This Privacy Notice describes how BIFM collects, uses, discloses, retains and protects your personal information, in accordance with the Data Protection Act (DPA) and other relevant laws.
The Privacy Notice applies to any website, application, form, document, product or service which references this Privacy Notice. It also supplements any other privacy policies which may apply in respect of BIFM’s processing of personal information.
Personal information as information which relates to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. This includes, but is not limited to, your name, sex, gender, address, contact details, identity number and medical or health information.
1. Who we are?
In this Privacy Notice, any reference to “BIFM”, or “we” refers to one or more of the entities, affiliates or subsidiaries of Botswana Insurance Fund Management Limited operating in Botswana.
2. How we collect information
We collect personal information about you and any other person whose details you provide to us in accordance with the relevant laws, either:
- Directly from you when you complete a product or service application form, electronically, telephonically or by way of a hard copy;
- Indirectly from you when you interact with us electronically by way of our website, apps, or social media channels, which may include the collection of metadata (data about data);
- Where relevant, from third-party sources, such as other entities within the BIHL Group, financial intermediaries that are representatives of BIFM or have intermediary agreements with BIFM, public databases, data aggregators, other financial institutions, credit bureaus, and fraud prevention agencies.
We will also collect your information where you have only partially completed and/or abandoned any information which you began to apply to our website and/or other online forms. Given that we already consider you a customer at this stage, we may use this information to contact you in order to remind you to complete outstanding information.
Where we require personal information in order to provide you with our products and services, your failure to provide us with the necessary information, will result in the BIFM being unable to provide you with our products and services. You are responsible for informing Bifm if your information changes.
3. Collection of information by third parties
Owners or information system administrators of third-party websites that have links to the BIFM website, may collect personal information about you when you use these links.BIFM does not control the collection or use of personal information by third parties and this privacy statement does not apply to third parties. BIFM does not accept any responsibility or liability for third-party policies or your use of a third-party app, platform or service.
BIFM also uses certain social networking services such as Facebook, WhatsApp, Instagram and Twitter to communicate with the public and its clients. When you communicate with BIFM through these services, that social networking service may collect your personal information for its own purposes. These services may track your use of our digital channels on those pages where the links are displayed. If you are logged into those services (including any Google service) while using our digital channels, their tracking will be associated with your profile with those service providers. These services have their own privacy policies which are independent of BIFM's privacy policies and practices. Please ensure that you fully acquaint yourself with the terms of any such third-party privacy policies and practices.
BIFM will only provide data to third-party information exchange services with your consent.
4. What information we collect
Your relationship with BIFM determines the exact nature of the personal information BIFM processes, and the purpose for which such personal information is collected and used. However, in many cases, if we are handling your personal information as part of our role as an investment manager, the personal information we may process includes the following:
- Information about you – for example, your name, identity number, age, gender, date of birth, nationality, occupation, lifestyle. Note that we will use that information strictly in accordance with applicable laws and for investment management purposes.
- Contact information – in some cases, for example, we may receive your email, address, phone number and postal address.
- Online information – for example, cookies and IP address (your computer’s internet address), if you use our websites, apps and/or social media channels.
- Financial information – we may process information related to payments you make or receive in the context of an investment account. We may process information regarding your income, expenses, assets, liabilities, investments, retirement and other financial provisions in the context of compliance with regulations.
- Contractual information – for example, details about the investments you hold and their beneficiaries in instances of death.
In certain instances, we may need consent to process your personal information. If you give us your consent for a specific context, you are free to withdraw this consent at any time. Please note that where you have withdrawn your consent, this will not affect the processing that took place prior to such withdrawal and it will not affect the processing of your personal information where consent is not required.
You may refuse to provide us with your personal information in which case we may not be able to provide you with a relevant service or would have to terminate our business relationship. The supply of certain items of personal information, especially those collected to comply with regulation, is legally mandatory.
5. How we use your information
We have regulatory obligations, including compliance with anti-money laundering legislation, to process your personal information. This includes verifying your identity or the identity of your beneficial owner and/or controlling persons. We are also required by various laws to maintain a record of our dealings with clients.
In order for us to provide clients with the financial products and services they have requested and to notify them of important changes to such products and services, we need to collect, use and disclose the personal information of clients, their representatives, controlling persons of entities, business contacts, staff of clients and service providers.
To the extent permissible under applicable laws,BIFM may use your information:
- To provide you with our financial products and services, and maintain our relationship with you.
- To execute a transaction in accordance with your request.
- To assess, check, and process investments and disinvestments.
- To meet our contractual obligations with you or take steps necessary for the conclusion of a contract with you.
- In relation to administering any securities you may hold in respect of a BIFM or BIHL group entity (where relevant).
- To comply with legislative and regulatory requirements, including codes of conduct and requirements of our regulators (including the Non-Bank Financial Institutions Regulatory Authority and the Financial Intelligence Agency)
- To undertake credit reference searches and/or verification.
- For the detection and prevention of unlawful activity, fraud, money-laundering and loss, including as part of party due diligence required under applicable laws and in terms of BIFM policies.
- For debt recovery or debt tracing.
- For purposes of online login and authorisation.
- To execute the BIFM's strategic initiatives.
- To perform any risk analysis or for purposes of risk management to you or our business in general.
- To record and/or monitor and have access to your telephone calls (i.e. voice recordings), correspondence and electronic communications to/with us (or any of our employees, agents or contractors) in order to accurately carry out your instructions and requests, to use as evidence and in the interests of crime prevention.
- To maintain the security of our digital channels and systems.
- For statistical analysis and research purposes.
- For audit and record-keeping purposes.
- For purposes of proof and legal proceedings.
- To enhance your experience when interacting with BIFM and to help us improve our offerings to you.
- To share with other entities in the BIHL Group, so that we can market our financial products and services which we deem similar, with the aim of offering you the opportunity to take up some of the financial products to fulfil your needs, provided that you have not objected to receiving such marketing.
- To conduct market research and provide you with information about our products and services from time to time via email, telephone or other means (for example, invite you to events).
- To process your marketing preferences (where you have unsubscribed from certain direct marketing communications, keeping a record of your information and request to ensure that we do not send such direct marketing to you again).
- To prevent or control the spread of any disease.
- For any purpose related to and compatible with the above.
6. Sharing your information
BIFM will only share your personal information with third parties if there is a legitimate reason to do so. We may disclose the personal information you provide to us to the following entities:
- Our third-party service providers and other Group entities who are involved in the delivery and/or administration of financial products and services.
- Other third parties in relation to the purposes set out under the previous section (How we use your information).
- Other insurers, public bodies and law enforcement (either directly or through shared databases) for fraud detection and prevention.
BIFM will process and share your personal information with other companies within the BIHL Group for the purpose of facilitating your membership to a loyalty or rewards programme. Your personal information may also be shared with third-party suppliers from time to time for the purpose of facilitating and providing benefits to you by way of a loyalty or rewards programme or when needed to fulfil our contractual obligations to you.
BIFM will not sell, rent, or trade your personal information to any third party. BIFM will share information about you with BIFM representatives or have intermediary agreements with BIFM. BIFM may also share information within the BIHL Group where it is in BIFM legitimate interest to do so.
BIFM will disclose information when lawfully required to do so:
- To comply with any relevant legislation.
- To comply with any legal process.
- By any regulatory authority (for example, the Non-Bank Financial Institutions Regulatory Authority and the Financial International Agency).
On occasion, BIFM may – for legitimate purposes – share aggregated information with its stakeholders and business partners (for example, demographic data) in a manner that does not identify the persons to whom the information applies. However, BIFM will not disclose your personal information to third parties unless there is valid processing ground as set out in the applicable legislation.
7. Transfer across borders
Some of the persons to whom we disclose your personal information may be situated outside of the Republic of Botswana in jurisdictions that may not have similar data protection laws to Botswana. In this regard, we may send your personal information to service providers outside of Botswana for storage or processing on BIFM's behalf. However, we will not send your information to a country that does not have information protection legislation similar to that of Botswana, unless we have ensured that the recipient agrees to effectively adhere to the principles for processing of information in accordance with DPA.
8. Security and storage of information
BIFM intends to protect the integrity and confidentiality of your personal information. BIFM has implemented appropriate technical and organisational information security measures (including, but not limited to, using encryption for transmission of credit card numbers) to keep your information secure, accurate, current, and complete. However, we cannot guarantee the security of any information you transmit to us online and you do so at your own risk.
Where third parties are required to process your personal information in relation to the purposes set out in this notice and for other lawful requirements, we ensure that they are contractually bound to apply the appropriate security practices.
Your personal information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.
9. Right of access to information
You have the right under privacy and data protection laws, as may be applicable, to:
a) Request access to and correction or deletion of your personal information.
b) Request restriction of our processing of your personal information, or to object to us processing.
c) Request portability of your personal information
d) Object to our processing of your personal information on reasonable grounds relating to your particular situation unless legislation provides for such processing.
10. Correction of your information
In accordance with our policies and legislation, you have a right to correct any of your personal information held by BIFM.
11. Objection to processing of your information
In accordance with the relevant legislation, you may object to our processing of your personal information on reasonable grounds relating to your particular situation, unless legislation provides for such processing.
Where you provide your personal information to BIFM in the context of a sale of one of our products or services, you agree to BIFM sending you information on news, trends, services, events and promotions for our own similar products and or services, always subject to your right to opt out of receiving such marketing at the time your information is collected and on each subsequent marketing communication thereafter. You may object to receiving direct marketing from BIFM at any time by contacting BIFM on 395 1564 or firstname.lastname@example.org
Where you choose to exercise your right to opt out of direct marketing, please allow up to 21 days for BIFM to effect that change.
13. Clickstream data
In the interests of better customer service, BIFM may collect anonymous information from visitors to its websites. For example, BIFM may keep track of the domains from which people visit its website and also measures visitor activity on its website. In the process, BIFM ensures the information cannot be used to identify you. This information is sometimes known as "clickstream data". BIFM or its analytics vendors (including Google Analytics) may use this data to analyse trends and statistics and to provide better customer service.
The information, referred to as traffic data, which may be collected includes:
- Your IP address.
- The search terms you have used.
- The pages accessed on the website and the links you’ve clicked on.
- The date and time you visited the website.
- The referring website (if any) through which you clicked through to our website.
- The type of website browser you use.
As mentioned, the traffic data is aggregated and not personally identifiable and our website analysis will also respect any ‘do not track’ setting you might have on your web browser.
A cookie is a small text file that is downloaded onto ‘terminal equipment’ (for example, a computer or smartphone) when you access a website. It allows the website to recognise your device and store some information about your preferences or past actions.
What cookies do we use?
How do I disable cookies?
If you do not want to receive a cookie from the website, you have the option of setting your browser to notify you when you receive a cookie, so that you may determine whether to accept it or not. However, please be aware that if you do turn off 'cookies' in your browser, you will not be able to fully experience some of the features of the website. For example, you will not be able to benefit from automatic log-on and other personalisation features.
While the BIFM website is not directed towards children, BIFM is committed to complying with all applicable laws aimed at the protection of children and in particular the protection of their personal information.
This privacy statement was last updated on 31 August 2022. A notice will be posted on the BIFM website home page whenever the Privacy Notice is materially changed.
Please check the website regularly to ensure that you are aware of the latest version of this Privacy Notice.
17. Questions regarding this statement
Questions, comments and requests regarding this statement may be directed to email@example.com for clarification.
18. Particulars of BIFM
Should you have a complaint or concern regarding the processing of your personal information, your complaint may be submitted to firstname.lastname@example.org.
BIFM is a subsidiary of the BIHL Group. BIFM is a licensed asset manager and its subsidiary, BIFM Unit Trusts (Pty) Limited a licensed Management Company for Unit Trusts.
Our head office’s registered address is Plot 66458, Fairgrounds Office Park, Block A, 3rd Floor, Gaborone, Botswana.
19. The Regulator (NBFIRA)
Whereas we would appreciate the opportunity to first address any complaints regarding our processing of your personal information, you have the right to complain to the Regulator.