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Privacy Policy

INDEX

 

CB RETAIL CLOTHING (PTY) LTD gathers and processes Personal Data in respect of its customers, staff, contractors, suppliers, business partners and other individuals in order to carry out its functions, to provide its services and to meet legal and regulatory obligations.

1. About This Policy

CB Retail Clothing (Pty) Ltd (CB Retail Clothing, the Company, we, us) is committed to protecting the personal information of its employees, customers, suppliers and business partners by ensuring the fair, responsible and transparent use of all Personal Data that it holds.

This Data Protection Policy sets out how CB Retail Clothing collects, uses, stores, shares and protects personal data in accordance with the Botswana Data Protection Act, 2024 and related regulations. The policy applies to all business operations, including in-store services and online shopping platform.

2. Scope of Application

  • All employees, third parties, contractors, and temporary staff of CB Retail Clothing
  • All customers (in-store and online)
  • Suppliers, service providers and business partners
  • All personal data processed by the Company, whether electronically or in paper form

3. Key Definitions

Data Subject
A natural person whose data is being processed

Data Controller
The company determining how data is processed

Data Processor
A person or third party processing data on behalf of CB Retail Clothing.

Personal Data
Any information relating to an identified or identifiable individual.

4. Our Data Protection Principles

1. Lawfulness, Fairness, and Transparency

We process data based on legal grounds including contractual necessity, legal obligations, and legitimate interests.

2. Purpose Limitation

Data is collected for specific, legitimate purposes and not used beyond its intended scope.

3. Data Minimization

Only the minimum necessary data is collected.

4. Accuracy

We take reasonable steps to ensure personal data remains accurate and up-to-date.

5. Storage Limitation

Data is retained only as long as required by law or business need.

6. Security

We implement strong security measures including encryption, access control, and staff training.

5. Categories of Personal Data We Collect

  • Customer Information — Names, ID numbers, contact details
  • Online Shopping Information — Addresses, account data
  • Payment Information — Processed securely by partners
  • Employee and Supplier Information
  • Technical Data — IP, cookies, analytics

6. Lawful Basis for Processing

  • Consent
  • Contractual necessity
  • Legal obligations
  • Legitimate business interests

7. Online Shopping

  • Orders placed online
  • Secure payments
  • Collection in-store only
  • No delivery offered

8. Use of Third-Party Service Providers

Shopify — E-commerce platform acting as a data processor.

FNBB — Secure payment processing provider.

9. Cross-Border Data Transfers

  • Adequate safeguards in place
  • Compliant with applicable laws
  • Users informed where applicable

10. Processing of Children’s Personal Data

CB Retail Clothing does not knowingly collect personal data from individuals under 18.

11. Data Retention

  • Financial records: 7 years
  • Employee records: as required by law
  • Online accounts: until deletion

12. Data Security Measures

  • Access controls
  • Encryption
  • Security monitoring
  • Staff training

13. Rights of Data Subjects

  • Access personal data
  • Request correction
  • Object to processing
  • Request deletion

14. Data Breach Management

  • Incident containment
  • Regulatory notification
  • User notification
  • Corrective actions

15. Employee Responsibilities

  • Handle data responsibly
  • Follow this policy
  • Report breaches immediately
  • Attend training

16. Data Protection Officer

Name: Kabelo Menyatso

Email: kmenyatso@cashb.bw & dpo@cashb.bw

Phone: +267 367 0831 / +267 718 70538

17. Policy Review and Approval

This policy is reviewed regularly and updated when business operations or legal requirements change.