PRIVACY NOTICE 

Okavango Diamond Company (“ODC”, “we” or “us”) is the Data Controller responsible for the processing of your personal data and is committed to protecting and respecting your privacy.  This Privacy Notice sets out how ODC collects, uses, stores, and protects personal information that we collect from you, or that you provide to us when you use our website or when you email us.  By visiting our website, you acknowledge that your personal information may be processed in accordance with this Privacy Notice.  

We may update this Privacy Notice from time to time by updating this page.  We recommend that you review this page periodically to ensure that you are familiar with the current version.  

INFORMATION WE MAY COLLECT FROM YOU 

Personal data or personal information means any information relating to an identifiable individual.  

We may collect and process the following categories of personal information: 

  • Personal information that you provide to us by filling in forms on our website (for example enquiry or contact forms);  

  • Personal information that you provide through email or other written communication;  

  • Records of correspondence if you contact us;  

  • Information provided when you participate in surveys or feedback requests (participation is voluntary).  

We may also automatically collect certain technical information about your visit to our website. This information is not used to identify you personally and may include:  

  • IP address  

  • Browser type and version  

  • Device information  

  • Pages visited and browsing patterns  

  • General demographic information  

This information is generally aggregated and used for statistical analysis and to improve the functionality and security of our website.   

HOW WE USE YOUR INFORMATION  

We may process your personal information for the following purposes:  

  • maintaining internal records;  

  • responding to enquiries and providing requested services; 

  • communicating with you regarding our services or relevant information;  

  • conducting market research;  

  • improving our website, services and customer experience;  

  • analysing how visitors interact with our website;  

  • improving security and preventing misuse of our website;  

  • sending you, from time to time, material in respect of events or other information which we think you may find interesting;  

  • market research purposes;  

We may contact you by post, email or telephone where necessary.  

LEGAL BASIS FOR PROCESSING  

We process personal data where it is necessary for: 

  • our legitimate business interests; 

  • providing services requested by you; 

  • complying with legal or regulatory obligations; or  

  • where you have given consent.  

DISCLOSURE OF PERSONAL INFORMATION  

  • ODC’s service providers, professional advisors, consultants and contractors who assist us in operating our business;  

  • regulatory authorities, law enforcement agencies, courts or government bodies where required by law;  

  • third parties where necessary to protect the rights, safety or property of ODC, our employees or others.  

Where personal data is transferred outside Botswana, we ensure that appropriate safeguards are in place to protect the personal information in accordance with applicable data protection requirements.  

RETENTION OF PERSONAL DATA 

We retain personal information only for as long as necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory obligations:  

When determining retention periods, we consider:  

  • the nature and sensitivity of the personal information;  

  • the risk of harm from unauthorised use or disclosure;  

  • the purposes for which the information was collected;  

  • applicable legal and regulatory retention requirements. 

Once personal information is no longer required, it is securely deleted or destroyed.  

 

DATA SUBJECTS RIGHTS  

Data Subjects have rights under the Botswana Data Protection Act No. 18 of 2024, and you may exercise your other rights by contacting our DPO using the details below. Under certain circumstances by law, you have the right to:  

  • request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it; 

  • request rectification/correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected; 

  • request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see directly below).;  Your right to erasure will be exercised as long as there is no legal justification for the continued processing;  

  • object to processing your personal information. Your right to object to the processing of your personal data will be exercised as long as there is no legal justification for the continued processing;  

  • request the restriction of processing your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish the accuracy or the reason for processing it;  

  • request the transfer of your personal information to another data controller in a structured, commonly in a machine-readable format and transmit such personal data without hindrance from ODC, as the data controller;  

  • the right to lodge a complaint with the office of the Data Protection Officer as well as the Information and Data Protection Commissioner (IDPC).  

  • You also have the right to opt-out of receiving any marketing related messages  

 

SECURITY 

We take appropriate technical and organisational measures to safeguard personal information and prevent unauthorised access, loss, misuse or disclosure.  

These measures include physical, electronic and administrative safeguards such as access controls, secure systems and staff confidentiality obligations.  

While we implement appropriate technical and organisational security measures to protect personal information, the transmission of information over the internet is not completely secure. Although we take reasonable steps to safeguard personal data, we cannot guarantee the absolute security of data transmitted through our website.  

 

COOKIES 

Our website may use cookies to improve your browsing experience. Cookies are small data files stored on your device when you visit a website. 

Most web browsers automatically accept cookies, but you may modify your browser settings to decline cookies if you prefer. Please note that disabling cookies may affect the functionality of certain parts of our website. 

For more information about cookies and how to control them, please visit Allaboutcookies.org. 

  

GOVERNING LAW 

Your use of the ODC website is governed by and construed in accordance with the laws of the Republic of Botswana. Any disputes arising in connection with the website shall be subject to the exclusive jurisdiction of the High Court of Botswana.  

 

CONTACT 

For any questions about this Privacy Notice, the processing of your personal information, or if you wish to exercise your data subjects rights, please contact:  

Data Protection Officer 

Okavango Diamond Company (Pty) Ltd 

Plot 67782, Block 8 Industrial 

Gaborone, Botswana  

Email: dpo@odc.co.bw 

Telephone: +267 3602421