Clients Privacy Notice

Introduction

Phoenix of Botswana Assurance (“Phoenix” or “we” or “us”) is a pan-African insurance company. The nature of our services require the collection of personal data. Personal data is information that identifies an individual. We regard, utmostly, the protection of the personal data that we collect and the individual right to privacy. Through this notice, we invite you transparently, to appreciate our handling of your personal data.

Purpose and Legal Basis

We have described below the purposes for collecting personal data and the corresponding lawful ground for processing.

Purpose of ProcessingLawful Ground for Processing
Provision of our products and services to policyholders in terms of the Insurance Industry Act and customer due diligence in terms of the Financial Intelligece Act.Contract; Legal obligation
Contacting individual policyholders’ next of kin/beneficiaries or corporate clients’ representatives as and when the need arises.Legitimate interest: To assist the policyholders
Promotion of our products and services.Consent; Legitimate interest: Marketing  
To assist in improving our products and services.Consent; Legitimate interest: Improved customer experience

Recipients

We share personal data with external orgnisations. As and when necessary, personal data will be shared with:

  • Our data processors, i.e. service providers
  • Phoenix Assurance Group
  • Industry regulators
  • Law enforcement

Your Rights

  • Access: Request confirmation of processing of personal data and/or a copy thereof.
  • Rectification: Request correction of inaccurate or incomplete personal data.
  • Erasure: Request deletion of personal data (where applicable).
  • Restriction: Request limitation of processing of personal data.
  • Objection: Object to the processing of personal data.
  • Data portability: Request that personal data be transmitted to another controller (where applicable).
  • Objection to automated decision making: Request human intervention in instances where personal data is used in automated decisions (where applicable).

Retention Period

The personal data we collect is primarily to advance the business relationship between us and our clients. As such the personal data shall be retained for a period prescribed by the Financial Intelligence Act, i.e. 20 years post the termination of the business relationship.

International Data Transfers

There will be transfer of personal data outside Botswana. Where personal data is  transferred to our Group office in Kenya, our basis is adequacy. Otherwise we will rely on appropriate safeguards and/or derogations.

Contact

If you have any questions about this notice, your rights or your personal data, you may reach our Data Protection Officer at dpo@phoenixbotswana.com or +267 3161322

Our Physical and Postal Addresses

Plot 54358, Prime Plaza, South Wing, Ground Floor, Marula Building, CBD, Gaborone

P O Box 361 Masa Center, Gaborone, Botswana

Last updated: 19 May 2025

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