Privacy Notice (Botswana)

Version 1 · in force since 15 September 2026 · BW

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

agreed to face recognition.

time, the gate, and whether it worked.

notification tokens for your phone.

Why we are allowed to hold it

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.

phone number and access records - the system cannot let you through a gate

without them.

keeping access records for a limited period.

Who else sees it

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

after your record is removed or the estate stops using the service.

Your rights under the Act

You may ask us, or your estate management, to:

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.