Privacy Policy
Last updated: February 2026
Before publishing: this policy is a working draft prepared for a Botswana-based online education business. It has not been reviewed by a lawyer and does not claim compliance with any specific legislation. Please have it checked against the Botswana Data Protection Act and your actual data-handling practices before you rely on it.
This policy explains what personal information Polelo Trading Academy ("we", "us", "the Academy") collects, why we collect it, how we use it and what control you have over it. It applies to this website, the member portal and the trading journal platform.
1. Who we are
Polelo Trading Academy is an online trading education provider based in Botswana. For any question about this policy or your information, contact us at info@polelotradingacademy.ac.bw.
2. Information we collect
Information you give us
- Account details — name, email address, username and password (stored only as a secure hash, never in readable form).
- Application and interview information — your trading experience, what you are struggling with, your goals, your view on risk, how much time you can commit and which membership period you are considering.
- Contact details — phone or WhatsApp number and country, so we can arrange your interview.
- Payment records — the proof of payment you upload, the amount, the reference and the date. We do not collect or store card numbers, because we do not currently take card payments.
- WhatsApp opt-in — if you choose to join our updates group to access free courses, we record your name, email, phone number, the wording you consented to, the date and your IP address, so the consent is auditable.
- Anything else you send us — emails, messages and support requests.
Information created as you use the platform
- Learning activity — courses started, lessons completed, progress and resources downloaded.
- Trading journal entries — the trades, notes, screenshots and statistics you record. This is your data; we do not publish it or sell it.
- Technical data — IP address, browser type, pages viewed and login timestamps, kept for security and to keep the service working.
3. Why we use it
- To assess your application and run the admission interview.
- To create and administer your account and control access to paid content.
- To verify payments and activate membership for the period you paid for.
- To deliver courses, resources, mentorship sessions and support.
- To send service messages — payment confirmations, access changes and membership expiry reminders.
- To send educational updates and announcements, where you have opted in.
- To keep the platform secure, prevent abuse and diagnose faults.
- To meet our legal, accounting and tax obligations.
4. Our lawful basis
We process your information because it is necessary to provide a service you asked for (your application, your membership, your account), because you gave consent (marketing messages and the WhatsApp group), because we have a legitimate interest in running and securing the Academy, or because the law requires it — for example retaining financial records.
5. Cookies and analytics
We use a small number of cookies that are necessary for the site to work — chiefly to keep you signed in and to protect forms against cross-site request forgery. These cannot be switched off without breaking the service.
If we add analytics or advertising cookies in future, we will ask for your consent first and update this policy. Most browsers let you block or delete cookies through their settings.
6. WhatsApp updates group
Access to our free courses requires you to opt in to the Academy's WhatsApp updates group. We will never add you silently — you must tick an explicit consent box, and we record what you agreed to.
Joining that group means other members may be able to see your phone number and display name, depending on how the group is configured. Please keep that in mind before opting in. WhatsApp is operated by a third party and its own privacy terms apply to messages sent through it.
You can leave the group at any time, and you can ask us to delete your opt-in record by emailing info@polelotradingacademy.ac.bw. Opting in to updates does not give access to paid academy content.
7. Sharing your information
We do not sell your personal information. We share it only with:
- Our hosting and email providers, who process data on our behalf to run the website and send service messages.
- Our bank, in the ordinary course of receiving and reconciling payments.
- Professional advisers such as accountants, where necessary.
- Authorities, where we are legally required to do so.
8. How long we keep it
- Unsuccessful applications — up to 12 months, so we can recognise you if you apply again.
- Member accounts and learning records — for as long as your account exists, and for a reasonable period afterwards in case you return.
- Payment records and proofs of payment — as long as tax and accounting rules require.
- Marketing consents — until you withdraw them.
When information is no longer needed we delete it or make it anonymous.
9. Security
The site is served over HTTPS. Passwords are hashed. Access to member content is controlled by role. Uploaded files, including proofs of payment and journal screenshots, are stored outside publicly browsable folders and are served only to people entitled to see them. Administrative access is limited to people who need it.
No online service can promise perfect security, and we will not pretend otherwise. If a breach affects your information, we will tell you and take the steps required of us.
10. Your rights
Subject to applicable Botswana law, you can ask us to:
- Give you a copy of the information we hold about you.
- Correct anything that is wrong or out of date.
- Delete your information, where we are not required to keep it.
- Stop sending you marketing, at any time.
- Withdraw a consent you previously gave.
Email info@polelotradingacademy.ac.bw and we will respond as promptly as we reasonably can. We may need to confirm your identity first.
11. Children
The Academy is intended for adults. We do not knowingly accept applications from anyone under 18. If you believe a minor has given us information, contact us and we will remove it.
12. Changes
If we change this policy we will update the date at the top of the page, and tell members directly where the change is significant.
13. Contact
Questions, requests or complaints about your information: info@polelotradingacademy.ac.bw.