Legal

Data Privacy Statement

How Sunshine Insurance Company of Botswana collects, uses, stores, shares and protects your personal data — and the rights you have over it.

Last updated: March 2026

At Sunshine Insurance Company of Botswana (Pty) Ltd we are strongly committed to protecting your personal data and, by upholding privacy, we aim to provide a safe and secure environment for you. The purpose of this Data Privacy Statement is to inform you about how we collect, use, store, make available, disclose, update, safeguard, destroy or process your personal data, to explain your rights relating to the privacy of your personal information and how the law protects you, and how to get in touch with us for anything concerning your privacy.

Please note that by using our services, you agree to the collection and use of information in accordance with this Data Privacy Statement available on our website. You may also request a copy of the privacy policy from any of our offices.

1. What Information We Collect

The type of information we collect from data subjects and intermediaries (brokers) may include, but is not limited to:

  • Personal identification details: such as your name, contact information, date of birth, National ID / Passport, physical address, postal address, email and nationality.
  • Financial information: such as credit or debit card number and bank account details.
  • Driving and insurance details: driving licence information, previous insurance policy details, previous accident and claim history, details of any motoring convictions, and authorised driver details (name, relationship, licence, National ID / Passport).
  • Audio, video and other electronic data: audio, electronic, visual or similar information such as CCTV footage, photographs and call recordings.
  • Sensitive information and data relating to criminal records and offences: such as health information and some background-checking information (for example, alleged criminal offences and records).

2. Purpose of Processing

The personal data we collect depends on how it is used. We collect the minimum personal data necessary for the stated purposes. We process your personal data in order to:

  • offer, administer and manage the services provided to you, including assessing and underwriting insurance policies and reinsurance processing;
  • administer, investigate and settle claims or complaints in relation to insurance policies and/or the services provided;
  • communicate with you and respond to your requests, inquiries, comments and concerns;
  • carry out due diligence, identity and data validation, anti-money laundering, “Know Your Customer” and other business-acceptance, vetting and risk-management checks;
  • process payments, including your payments for the insurance premium and any mid-term adjustments;
  • fulfil legal and regulatory obligations, including applicable prudential rules and industry codes of conduct;
  • perform analytics for risk-modelling purposes and to analyse trends;
  • carry out research, audit, reporting and other business-operations purposes.

3. Legal Basis for Processing

We use the information we collect about you in connection with the services, and for any such use we rely on an appropriate legal ground. Where processing involves sensitive personal information, we also rely on an additional legal justification to use such information.

  • Performance of the contract with you, to enable us to take steps in offering the services and to fulfil our obligations.
  • To meet our legal and regulatory obligations, as Sunshine Insurance Company of Botswana (Pty) Ltd is regulated by certain industry regulators and is required to provide some services in accordance with relevant regulatory rules, such as financial and prudential regulations, tax rules, and obligations to prevent and detect unlawful activities, among others.
  • Consent: you may also provide us with your consent to receive certain services, marketing or communications from us (where legally required). In such situations you are not obliged to provide your consent, and you may withdraw it at any stage once provided by emailing info@sunshineinsurance.co.bw or contacting us during office hours on 310 5137. However, where you refuse to provide information that we reasonably require to provide the services, we may be unable to offer you the services and/or may terminate them if they cannot be fulfilled without the respective information.
  • Legitimate interests: we may collect personal data for the purposes of legitimate interests pursued by us or a third party (authorised recipients).

4. Recipients of Your Information

Sunshine Insurance Company of Botswana (Pty) Ltd may from time to time share your personal information with the following categories of recipients where necessary to offer, administer and manage the services provided to you:

  • Within Sunshine Insurance Company of Botswana (Pty) Ltd: we may share your personal information with other organisations, entities, divisions and subsidiaries for the processing purposes outlined in this Statement.
  • Insurance market participants: such as insurers, underwriters, reinsurers, associations of insurance underwriters, brokers, intermediaries, assessors, claim investigators, loss adjusters and legal advisors, where necessary to place cover, defend legal claims or handle insurance claims or claims similar in nature.
  • Internal and external auditors: where necessary for the conduct of company audits or to investigate a complaint or security threat.
  • Law enforcement bodies: where necessary to facilitate the prevention or detection of crime or the apprehension or prosecution of offenders.
  • Public authorities, regulators and government bodies: where necessary for us to comply with our legal and regulatory obligations.
  • Third-party service providers: where we outsource our processing operations to suppliers that process personal information on our behalf. These operations remain under our control and are carried out in accordance with our security standards and strict instructions.

5. Third Country / International Organisation Transfers

Sunshine Insurance Company of Botswana (Pty) Ltd may transfer your personal information to other countries for further processing for the purposes outlined in this Statement. We endeavour to ensure that such transfers comply with all applicable data-privacy laws and provide appropriate protection for the rights and freedoms conferred on individuals under those laws.

This may include transfers to countries that the Information and Data Protection Commission considers to provide adequate data-privacy safeguards.

Where we transfer personal information to countries that are not subject to an adequacy decision, we shall put in place appropriate safeguards, approved by the Commission and covered through data-transfer agreements which contain standard contractual clauses or conditions set out as derogations for specific situations, to ensure that personal information receives an appropriate and consistent level of protection across the entities.

6. CCTV Monitoring

For security and safety purposes, we use CCTV surveillance in certain areas of our premises. CCTV cameras may record images of individuals who enter these areas. The footage is used solely to ensure the safety and security of individuals on our premises; to prevent, detect and investigate incidents of crime or misconduct; and to monitor and protect company property and assets.

7. Direct Marketing

Sunshine Insurance Company of Botswana (Pty) Ltd may send you information about its products and services to the contacts you have shared with us, which may include text messages, emails and other related platforms. If you do not wish to receive such information, you have the right to opt out of receiving these messages at no cost to you by contacting our offices.

8. Data Security

The security of your personal information is important to us. We have implemented appropriate technical and organisational security measures to protect the confidentiality, integrity and availability of your personal information from unauthorised access, alteration, disclosure or destruction, and to ensure that such information is processed in accordance with applicable data-privacy laws.

9. Data Retention

We retain appropriate records of your personal information for as long as is reasonably necessary for the purposes outlined in this Statement and to comply with our legal and regulatory obligations on how long such data is required to be retained.

Where it is no longer required for the outlined purposes, we undertake to securely dispose of it in a timely and consistent manner, or to pseudonymise it.

10. Your Rights as a Data Subject

Subject to legal and regulatory requirements, you have the right to:

  • access and request a copy of your personal data;
  • request rectification where accuracy is disputed;
  • request the erasure of your personal information, where erasure is not subject to legal or statutory obligations to which we are bound;
  • object to the processing of your personal data under certain circumstances;
  • withdraw consent given for the processing of personal data at any time;
  • request that your personal information be provided to you or to a third party of your choice in a portable, structured, commonly used and machine-readable format, where the processing is based on consent or contract, carried out by automated means, and technically feasible.

We do not make any decision solely based on automated processing that produces legal or similarly significant effects.

11. Contact Us

If you have any questions about this Statement or the rights conferred on you under applicable data-privacy laws, or a complaint about how your personal data is processed, you may contact us:

Finance & Compliance Manager
Mr Weston Takaedzwa Nende
Email: weston@sunshineinsurance.co.bw
Telephone: 310 5137
Postal: Private Bag BR 15, Gaborone

Data Protection Officer
Ms Aobakwe Kwape
Email: aobakwe.kwape@bstiua.co.bw
Telephone: 73886606 / 74434273
Postal: P O Box 715, Gaborone

After engaging us, should your complaint not be addressed to your satisfaction, you have the right to lodge a complaint with the Information and Data Protection Commission.

12. Changes to this Statement

This Statement may be amended from time to time in accordance with changes in our regulatory requirements and data-protection practices.

Download this statement as a PDF