Privacy Notice

1. Who We Are

Seedstone Capital (Pty) Ltd is a licensed micro-lender registered and regulated by the Non-Bank Financial Institutions Regulatory Authority (NBFIRA) of Botswana. We also operate Seedstone Insurance Agency, the insurance arm hosted as a sub-site of seedstone.co.bw. We are the controller of personal data collected through this website, our loan application process, our insurance business, and the Halo sales-agent app.

Contact: info@seedstone.co.bw · P.O. Box 501359, Gaborone, Botswana

2. What Data We Collect

• Identity data: full name, national ID / Omang number, date of birth, gender
• Contact data: phone number, email address, physical address
• Financial data: employer name, position, gross and net salary, bank account details
• Document data: scanned copies of ID, payslips, bank statements, and employment confirmation
• Technical data: IP address (used for fraud detection only), browser type

3. How We Use Your Data

• To assess and process your loan application
• To verify your identity and prevent fraud
• To communicate with you about your application status
• To comply with NBFIRA reporting requirements and anti-money-laundering obligations
• To maintain records as required by Botswana law

We do not sell or share your personal data with third parties for marketing purposes.

4. The Halo Sales-Agent App

Halo is our field sales-agent Android app, published on Google Play by Seedstone Capital (Pty) Ltd and used only by authorised Seedstone agents. It is not a customer app.

• Agent data: name, phone number, email address, national ID (Omang) number, profile photo, identity document, and passcode / two-factor security data - used to authenticate the agent and attribute the business they write.
• Location data: collected only while the agent is signed in and working, to plan visit routes and confirm that field activity took place. It is not shared with third parties or used for advertising.
• Customer data captured in the field: where an agent captures a lead or completes an application on a customer’s behalf, that data is handled under this same notice, and the customer’s consent is recorded at the point of capture.
• Transmission: data moves between Halo and our systems over TLS on a signed, authenticated API. It is not sold, and it is not shared with advertising or analytics brokers.

Agents can request deletion of their Halo account at any time - see Account & Data Deletion.

5. Data Retention

Loan application records are retained for a minimum of 7 years in accordance with NBFIRA requirements. If your application is declined, basic records are held for 3 years for regulatory and dispute-resolution purposes.

6. Your Rights

You have the right to access, correct, or request deletion of your personal data, subject to legal retention obligations. To exercise these rights, contact us at info@seedstone.co.bw, or follow the steps in our Account & Data Deletion policy.

7. Security

We use industry-standard encryption (TLS 1.2+) for all data in transit. Application data is stored in a secured cloud database with access controls restricted to authorised staff only. Documents are stored in encrypted object storage.