Privacy Policy

1. Introduction

This Privacy Policy explains how Abaricom collects, uses, stores, shares and protects personal data when you use our website, communicate with us, engage with us as a client, supplier, partner or other stakeholder, or use our services, including digital security, network solutions, systems integration and other technology services.

For purposes of the Data Protection Act, 2024, Abaricom acts as a data controller in respect of personal data for which it determines the purposes and means of processing. In certain service arrangements, Abaricom may also process personal data on behalf of its clients in its capacity as a data processor.

Abaricom is committed to processing personal data lawfully, fairly, transparently and securely and in accordance with the Data Protection Act, 2024 and other applicable legal and regulatory requirements.

We may update this Privacy Policy from time to time to reflect changes to our services, technology, legal and regulatory requirements or data processing practices. The latest version of this Privacy Policy will be published on our website together with its effective date.

2. What Personal Data We Collect

Depending on your interaction with Abaricom and the services being provided, we may collect and process the following categories of personal data:

• names, job titles, professional credentials and other identification information;
• government-issued identification where necessary for security, contractual, regulatory or compliance purposes;
• contact information, including email addresses, telephone numbers and business addresses;
• physical addresses, site locations and other location information necessary for network deployment, infrastructure installation or service delivery;
• technical information, including IP addresses, device identifiers, browser information, system and network logs, authentication records and other technical information generated through the use of our systems or services;
• information necessary for the provision, management and security of digital security, network solutions, systems integration and related technology services, including configuration information, access-control information and system information;
• website usage information, including information collected through cookies and similar technologies;
• correspondence, enquiries, support requests, complaints and other information provided when communicating with us; and
• other personal data that may reasonably be required for the provision of our services or compliance with applicable legal, regulatory or contractual requirements.

We seek to collect only personal data that is adequate, relevant and necessary for the purposes for which it is processed.

3. How We Obtain Personal Data

We may collect personal data directly from you when you:

• use our website;
• contact or communicate with us;
• request information about our products or services;
• enter into or perform a contract with us;
• use our products, networks, systems or services;
• submit an enquiry, complaint or support request; or
• otherwise interact with Abaricom.

We may also receive personal data from our clients, business partners, suppliers, contractors, technology providers, employers, regulatory authorities or other third parties where the collection and processing of such information is lawful.

Where personal data is received from another organisation in connection with services being provided to that organisation, Abaricom may process that information as a data processor acting on the instructions of the relevant data controller.

4. Why We Process Your Personal Data

We may process personal data for purposes including:

• delivering, maintaining, managing and supporting our digital security, network solutions, systems integration and other technology services;
• managing our relationship and contractual arrangements with clients, suppliers, partners and other stakeholders;
• securing networks, systems, applications, infrastructure and information;
• authenticating users and managing access to systems and services;
• monitoring systems and networks for security, availability, performance and operational purposes;
• detecting, investigating, preventing and responding to cybersecurity incidents, fraud, unauthorised access and other security threats;
• providing technical support and responding to service requests;
• complying with legal, regulatory, contractual, audit and compliance requirements;
• maintaining appropriate business, operational, security and audit records;
• improving our products, services, systems and customer experience;
• developing new technologies, products and solutions;
• communicating service updates, security advisories, maintenance notices and other information relevant to our services;
• managing enquiries, complaints, disputes and legal claims;
• protecting Abaricom’s legal rights, systems, personnel, clients and business operations; and
• carrying out other legitimate business activities consistent with applicable law.

5. Legal Basis for Processing Personal Data

Depending on the circumstances and the nature of our relationship with you, Abaricom may process personal data where:

• you have given consent to the processing;
• processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract;
• processing is necessary for compliance with a legal or regulatory obligation applicable to Abaricom;
• processing is necessary to protect the vital interests of an individual;
• processing is necessary for the performance of a task carried out in the public interest, where applicable; or
• processing is necessary for legitimate interests pursued by Abaricom or a third party, provided that such interests do not override the rights and freedoms of the data subject.

Where processing is based on your consent, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.

6. Marketing and Customer Communications

We may periodically send service-related communications, security advisories, maintenance notices and other operational communications using the contact information provided to us.

Where permitted by applicable law or where you have provided the required consent, we may also use your contact information to provide information about our products and services, conduct market research or undertake customer satisfaction activities.

You may object to the processing of your personal data for direct marketing purposes at any time. Where you exercise this right, we will cease processing your personal data for direct marketing in accordance with applicable law.

7. Comments

Where visitors are able to leave comments on our website, we may collect the information provided through the comments form together with technical information such as the visitor’s IP address and browser user agent information for purposes including spam detection, security and administration of the website.

9. Cookies and Similar Technologies

Our website may use cookies and similar technologies to support website functionality, improve user experience, maintain security and understand how our website is used.

If you leave a comment on our website, you may be given the option of saving certain information, such as your name and email address, in cookies so that you do not have to enter the same information when leaving another comment. The duration of these cookies will depend on their purpose and configuration.

Where user accounts or login functionality are provided, temporary or session cookies may be used for authentication, security and website functionality.

We may also use analytics or other technologies where appropriate. Where consent is required for particular cookies or tracking technologies, we will obtain the required consent before using them.

Further information about cookies used by our website may be provided through our cookie notice or cookie management tools.

10. Embedded Content from Other Websites

Our website may include embedded content from third-party websites or services, including videos, images, maps, articles or other content.

Embedded content from third-party websites may operate in a similar manner to content accessed directly through the relevant third-party website.

Third-party providers may collect information about your interaction with embedded content, including your IP address, device information, cookies and usage information, in accordance with their respective privacy policies.

Abaricom does not control the privacy practices of these third parties.

11. Links to Other Websites

Our website may contain links to third-party websites, social media platforms or online services.

Once you follow a link and leave our website, Abaricom may no longer have control over the processing of information by that third party. Information provided to third-party websites or services will be subject to their respective privacy policies and terms.

We encourage you to review the applicable privacy policies before providing personal information to third-party websites or services.

12. Who We Share Personal Data With

Abaricom does not disclose personal data to third parties except where there is an appropriate business, contractual, security or legal basis for doing so.

Where third parties process personal data on our behalf, we require appropriate contractual, confidentiality, security and data protection obligations to be implemented in accordance with applicable requirements.

13. How Long We Retain Personal Data

If you leave a comment, the comment and associated metadata will be retained for as long as reasonably necessary to manage comments, recognise and process follow-up comments, maintain the integrity and security of the website and comply with applicable legal and regulatory requirements.

For clients and users of our digital security, network solutions and systems integration services, we may retain service-related data, system records, security logs, audit logs and other associated information for as long as reasonably necessary to provide and secure our services, comply with applicable legal and regulatory requirements, fulfil our contractual obligations, investigate and respond to security incidents, maintain appropriate audit records, resolve disputes, establish or defend legal claims and enforce our agreements.

Where necessary for these purposes, certain information may be retained after the termination or expiry of a service agreement.

The applicable retention period will depend on the nature of the information, the purpose for which it is retained, contractual requirements, applicable legal or regulatory obligations, cybersecurity and audit requirements and other lawful requirements for continued retention.

Personal data will not be retained for longer than necessary for the purposes for which it was collected or subsequently lawfully processed.

Where personal data is no longer required, it will be securely deleted, destroyed or anonymised in accordance with our data retention requirements and applicable law.

14. Your Rights in Relation to Your Personal Data

Subject to the circumstances and any limitations provided under applicable law, you may have the right to:

• request confirmation as to whether Abaricom processes personal data concerning you and obtain access to that personal data;
• request correction of inaccurate or incomplete personal data;
• request erasure of your personal data where the applicable legal requirements are satisfied;
• request restriction of the processing of your personal data in circumstances provided by law;
• receive personal data that you have provided to us in a structured, commonly used and machine-readable format and, where applicable, request its transmission to another data controller;
• object to certain processing of your personal data, including processing for direct marketing purposes;
• withdraw consent at any time where processing is based on consent, without affecting processing undertaken lawfully before withdrawal;
• exercise applicable rights relating to decisions based solely on automated processing, including profiling; and
• lodge a complaint with the Information and Data Protection Commission where you believe that your personal data has been processed contrary to applicable data protection law.

Certain rights may be subject to limitations or exemptions under applicable law. We may also retain personal data where retention is required by law or is necessary for the establishment, exercise or defence of legal claims.

Abaricom may take reasonable steps to verify your identity before responding to a request concerning your personal data.

15. Automated Decision-Making and Profiling

Where Abaricom uses automated processing, including profiling, in a manner that produces legal effects or similarly significantly affects an individual, such processing will be undertaken in accordance with applicable data protection requirements.

Where required by law, appropriate information regarding the automated processing and applicable safeguards will be provided to affected individuals.

16. How We Protect Your Personal Data

Abaricom implements appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction, alteration, disclosure, access or damage.

These measures may include, as appropriate to the nature and sensitivity of the information being processed:

• identity and access-management controls;
• authentication and authorisation controls;
• network and endpoint security;
• encryption and other data protection technologies;
• security logging and monitoring;
• vulnerability and patch management;
• malware protection and threat detection;
• backup, recovery and business continuity measures;
• cybersecurity incident detection and response procedures;
• physical security controls;
• employee security and confidentiality requirements;
• supplier and third-party security controls; and
• appropriate information security and data protection policies and procedures.

Our security measures are reviewed periodically and adjusted where necessary having regard to changes in technology, risk, our processing activities and applicable legal and regulatory requirements.

17. Personal Data Breaches

Abaricom maintains processes for identifying, assessing, managing and responding to cybersecurity incidents and personal data breaches.

Where a personal data breach occurs, Abaricom will assess and manage the incident in accordance with its incident management procedures and comply with applicable notification and communication requirements under the Data Protection Act, 2024.

Where Abaricom processes personal data on behalf of a client, we will manage and report relevant personal data breaches in accordance with applicable law and our contractual obligations to the client.

18. Contact Us About Your Personal Data

If you have questions about this Privacy Policy, wish to exercise your data protection rights, or have concerns about how Abaricom processes your personal data, please contact us:

Abari Communications (Botswana) (Pty) Ltd
Plot 69184, Block, Botswana Digital & Innovation Hub
Gaborone, Botswana
Email: xxxx
Telephone: 391 6104

Requests concerning personal data will be handled in accordance with the Data Protection Act, 2024 and Abaricom’s applicable data protection procedures.

19. Complaints

If you have a concern about Abaricom’s processing of your personal data, we encourage you to contact us so that we can review and address the matter.

You also have the right, where applicable, to lodge a complaint with the Information and Data Protection Commission in accordance with the Data Protection Act, 2024.

20. Changes to This Privacy Policy

Abaricom may amend this Privacy Policy from time to time to reflect changes in our business operations, technology, services, data processing activities or applicable legal and regulatory requirements.

Any revised Privacy Policy will be published on our website. Where appropriate, we may also communicate material changes through other appropriate channels.