Privacy Policy

 

Privacy Policy

 

Nors Botswana (Pty), Ltd., a company within the Nors Group, presents its Privacy Policy, through which informs you of your rights and establishes how it collects and uses your personal data.

At Nors Botswana (Pty), Ltd., we are committed to using your data only for specified, explicit, and legitimate purposes. Various security measures, both technical and organizational, have been implemented to protect the personal data provided to us against unauthorized disclosure, loss, misuse, alteration, processing, or access, as well as against any other form of unlawful processing.

  1. Data Controller

Nors Botswana (Pty), Ltd., registered office at Plot 47, Gaborone International Commerce Park, P.O. Box 202616 Gaborone, with registered number BW00000522016, is the entity responsible for the processing of your personal data, as it determines which data are collected, the means of processing, and the purposes of the processing.

  1. Data Protection Officer

Nors Botswana (Pty), Ltd. has appointed a Data Protection Officer (DPO), who:

  • informs and advises the Data Controller regarding obligations within the scope of privacy and data protection rules;
  • cooperates with the supervisory authority;
  • is the contact point for the customer, or potential customer, to clarify any questions regarding the processing of personal data carried out by Nors Botswana (Pty), Ltd.

If you wish to clarify any doubts or lodge a complaint, you can contact our Data Protection Officer at the following email address: dpo@nors.com.

  1. Personal Data, Data Subjects, Categories, and Collection Methods of Personal Data
  • What is Personal Data?

Personal data refers to any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, especially by reference to an identifier. An identifier could be, for example, a name, identification number, location data, online identifiers, or one or more specific factors relating to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

  • Who are the Data Subjects?

The customer or potential customer, a natural person, to whom the data relates and who uses, or intends to use, the products or services provided by Nors Botswana (Pty), Ltd. The representative/employee or contact point in a company, in the case of legal persons, within the scope of executing a contract or pre-contractual diligence between that company and Nors Botswana (Pty), Ltd..

  • What Categories of Personal Data are Processed by Nors Botswana (Pty), Ltd.?

 

IDENTIFICATION DATA

EXAMPLES

Personal and contact information

Name, civil or tax identification data, phone contact, address, email address.

Data relating to the purchase of Products and Services

History of purchased products or acquired services.

Customer History

Information related to contracts entered; responses to satisfaction surveys; received offers; campaign history; event participation; complaint history.

 

  • How and When is Your Personal Data Collected?

Your personal data may be collected in the following circumstances:

  1. For the purpose of entering and executing a contract, namely when you purchase or acquire a product and/or service from us.
  2. Through Nors Botswana (Pty), Ltd.’s website or through the websites of the brands we represent.
  3. When you visit one of our sales points and provide us with your personal data.
  4. When you subscribe to our newsletters, giving us your consent.
  5. When you participate in events organized by Nors Botswana (Pty), Ltd. or by the brands we represent and provide us with your personal data.
  1. Legal Basis, Purposes, and Duration of Personal Data Processing

The legal bases that legitimize the processing of your personal data by Nors Botswana (Pty), Ltd. are as follows:

Consent: Your personal data may be processed upon your free, specific, informed, and unambiguous consent, by which you accept, through a declaration or clear affirmative action, the processing of your personal data.

Pre-contractual diligence and/or contract execution: Your personal data may be necessary to clarify doubts, present a proposal, execute, and manage the contract entered into with Nors Botswana (Pty), Ltd.

Compliance with a legal obligation: Your data may be necessary to comply with a legal obligation to which the data controller, in this case, Nors Botswana (Pty), Ltd., is subject to.

Legitimate interest: Your data may be processed to carry out certain operations related to Nors Botswana (Pty), Ltd.'s business activity, provided that your interests, rights, and fundamental freedoms do not override those interests, considering your reasonable expectations within your relationship with Nors Botswana (Pty), Ltd..

Thus, Nors Botswana (Pty), Ltd. will process your personal data as follows:

 

 

LEGAL BASIS

PURPOSES

Consent

We process personal data of customers and potential customers, upon consent, for commercial and marketing purposes, including marketing campaigns, events, promotions, information about new products, and satisfaction surveys regarding services provided by Nors Botswana (Pty), Ltd..

Pre-contractual diligence and/or contract execution

We process personal data for the purpose of entering into, executing, and managing the contract entered into between the customer and Nors Botswana (Pty), Ltd., particularly when we need to contact the representative of a legal person in the context of executing a contract or pre-contractual diligence.

Compliance with a legal obligation

When processing is necessary to comply with legal obligations, your personal data will be transmitted to official entities, for example, for billing purposes or to respond to and resolve registered complaints, among others.

Legitimate interest

We process personal data based on legitimate interest, particularly for business monitoring and management; in the context of the customer's contact request via the website, social media, phone, or email; and to respond to complaints made.

Nors Botswana (Pty), Ltd., in order to fulfill its contractual obligations, needs to collect some personal data (name, email, and phone number) of the representative or employee of that company, solely for the purpose of ensuring proper execution of that contract.

In this case, the customer legal entity must ensure that the data collected from its representatives/employees are collected and transmitted to Nors Botswana (Pty), Ltd. lawfully (under one of the legal bases provided for in the applicable legislation) and must ensure the data subjects, their representatives, or employees the right to be informed about the processing of those data.

  • Personal Data Retention Period

Nors Botswana (Pty), Ltd. retains personal data of data subjects only for the period strictly necessary to pursue the purpose for which they were collected. In certain cases, the law requires data to be retained for a specific period, such as data needed for information to the Tax Authority, which will be kept in accordance with current legislation.

We will also retain your data for the period during which you maintain a contractual relationship with Nors Botswana (Pty), Ltd.. However, we may retain your personal data for periods longer than the duration of the contract to ensure rights and duties related to the contract or in situations where there is a legitimate interest of Nors Botswana (Pty), Ltd., always respecting the period necessary to pursue the purpose for which they were collected.

Where there is no specific legal obligation, your data will be processed only for the period necessary to fulfill the purposes that motivated their collection, and as long as there are legitimate grounds that allow their retention by Nors Botswana (Pty), Ltd..

Once the maximum retention period has been reached, personal data will be anonymized, in which case they will no longer constitute personal data due to the irreversibility of the anonymization process, being safely retained or deleted.

  1. Transmission of Your Personal Data

Nors Botswana (Pty), Ltd. transmits your personal data only when necessary for the purposes described above, namely, to provide the services requested by you.

Our suppliers, as processors, are contractually bound and provide guarantees of implementing technical and organizational measures to ensure that personal data processing is carried out in accordance with legal requirements and that data subjects’ rights are safeguarded, processing the data only according to our documented instructions.

Nors Botswana (Pty), Ltd. may transmit your personal data, depending on the purpose for which they were collected, to third parties when requested by you, and only the data necessary for the activity carried out by these entities will be transmitted.

Your personal data will also be hosted in the European Economic Area, subject to European data protection standards, with Nors Botswana (Pty), Ltd. transferring personal data as necessary in view of the established Group relationship.

  1. Links to Other Websites

We alert you to the fact that Nors Botswana (Pty), Ltd. is not responsible for the privacy practices of third parties whose websites have a link on our website, and we cannot guarantee the accuracy or authenticity of the information contained therein. We advise you to read the privacy policies of any other website linked to Nors Botswana (Pty), Ltd.’s website.

Nors Botswana (Pty), Ltd. does not guarantee the accuracy, completeness, or authenticity of the information contained in any link or other website on the Internet. Personal data entered on other websites linked to Nors Botswana (Pty), Ltd.’s website will be the sole responsibility of the data subject.

  1. Rights of Data Subjects and Response to Data Subjects' Requests

Nors Botswana (Pty), Ltd. guarantees the applicability and fulfillment of all the rights of the data subject as provided in the General Data Protection Regulation and national legislation in force.

  • Right of Access

You have the right to obtain from Nors Botswana (Pty), Ltd. confirmation as to whether or not personal data concerning you are being processed and, where that is the case, access to your personal data and information regarding that processing. For example, you can request an exact copy of your compilation and, where legally possible, request information related to the processing of your personal data.

  • Right to Rectification

You also have the right to obtain from Nors Botswana (Pty), Ltd., without undue delay, the rectification of inaccurate personal data concerning you, as well as the right to have incomplete personal data completed.

  • Right to Erasure (“Right to be Forgotten”)

You may request Nors Botswana (Pty), Ltd. to delete your data without undue delay, for example, in the following situations: (i) when personal data are no longer necessary for the purposes for which they were collected or otherwise processed; or (ii) when you withdraw your consent on which the processing is based, in cases where processing is carried out on the basis of consent, and where there is no other legal basis for processing.

 

  • Right to Data Portability


You have the right to receive your personal data concerning you that you have provided to Nors Botswana (Pty), Ltd.  in a structured, commonly used, and machine-readable format, as well as the right to transmit that data to another data controller (if technically feasible), without Nors Botswana (Pty), Ltd. being able to prevent this if: i) the processing is based on consent or a contract, and ii) the processing is carried out by automated means.

  • Right to Withdraw Consent


Data subjects have the right to withdraw consent at any time, without affecting the lawfulness of the processing based on consent prior to its withdrawal. Nors Botswana (Pty), Ltd. will inform data subjects of this right to withdraw consent before processing begins, ensuring that the process for withdrawing consent is easy for data subjects.

  • Right to Object


You also have the right to object at any time to the processing of your personal data when there are no compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of a right in legal proceedings. You may also object at any time to the processing of your personal data for direct marketing purposes. In this case, Nors Botswana (Pty), Ltd. commits to ceasing the processing of data for this purpose.

  • Right to Restrict Processing


In certain situations, you have the right to obtain from Nors Botswana (Pty), Ltd. the restriction of processing your data, particularly if you contest the accuracy of the personal data during a period enabling Nors Botswana (Pty), Ltd.  to verify its accuracy, in cases where the data is no longer necessary for the purposes of processing but is required by the data subject for the establishment, exercise, or defense of a right in legal proceedings, and also when you object to the processing, until it is verified that the legitimate interests of Nors Botswana (Pty), Ltd. prevail over yours, as well as in other legally stipulated cases.

  • Right not to be Subject to Automated Decision-Making


You have the right not to be subject to any decision taken solely on the basis of automated processing, including profiling, which produces effects in your legal sphere or similarly significantly affects you.

  • Exercising Your Rights


You may exercise your rights free of charge, except in the case of manifestly unfounded or excessive requests, or due to their repetitive nature, in which case we may, legally, charge you a reasonable fee taking into account the administrative costs.

We will respond to your requests within a maximum of 30 (thirty) days, unless in cases of more complex requests or when the number of requests is high, in which case this period may be extended up to 60 (sixty) days.

You may exercise your rights in one of the following ways:

  1. By letter addressed to the DPO of the Nors Group, to which we belong, sent to Rua Manuel Pinto de Azevedo, nº 711, 1º, 4149-010 Porto – Portugal;
  2. By email: dpo@nors.com

Nevertheless, if you are not satisfied with our response after exercising any of these rights, you have the right to lodge a complaint with a supervisory authority.

  1. Organisational and Technical Security Measures

Nors Botswana (Pty), Ltd. uses appropriate physical, technological, and organisational security measures to protect your personal data from disclosure, loss, misuse, alteration, unauthorized processing, or access, as well as from any other form of unlawful processing.

To this end, Nors Botswana (Pty), Ltd. implements technical and organisational measures to ensure an adequate level of security corresponding to the risk associated with the storage of Personal Data and during their transmission.

Nors Botswana (Pty), Ltd. has an information system capable of resisting, with a high level of confidence, to accidental events or malicious or unlawful actions that compromise the availability, integrity, and confidentiality of Personal Data stored or transmitted.

  1. Cookies

Nors Botswana (Pty), Ltd.’ website uses ‘cookies’ technology to help determine the website’s use, interest and number of visits, so that browsing may be quicker and more efficient, while also avoiding the need for the user to repeatedly input the same information.

Cookies are small text files that are stored on the devices used to access the Internet, through the browser, where only the information related to your preferences is retained and they do not, therefore, include your personal data.

All browsers allow the user to accept, block or delete cookies, namely by selecting the appropriate definitions in the respective browser.

Our website also has a cookies notice bar when users visit our website, with information about cookies, allowing users to reject all cookies (except essential operational cookies) or accept all.

  1. Use of the Nors Botswana (Pty), Ltd. Website

10.1 Regarding the use of materials on the Nors Botswana (Pty), Ltd. website, information, text, figures, or graphics contained therein may only be used for personal purposes and not for commercial purposes. You should not reproduce, modify, transmit, authorize, or publish such information, texts, figures, or graphics, in whole or in part, for any purpose without prior written permission from Nors Botswana (Pty), Ltd..

10.2 Regarding the use and risk of its use, Nors Botswana (Pty), Ltd. specifically disclaims any responsibility for direct, indirect, incidental, consequential, or special damages arising from or in any way related to your access to or use of this site, which affect your computer equipment or your trust in the information obtained through the Nors Botswana (Pty), Ltd. ‘s website.

10.3 The information on the site should be considered informative. Despite Nors Botswana (Pty), Ltd. 's efforts to keep content updated and reliable, it may contain inaccuracies, typographical errors, or be outdated, and may be changed at any time without prior notice from Nors Botswana (Pty), Ltd..

 

  1. Update of the Privacy Policy

Nors Botswana (Pty), Ltd. reserves the right to update this policy at any time according to legal requirements and/or the needs of its business activity. Therefore, users are invited to regularly visit this page to become aware of any changes.

 

This Privacy Policy was last updated on October 14th, 2024.