Account & Data Deletion

This page explains how to request deletion of your account and the associated personal data. It covers both of the accounts operated by Seedstone Capital (Pty) Ltd:

• Halo - the field sales-agent Android app used by Seedstone agents, published on Google Play by Seedstone Capital (Pty) Ltd.
• seedstone.co.bw - the public website, the loan application portal and the Seedstone Insurance Agency sub-site, used by customers and applicants.

Seedstone Capital (Pty) Ltd is a micro-lender licensed and regulated by the Non-Bank Financial Institutions Regulatory Authority (NBFIRA) of Botswana, and is the controller of the personal data described below. You do not need to install or open the app to make a request.

1. How to request deletion

Send us an email and we will handle the rest. No account, login or app is required.

What happens next: we verify that the request comes from the account holder, confirm by reply, and then delete all eligible data within 30 days of verification. If any data must be retained for the legal reasons set out in section 4, our reply will tell you exactly what is being kept and for how long. There is no charge for a deletion request.

We only need enough information to confirm the account is yours. If we cannot verify a request we will not act on it, because deleting an account on an unverified instruction would itself be a security risk.

2. What is deleted - Halo agent accounts

On a verified request we delete your Halo agent account and profile, including:

Account & profile

Full name, email address, phone number, national ID (Omang) number, profile photo and any identity document you uploaded.

Field activity

Leads you captured, activity-log entries, planner stops and any location data recorded by the app - except where that activity forms part of a submitted loan or insurance application (see section 4).

Sign-in & device

Passcode and two-factor security data, push-notification tokens, and all active sessions on every device.

App data on your phone

Uninstalling Halo removes the local cache and any offline drafts held on the device. Nothing is left behind on the phone.

3. What is deleted - customer accounts

If you registered on seedstone.co.bw but never submitted a loan or insurance application, we delete your account in full: your login, contact details, any partially completed application draft and any documents you uploaded.

Account & login

Email address, password credentials, active sessions and password-reset tokens.

Contact & identity data

Name, phone number, physical address, national ID (Omang) number and date of birth.

Incomplete applications

Draft applications, uploaded payslips, bank statements and ID scans that were never submitted for assessment.

Marketing

Newsletter subscription and any marketing contact history. You can unsubscribe at any time without deleting your account.

If you have submitted an application, we delete everything that is not covered by the legal retention rules in section 4, and we stop using your data for anything other than meeting those obligations.

4. What we must retain, and why

Some records cannot be deleted on request. As a licensed financial institution, Seedstone Capital is required by Botswana law and NBFIRA regulation to keep them for a set period, for audit, regulatory reporting, anti-money-laundering and fraud-prevention purposes.

Submitted applications

Information forming part of a submitted loan or insurance application, and the related financial and transaction records, are retained for a minimum of 7 years in line with NBFIRA record-keeping requirements, then deleted or anonymised.

Declined applications

Basic records of a declined application are retained for 3 years for regulatory and dispute-resolution purposes.

Agent-attributed business

Where a Halo agent submitted an application on a customer's behalf, the agent's name and identifier stay attached to that application record for the same retention period, so the transaction remains auditable. The agent's account itself is still deleted.

Customer records captured by an agent

Records about customers a Halo agent captured belong to Seedstone's own systems and are governed by the Privacy Notice. Deleting an agent account does not delete customer records, and an agent cannot request deletion of another person's data.

Legal & fraud holds

Data subject to an active legal claim, regulatory investigation or confirmed fraud record is retained until that matter is closed.

Retained records are locked down to the minimum staff who need them, and are not used for marketing or any new purpose.

5. Deleting your account instead of the data

If you only want to stop using the service, you can ask us to deactivate your account rather than delete it. Deactivation disables sign-in and all notifications while leaving your record intact, which is useful for an agent who may return, or a customer with a live application. Say so in your email and we will confirm which option we have applied.

6. Contact

Seedstone Capital (Pty) Ltd · P.O. Box 501359, Gaborone, Botswana
info@seedstone.co.bw · +267 75 660 568

For the full picture of what we collect and why, see our Privacy Notice. If you are not satisfied with how we have handled your request, you may contact NBFIRA at www.nbfira.org.bw.