Okavango Diamond Company (“ODC”, “we” or “us”) is committed to protecting and respecting your privacy.  This privacy policy sets out how ODC uses and protects any information (including personal data) that we collect from you, or that you provide to us, when you use our website.  By visiting our website, you consent to the use of your information as set out in this privacy policy.

ODC may change this policy from time to time by updating this page.  We recommend that you regularly review this policy to ensure that you are familiar with the current version.

INFORMATION WE MAY COLLECT FROM YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect and process the following information:

• personal information that you provide to us by filling in our forms (including, for example enquiry forms);
• personal information that you provide to us by e-mail or otherwise in writing;
• if you contact us, we may keep a record of that correspondence; and
• we may ask you to complete surveys for market research purposes, though you do not need to respond to them.

If you do not want your personal data collected, please do not provide it to us. 

If you believe that any information that we are holding is incorrect or incomplete, please amend your details through your online account or notify us in writing (details provided below) as soon as possible.

We may also collect information automatically about your visit(s) to our site.  This information is not personally identifiable and includes general information about your computer settings (including IP address), browsing patterns, and demographic data.  This information shall remain in aggregated form and may be used to understand how visitors use this site or for other statistical purposes.

USE AND DISCLOSURE OF THE INFORMATION

We process your personal information for our legitimate business interests. ‘Legitimate interests’ means the interests of ODC in conducting and managing our business to enable us to offer you the best customer service that we can.

You agree that we may obtain, hold and use the information we collect to provide you with a better service, and in particular for the following reasons:

• internal record keeping;
• providing you with information about our products and/or services;
• sending you, from time to time, material in respect of events or other information which we think you may find interesting; and
• market research purposes.

Processing your personal data also allows us to:

• enhance, modify, personalise and improve our customer service;
• understand how visitors interact with our website;
• produce relevant and timely online and offline marking campaigns as well as determine the effectiveness of our advertising; and
• enhance online security.

We may contact you by post, e-mail, telephone or fax.

We hold and process your personal data for as long as required for the purpose for which the data was initially collected. Once we no longer need your personal data, we dispose of it securely. To determine the appropriate retention period for personal information, we consider:

• amount, nature and sensitivity of information;
• potential risk from unauthorised use or disclosure of your personal information;
• purposes for which we collected and used it and whether we still need to keep it in the same form; and
• legal retention requirements that may apply to that information.

We keep a record of our processing activities, including a data retention schedule, which records how long your data is kept on our system.

Whenever we process personal data we will ensure that we always keep your personal data rights in high regard and take account of these rights. 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 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);
• object to processing your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation that makes you want to object to processing on this ground;
• 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; and
• request the transfer  of your personal information to another party.

You agree that we may disclose the information we collect:

• to ODC’s external service providers (which may be international organisations or organisations based in a third country), including to ODC’s external professional advisors and for the purpose of compliance and due diligence screening;
• to protect the rights or safety of ODC, any of ODC’s employees or any third party;
• as we consider required or permitted under law or to comply with legal or regulatory requirements.  This may require disclosures to courts, law enforcement agencies or government, regulatory or other competent authorities and bodies.

You have the right to object to the processing of your personal data, and if you wish to do so please contact us using the contact information below. Please bear in mind that if you object this may affect our ability to carry out certain tasks for your benefit.

SECURITY

In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.  Unfortunately however, due to the inherent nature of the internet as an open global communications vehicle, we cannot ensure the security of your data transmitted to our site.  Any transmission, therefore, is at your own risk.

COOKIES

We may collect information from you through the use of “cookies”.  “Cookies” are small data files that are sent to your browser or related software from a web server and stored on your computer’s hard drive.

Most internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer.  Without cookies enabled, you may not be able to use certain features on our site.  For more information about cookies and how to control them, please visit Allaboutcookies.org.

GOVERNING LAW

Your use of the ODC Sites shall be governed by and construed in accordance with the substantive law of Botswana. You hereby give consent to the exclusive jurisdiction of the High Court of the Republic of Botswana in respect of any disputes arising in connection with the ODC Site.

CONTACT

Questions about this privacy policy, ODC’s use of your information or practices relating to ODC’s website generally should be directed to the Communications Coordinator at the following address: Okavango Diamond Company, P.O. Box 2258 ABG, Sebele, Gaborone, Botswana or by email to info@odc.co.bw