Privacy Policy

Last updated: August 2026

This policy explains what personal data Polelo Trading Academy collects, why we collect it, how long we keep it, who we share it with and what you can require of us. It is written to meet our obligations as a data controller under the Data Protection Act, 2024 (Act No. 18 of 2024) of Botswana, which came into force on 14 January 2025 and replaced the Data Protection Act of 2018.

It applies to www.polelotradingacademy.ac.bw, the member portal and the trading journal platform. Words like "personal data", "processing", "data controller" and "data subject" carry the meanings given to them in the Act.

1. Who is responsible for your data

Polelo Trading Academy is the data controller for the personal data described in this policy. We are an online trading education provider based in Botswana.

The supervisory authority for data protection in Botswana is the Information and Data Protection Commission (IDPC). You may contact the Commission directly about anything in this policy — see section 15.

2. The principles we apply

The Act requires that personal data be handled lawfully and fairly. In practice that means we commit to the following, and you can hold us to them:

3. What we collect

3.1 Data you give us

3.2 Data created as you use the platform

3.3 Sensitive personal data

The Act gives special protection to data revealing race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual life, and to genetic and biometric data. We do not ask for any of it and we have no legitimate use for it. Please do not send it to us.

One caveat, stated plainly: the trading journal invites you to record how you felt while trading, because emotional discipline is part of what we teach. If you choose to write something there that touches on your health or wellbeing, it becomes data we hold. You control what you write, you can edit or delete any entry at any time, and we do not analyse those notes for any purpose other than showing them back to you and generating your own performance statistics.

4. Our lawful basis for each purpose

The Act requires a lawful basis for every processing operation. Ours are as follows.

What we doWhyLawful basis
Assess your application and run the admission interviewTo decide whether the programme suits youSteps taken at your request prior to entering a contract
Create and administer your account; control access to paid contentTo deliver the membership you boughtPerformance of a contract
Verify payment and activate membershipTo confirm what you paid forPerformance of a contract
Deliver courses, resources, mentorship and supportThe service itselfPerformance of a contract
Send service messages — payment confirmations, access changes, expiry remindersSo you are not caught out by an account changePerformance of a contract
Send marketing emails — educational content, new intakes, offersMarketingYour separate opt-in consent, withdrawable at any time
Send WhatsApp community and marketing messagesCommunity and marketingYour separate opt-in consent, withdrawable at any time
Keep the platform secure, throttle brute-force logins, diagnose faultsTo protect your account and oursOur legitimate interest in securing the service
Retain financial and tax recordsStatutory bookkeepingCompliance with a legal obligation

Where we rely on legitimate interest, we have considered whether that interest is overridden by your rights and freedoms, and we have limited the processing accordingly. You may object to it — see section 14.

4.1 Marketing is always a separate choice

Two things we want to state plainly, because plenty of sites do the opposite:

There are two independent opt-ins — email and WhatsApp. Taking one does not take the other, and declining both has no effect whatsoever on your application.

Every marketing email carries a one-click unsubscribe link. You can also withdraw either consent at any time by writing to privacy@polelotradingacademy.ac.bw.

5. We do not make automated decisions about you

No decision that affects you — admission, pricing, access or removal — is made by automated processing or profiling. Applications are read and decided by a person. Your journal statistics are calculated automatically, but they are shown only to you and are not used to make decisions about your membership.

6. Cookies

We use a deliberately small number of cookies, all of them strictly necessary for the site to function:

We run no analytics, advertising, profiling or tracking cookies of any kind, and no third-party tracking pixels. Because our cookies are strictly necessary, no consent banner is required for them. If we ever introduce non-essential cookies we will ask for your consent first and update this policy before doing so.

We publish the cookie names and their security flags deliberately. None of it is secret — any visitor can see both in their browser's developer tools — and the protection comes from the flags themselves, not from concealing them. The one thing a cookie notice must never disclose is the cookie's value, which is the actual session secret, and we never do.

Most browsers let you block or delete cookies in their settings. Blocking our session cookie will prevent you from signing in.

7. What we do with your WhatsApp number

We want to be completely specific here, because a phone number is the piece of data people most dislike having misused.

7.1 What we use it for

7.2 How you opt in

By ticking a box that is unticked by default on the application form, or on the free-resources form. We record the exact wording you agreed to, along with the date and your IP address, so the consent can be evidenced. We will never add you to a group silently, and we do not buy, scrape or exchange phone numbers.

Your decision has no bearing whatsoever on your application. Declining costs you nothing.

7.3 How you opt out

At any time, by any of these — all equally valid, all free, and none requiring a reason:

We action opt-outs promptly and, once you have opted out, we stop. You will still receive essential service messages about an active membership — a payment confirmation is not marketing — and you can close your account entirely if you want those to stop too.

7.4 Things you should know before joining a group

A WhatsApp group may expose your phone number and display name to other members of that group, depending on how it is configured. That is a property of WhatsApp, not a choice we make, and we cannot undo it for messages already sent. Consider using a WhatsApp display name you are comfortable sharing.

WhatsApp is operated by a third party under its own terms and privacy policy. Messages sent through it are processed on its infrastructure, outside Botswana, not on ours.

Opting in to the community does not grant access to paid academy content.

7.5 The chat button on this site

The floating chat button asks for your name and email, then opens WhatsApp with a message already written. Two things worth being straight about:

Our lawful basis is the step you asked us to take at your request. You can ask us to erase a chat enquiry record at any time under section 14.

8. Showing your name on our website

We run a small notice on our marketing pages saying that someone has recently joined the academy. Everything about it is real: it is generated from actual approved memberships, and we never invent names, numbers or sign-ups.

You appear there only if you have agreed to it. Specifically:

Our lawful basis is your consent, which you may withdraw at any time.

9. Who we share your data with

We do not sell your personal data, and we do not share it for anyone else's marketing. We disclose it only to the following, and only as far as each needs it:

Every processor acting on our behalf is bound to process your data only on our documented instructions, to keep it confidential, and to apply appropriate security — as the Act requires of us.

10. Transfers outside Botswana

Some of the providers listed above operate servers outside Botswana. That means your personal data is transferred across borders.

Under the Act, a transfer of personal data to a country outside Botswana may only take place where that country ensures an adequate level of protection, or where an authorised alternative applies. The Commission treats a number of jurisdictions as offering adequate protection, including the states of the European Union and European Economic Area, South Africa, Japan, Israel, New Zealand and Uruguay. Where a destination is not covered by such a finding, we rely on your explicit consent or on contractual safeguards with the recipient, and we seek the Commissioner's authorisation where it is required.

If you would like to know exactly where your data is held and on what basis it is transferred, email privacy@polelotradingacademy.ac.bw and we will tell you.

11. How long we keep it

DataRetentionReason
Unsuccessful or withdrawn applications12 months from the decisionSo we can recognise you if you reapply
Member account, learning records and journal entriesFor the life of the account, then 12 monthsSo you can return without losing your history
Payment records and proofs of payment7 yearsTax and accounting obligations
Marketing and WhatsApp consent recordsUntil withdrawn, then 24 monthsTo evidence that consent was validly obtained
Chat-button enquiries12 monthsTo follow up and keep a record of what was asked
Failed login attemptsRolling 15 minutesBrute-force protection only
Server and security logsUp to 12 monthsSecurity and fault diagnosis

You may ask us to delete your account and its contents sooner, and we will do so except where we are legally obliged to retain a record — principally financial records. When a retention period ends we delete the data or irreversibly anonymise it.

12. Security

The measures we actually have in place:

Botswana's Cybersecurity Act, 2025 (Act No. 21 of 2025) established a national framework for cybersecurity and a National Cyber Security Authority. We monitor the obligations arising under it and under the Digital Services Act, 2025 (Act No. 22 of 2025) as their subsidiary regulations are issued, and we will adjust our practices and this policy as required.

No online service can guarantee perfect security and we will not claim otherwise. What we can commit to is the response set out next.

13. If there is a data breach

The Act sets a firm timetable for reporting a personal data breach, and we will meet it:

14. Your rights

Under the Act you have the following rights over your personal data. Exercising them is free of charge.

How to exercise them

Email privacy@polelotradingacademy.ac.bw. We will acknowledge your request promptly and respond substantively within 30 days. If a request is genuinely complex and we need longer, we will tell you why within those 30 days. We may need to verify your identity first, so that we do not disclose your data to somebody else — we will ask only for what is necessary to do that.

You can also delete your own account directly from your account settings.

15. Complaints

If you are unhappy with how we have handled your personal data, please raise it with us first at privacy@polelotradingacademy.ac.bw — most issues are resolved quickly at that stage.

You have the right to complain to the supervisory authority regardless of whether you come to us first:

Information and Data Protection Commission (IDPC)
Republic of Botswana
www.idpc.org.bw

16. Children

The Act treats the personal data of minors as requiring special protection. The Academy is intended for adults: we do not knowingly accept applications from, or create accounts for, anyone under the age of 18. We do not direct any marketing at children.

If you believe a minor has given us personal data, contact privacy@polelotradingacademy.ac.bw and we will verify and erase it promptly.

17. Changes to this policy

When we change this policy we update the date at the top of the page. Where a change is significant — a new purpose, a new category of recipient, or a new basis for processing — we will notify members directly by email before it takes effect, and where the change requires your consent we will ask for it rather than assume it.

18. Contact

Any question, request or complaint about your personal data: