Privacy Notice (Botswana)
Privacy notice - Botswana
This notice explains how GateControlX handles personal data in Botswana, under
the Data Protection Act, 2018. It sits alongside the general privacy notice
and, where the two differ, this one applies to residents of estates in Botswana.
Who is responsible for your data
Oceanbreeze Concepts (Pty) Ltd, registration BW00005819590, Plot 475,
Ghanzi, Botswana, P.O. Box 851, Ghanzi.
Email: [admin@gatecontrolx.com](mailto:admin@gatecontrolx.com)
Your estate management decides that the estate uses GateControlX and who is
enrolled on it; they are the data controller for your estate. Oceanbreeze
Concepts operates the system on their instructions.
What we hold about you
- Your name, unit number and phone number.
- Your email address, if you are estate management.
- A photograph of your face and the face template made from it, if you have
agreed to face recognition.
- A record of every time a gate was opened with your face, QR code or PIN: the
time, the gate, and whether it worked.
- Visitor passes you create, and when they were used.
- The phone number you message us from on WhatsApp or SMS, and push
notification tokens for your phone.
Why we are allowed to hold it
- Your consent, for your face photograph and face template. Under the Act,
biometric data is sensitive personal data and is processed only with your
explicit consent. Nothing else about your access depends on giving it - every
gate also accepts a QR code or PIN.
- Performing the contract between your estate and us, for your name, unit,
phone number and access records - the system cannot let you through a gate
without them.
- Legitimate interests of the estate in the security of the property, for
keeping access records for a limited period.
Who else sees it
- Your estate management and the guards they employ.
- The installer who maintains your estate's equipment.
- Our hosting and messaging providers, who process it only to run the service:
server hosting, WhatsApp (Meta Platforms Ireland), and our SMS gateway.
We do not sell personal data and we do not use it for advertising.
Sending data outside Botswana
Our servers and some of our messaging providers are outside Botswana. Section 48
of the Act permits a transfer where it is necessary for the performance of a
contract with you, and where the recipient is bound to protect the data. Message
delivery through WhatsApp and SMS necessarily involves sending your number
outside the country.
How long we keep it
- Face photograph and template: while you are registered, and up to 30 days
after your record is removed or the estate stops using the service.
- Access records: 90 days.
- Visitor passes: until they expire or are used, then deleted.
Your rights under the Act
You may ask us, or your estate management, to:
- tell you what personal data we hold about you and why;
- correct anything that is wrong;
- delete your data, including withdrawing consent for your face at any time;
- object to processing, or ask that it be restricted.
Write to your estate office first, since they hold the relationship with you. You
can also write to us at the address above. We will answer within 30 days.
If you are not satisfied, you may complain to the **Information and Data
Protection Commission** of Botswana.
Children
GateControlX is not offered directly to anybody under 18. Where an estate enrols
a child as a household member, the consent of a parent or guardian is required,
and that includes consent for any face photograph.
Changes
We will publish a new version of this notice when it changes, and you will be
asked to read and accept it in the app. The version you agreed to, and the date,
are recorded.