Website and Providing Services: Personal Data is processed to perform our contractual obligations, where applicable. In instances where we have not entered into a contract with you, such processing is based on our legitimate interest to manage and promote our business, operate and administer the Website, provide and improve the Services, and to provide requested content or materials (for example, when you request to download one of our reports from the Website).

User Registration: In accordance with our contractual obligations or legitimate interest to provide Services, when you register for an account with SmartSwitch (whether as a paying client or on a complimentary basis), we process your Personal Data as needed to register and administer your account, provide technical and client support and training, verify your identity, and send important account, subscription, and Services information.

Support Requests: If you request that SmartSwitch contacts you (for example, to learn about our offerings), or if you contact us by other means, we process your Personal Data to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you, or as is required by contractual obligations.

Compliance; Security and Functionality of Website and Services: For our legitimate interests in ensuring adherence to relevant terms, we process your Personal Data to review compliance with the applicable usage. Personal Data is also processed by tracking use of the Website and Services, to perform our contractual obligations, where applicable, to provide a secure and functional experience. In instances where we have not entered into a contract with you, such processing is based on our legitimate interest in promoting the safety and security of the Website, Services, systems and applications and in protecting our rights and the rights of others, whereby we reserve the right to monitor, investigate and report any attempts to breach the security of the Website or Services, verify accounts and activity, and enforce our terms and policies.

Event Registration and Attendance: We process your Personal Data to plan and host events, conferences, networking/community offerings for which you have registered or attend, including sending related communications to you, to perform of our contract with you, or as part of our legitimate interest to operate and improve our events business, enable peer networking opportunities, promote our brand, and collect relevant information for hospitality and health and safety purposes.

Improving Website and Services; Developing Offerings: We process your Personal Data to analyze trends, usage, and interactions with the Website and Services to the extent it is necessary for our legitimate interest in improving the Website and Services, developing new offerings, and providing individuals with tailored content and to personalize your experience with our Services. In certain instances, we will process your Personal Data for such development by directly seeking your input (for example, through surveys).

Identifying Client Interests and Opportunities: Because it is in our legitimate business interest to meet our client demands and ensure positive user experiences, we may process your Personal Data to assess new potential customer opportunities as relevant.

Marketing Communications; Advertisement. It is our legitimate business interest to promote our Website and Services, grow our company, and advertise our offerings (whether via direct marketing or providing personalized content advertisements), and as such we will process your Personal Data by sending certain marketing information, product recommendations, custom research, and other communications (for example, newsletters, sales calls, or other electronic communications) solely as necessary to reflect such legitimate interests, or, if applicable, to the extent you have provided your prior consent.

Payments: In the rare instances where you have provided financial information to us, Botswana Services will process your Personal Data to verify such information and to collect payments solely as needed to complete a transaction and perform our contractual obligations.

Legal Obligations: We may be required to process Personal Data for legal and compliance reasons we believe to be necessary or appropriate under applicable law (which may include laws outside your country of residence). Such processing may be required to: respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities; enforce our terms of service or other terms and conditions; or protect our rights, privacy, safety, or property, or those of other persons.

V.     Sharing Information

SmartSwitch may share Personal Data as follows:

Contracted Service Providers. As necessary to provide the Services, conduct our business operations, or when we believe that applicable law permits or requires disclosure, we may share Personal Data with contracted service providers, including entities which provide for hosting and system administration, payment processing, analytics, marketing, data enrichment, or client support, to the extent necessary and in accordance with the legal bases set forth above. These service providers only receive Personal Data necessary to fulfill the services they provide to SmartSwitch. Under no circumstances are such service providers permitted to use obtained Personal Data for any purpose other than to provide SmartSwitch with the designated services.

Mergers or Acquisitions. In the event of a merger, acquisition, consolidation, change of control, corporate divestiture or dissolution where we sell all or a portion of our business or assets, we will disclose necessary Personal Data and such information will be governed by the privacy policies of acquiring entities. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.

Data Analytics. Occasionally, we may share non-personal, anonymized, and statistical data with third-parties for the purpose of helping CBI with such analysis and improvements. Botswana Services may also use anonymous, aggregated utilization data for typical business operations (for example, demonstrating the audience size of our newsletter).

VI.     Location of Processing.

SmartSwitch is solely located in, and operates from, SmartSwitch. Additionally, it is possible that some of the service providers referenced above may process Personal Data outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and that may not provide for the same level of data protection as your jurisdiction. We ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of protection required under applicable law, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses for the transfer of data.

IX.     Accessing and Controlling Your Information

Depending on applicable laws, you have certain rights regarding your Personal Data. These rights may include:

• Right to access and/or rectify inaccuracies. You have the right to access Personal Data we hold about you and, in most circumstances, to be provided with a copy of this information. You also have the right to correct any inaccuracies relating to your Personal Data which we hold.
• Right to restrict use. to the extent permitted by law, you have the right to restrict use of such processing.
• Right to request deletion. You have the right to request that we delete your Personal Data from our systems. Please note, if you prefer to opt-out of marketing communications, it is preferable that we retain your basic contact information with a strict “do not contact” mark applied, to ensure we do not contact you in the future.
• Right to object to processing. Where we process your Personal Data on a legitimate interest basis (for example, direct marketing purposes), you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection. In such cases, we will stop processing your Personal Data until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise, or defense of legal claims.
• Right to withdraw consent. To the extent we base the processing of your Personal Data on your consent, you have the right withdraw consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
• Right to data portability. In most instances, you have the right to receive all Personal Data you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, to the extent such transfer is technically feasible.

How to exercise your rights

To exercise your rights, please contact us as set forth below in Section XI. Any requests should include information to allow us to verify your identity (e.g., your name, address, email address, or other information reasonably required).

We use all efforts to respond to any legitimate requests within one month. In the event we require additional information, we will contact you and specify what is needed. In certain circumstances, it may take longer than one month, for example if we receive overly complex or numerous requests.

Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Marketing Communication Preferences.

Regarding electronic marketing communications, you may manage your receipt of the same by clicking on the “unsubscribe” or other equivalent link located on the bottom of any marketing or sales emails, visit the applicable email preference center, or contact us as described below in Section XI. As pertaining to sales calls, if you want your phone number to be added to our internal Do-Not-Call list, please contact us as described below in Section IX (please include your first name, last name, company and the phone number you wish to add to our Do-Not-Call list).

Response Timing

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

XI.      Questions Regarding this Statement and Your Information

If you have any questions or comments regarding this Statement or your information, please contact us:

In addition to writing at the above address, you can email us at privacy@smartdev.developer.co.bw

XII.      Security; Modifications to this Statement

We implement technical and organizational measures to seek to ensure a level of security appropriate to the risk to the Personal Data we process. These measures are aimed at ensuring the integrity, confidentiality, and availability of Personal Data.

SmartSwitch reserves the right to change this Statement at any time by posting revisions on the Website. Such changes will be effective upon posting and will modify the “Last Updated” date above. We encourage you to periodically review this Statement to stay informed about our processing of your Personal Data