1. Introduction

1.1 Morula Capital Partners is dedicated to protecting the privacy of [our website visitors, service users, individual customers, and customer personnel].   

1.2 This notice pertains to how Morula Capital Partners processes personal data of individuals, specifically outlining both the purposes and methods of such processing.

1.3 We utilize cookies on our website. To the extent that these cookies are not strictly necessary for the provision of [our website and services], we will request your consent for their use upon your initial visit to our website.

        2. The personal data that we collect

We collect the following types of information when you use our website:

2.1 Personal Identifiable Information (PII): We process data that enables us to contact you, such as name, email address, phone number, or other submitted contact details.

2.2 Communication Data: We process information contained in or relating to any communication that you send to us or that we send to you, such as inquiries, feedback, or other voluntarily provided information.

2.3 Account Data: We process your website user account data. The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings, and marketing preferences.

1. Usage Data: We process data about your use of our website and services, such as your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency, and pattern of your service use.

1. When you visit our office, we use CCTV cameras to collect your images for security reasons and record keeping. 

Note: For account opening we collect data specifically for account opening purposes. For more information see Client Privacy Notice.

• Purposes of processing and legal bases

We process contact data, account data, and communication data to manage relationships and communicate with you, based on legitimate interests. Personal data may also be processed to comply with legal obligations, protect vital interests, maintain records, and ensure security against fraud and criminal activities. For account opening purposes, personal data is collected and processed during the onboarding process and on an ongoing basis as circumstances change or the information becomes outdated. 

• Sharing/ Transfer of Personal Information

We share data with subsidiaries, service providers, or third-party for operational, legal, and security purposes. In some instances, data may be transferred outside Botswana in compliance with applicable data protection laws.

• Retaining and deleting personal data

Morula has established data retention policies to ensure compliance with legal obligations concerning personal data. We will retain your personal data as long as necessary to fulfill outlined purposes or as required by law, with a minimum retention period of 20 years under the Financial Intelligence Act. Once no longer needed, data will be securely deleted or anonymized.

• Data Security

We implement technical and organizational measures to protect your personal data from unauthorized access disclosure, alteration misuse or destruction. We ensure that third-party service providers adhere to appropriate security standards. Our security protocols include encryption of sensitive data, access controls and authentication mechanisms.

• Your Data Protection Rights

1. 1. You have the right to: access, correct, or request the deletion of your personal data as well as to withdraw consent, you can request for transfer of your personal data in specific situations or object to processing of your data under certain conditions.

1. You may exercise any of your rights in relation to your personal data by using this Data Subject Right request form.

1. About cookies
   1. Cookies are small text files that are stored on your device (computer, tablet, smartphone) when you visit a website. 
   2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

• Cookies that we use

1. 1. We use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website. These cookies are essential for enabling core site functionality, such as secure login and session management. 
   2. We use cookies as part of our security measures to protect user accounts, including preventing fraudulent use of login credentials and safeguarding our website and services. These cookies help detect and mitigate unauthorized access attempts.
   3. We use cookies to help us analyze the usage and performance of our website and services. These cookies allow us to understand how visitors interact with our site, which pages are visited most often, and how users navigate through our content. 

• Amendments

This notice may be updated periodically, and any new version will be published on our website. We will inform you of any changes or significant modifications to this notice via email.

1. Contact Us

For any questions about this Privacy Notice or to exercise your rights, please contact us at:

Email: dpo@morula.co.bw or Tell: 267 3931063