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Updated: June 14, 2021

betway botswana Air Corporation and its affiliates and subsidiaries (“we”, “us” or “our”) respect your concerns about privacy. This Privacy Policy (“Privacy Policy”) applies to the information about you that we collect on betway botswanaair.com and any of our other websites that link to this Privacy Policy (each, a “Site” and collectively, the “Sites”), as well as through our customer experience centers (“CX Centers”). This Privacy Policy is incorporated into, made subject to and is governed by, our Web Site Terms of Use (the “Terms”). By accessing any of our Sites or contacting our CX Centers you agree to be bound by the Terms, including this Privacy Policy.

This Privacy Policy describes the types of information we collect via the Sites, how we may use such information, with whom we may share such information, and what we do to protect such information. We also tell you how you can reach us to ask us to update your preferences regarding how we communicate with you, or answer any questions you may have about this Privacy Policy.

If you access any of our Sites, or communicate with our CX Centers, in the scope of your employment or otherwise in connection with your responsibilities to your employer, our collection and use of your information may be governed by, and subject to, a separate agreement between us and your employer, instead of this Privacy Policy. You should confirm with your employer whether any such separate agreement exists that governs our collection and use of your information. To the extent there is a conflict between this Privacy Policy and another agreement between us and you or your employer, that agreement shall prevail.

 

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Identifying Information, Transactional Information, Site Information and Information You Provide: When you use any of the Sites or communicate with the CX Centers, you may provide to us (and, if so, we will collect) information that will identify you or make you identifiable, including your name, e-mail address, telephone number, Site access credentials, the country in which you are located, your company name, and your job level. We also may collect information regarding any transactions or purchases you make through the Sites (e.g., products purchased, frequency of purchases, etc.); information regarding your use of the Sites; and any other information that you provide or otherwise make available to us in connection with the Sites. We may record conversations that you have with our CX Center representatives. You may choose not to provide certain information to us, but as a result you may not be able to take advantage of some of the features of the Sites or access or receive certain of our products or services.

Cookies & Automatically Collected Information: When you visit our Sites, we use technologies such as cookies, web server logs and web beacons to collect certain information about you. Cookies are small files that websites and email servers place and access on your computer or other Internet-connected devices to uniquely identify your browser or device or to store information or settings in your device. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict, disable or delete certain cookies. Please note, however, that without certain cookies, you may not be able to use all of the features of our Sites.

Our web servers log information such as your device and operating system type, browser type, domain, device ID, Internet Protocol (“IP”) address and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server also logs information such as the address of the web page that referred you to our Site and the IP address of the device you use to connect to the Internet.

To control which web servers place and access cookies and collect information automatically, we place tags on our webpages called “web beacons”, which are small files that allow us to understand the actions of visitors to our Sites. We use similar technology in marketing emails we send, which may enable the placing or accessing of cookies, and also enable us to know if you received the email, if the email was opened and if you clicked on any links included in the email.

Third-Party Data Collection & Data Collection for Marketing Purposes: We use third-party web analytics services on our Sites (such as Google Analytics). These service providers use cookies and web beacons or other similar technology to help us analyze how users use the Sites. The information collected by such technology (including, where applicable, your IP address) will be disclosed to (or collected directly) by these service providers, who use the information to facilitate the evaluation of your use of the Sites on our behalf. Google Analytics, for example, uses cookies to track your interactions with our Sites. Google collects information and reports it to us, without identifying individual users. This information helps us improve our Sites so that we can better serve users. For more information on Google Analytics, please visit www.google.com/policies/privacy/partners/. You can also view Google Analytics' currently available opt-outs for the web at https://tools.google.com/dlpage/gaoptout.

Third-parties also collect information about your online activities over time and across different sites when you use our Sites. For example, third-party providers of certain embedded content and tools on our Sites (such as an embedded Twitter or Facebook feed, or an embedded blog commenting system, or any social network that you can use to log in to our Site or to submit information to our Site) collect information directly from you in connection with your interaction with such content and tools. You may review your privacy settings for your accounts with such third-party providers through their respective websites.

Information about your activities on our Sites is collected for use in providing advertising tailored to your individual interests on other websites and online services. You may choose whether to have your information collected for that purpose. We participate in advertising services administered by third-parties. These ad services track your online activities over time by collecting information through automated means, including through the use of the automated technologies described above, and such ad services may use this information to show you advertisements that are tailored to your individual interests and/or based on prior visits to our Sites. We and our third-party service providers use first-party cookies and third-party cookies alone or together, as well as other automated means, and the data collected through such means and from other sources to: (i) inform, optimize, and serve ads (including ads based on past visits to our Sites), and (ii) report on our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services (including how they are related to visits to our Sites).

 

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We use the information we obtain about you when you visit the Sites or contact the CX Centers to:

  • manage or service your account (or the account of the person or entity you represent);
  • fulfil transactions and orders;
  • communicate with you (or the person or entity you represent);
  • assist in marketing and advertising;
  • perform business analytics and business operations;
  • assist our quality and training efforts; and
  • comply with applicable law.

We retain information only for so long as it is necessary or relevant to fulfill the above-mentioned purposes or comply with applicable law, resolve disputes, troubleshoot problems or assist with investigations. After it is no longer necessary for us to retain your information, we dispose of it in accordance with our data retention and disposal policies.

 

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Third-Party Service Providers: We engage in transfers of information collected from you to third-party service providers that we use to support the provision of the Sites, the CX Centers and our services. As allowed by applicable law, we may also disclose automatically collected and other aggregated information with our third-party service providers, to assist such parties in assisting us in understanding the usage, viewing, and demographic patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Sites; such third-party service providers shall not make use of your information for any other purpose. We only transfer information to our third-party service providers that contractually agree to protect such information in a manner that is no less restrictive than the standards set forth in this Privacy Policy.

Affiliates, Joint Marketing Partners; and Authorized Distributors: As allowed by applicable law, we also share information among our affiliates and joint marketing partners for the purposes described in this Privacy Policy. Note also that certain betway botswana Air products are provided via our distributors. If you provide us information at the Sites or during a call to a CX Center in regards to a betway botswana Air product offered and sold by our authorized distributors, you acknowledge and agree that we may provide such information to the authorized distributors who offer and sell such products. The authorized distributors may use such information for the purpose of contacting you for follow-up regarding your requests, offering or selling our products (or their services related to such products), keeping you informed of new activities, or for other business purposes of such authorized distributors.

As Required by Law: Subject to applicable law, we disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.

Mergers, Acquisitions & Reorganizations: In the event that all or a portion of our business or its assets are acquired by, reorganized or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from users in connection with such acquisition, reorganization or merger. In such an event, we will require any such third-party to agree to treat your information in a manner that is no less restrictive than the standards set forth in this Privacy Policy.

 

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If you would like to update or modify your information or subscription preferences, you may contact us as described in the Contact Us section below. You also may unsubscribe from any of our promotional emails by clicking on the “unsubscribe” link in any promotional email you receive from us. Changes made to your profile will be effective once saved into our systems in accordance with our standard procedures for implementing user questions regarding your Personal Information.

 

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You have access to your information through your user account on our Sites. You can correct and update this information using this access. You may obtain a copy of your information or have it corrected, if it is incorrect, by sending us a written request by e-mail.

No request for access, rectification or deletion may be considered unless it is made in writing by you when you prove that you are the individual concerned (or the representative, heir or successor of that individual, or the liquidator of the succession, a beneficiary of life insurance or of a death benefit).

When we receive a request for access, rectification, or removal, we will attempt to respond within a reasonable timeframe after receipt of the request.

In certain situations, we may not be able to provide access to all the information we hold about you. Exceptions to the access requirement are meant to be limited and specific. The reasons for denying access will be provided to you upon request.

Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons and information that is subject to solicitor-client or litigation privilege.

A reasonable fee may be charged for the transcription, reproduction, or transmission of your information.

 

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We use commercially reasonable efforts to safeguard and protect the security of all data, inclusive of any information collected by us from you through the Sites and the CX Centers. It is also important for you to comply with the access controls (e.g., username/password management) and other applicable provisions of the Terms to protect against unauthorized access to the devices you use to access the Sites.

Unfortunately, it is impossible for us to guarantee the absolute security of all information collected or transmitted through our Sites or the CX Centers.

You therefore understand and agree that (i) there are limits to the security and confidentiality of the information we collect that are beyond our control; (ii) the security, integrity and confidentiality of all information and data exchanged between you and us through our Sites and at our CX Centers cannot be guaranteed; and (iii) such information may be viewed or altered by a third party at the time of transfer. For these reasons, we cannot be held responsible for any loss, capture or alteration of such information.

 

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Our Sites may provide links to other websites for your convenience and information. Those linked websites may be operated by companies not affiliated with us and we do not control or endorse any such websites. Linked websites may have their own privacy policies, which we strongly suggest you review if you visit any linked websites. You agree that your use of a linked website is at your own risk and that we are not responsible for the content of any linked websites that are not affiliated with us, any use of those websites, or the privacy practices of those websites.

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In addition to any other applicable provisions of this Privacy Policy, if you are a resident of California, you may have additional rights pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). This section describes those rights and how to exercise them. As used in this section, the term “personal information” has the meaning given it in the CCPA.
 

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Pursuant to the CCPA, you have the right to know:

  • the categories of personal information that we have collected about you;
  • the categories of sources from which the personal information is collected;
  • our business or commercial purpose for collecting or selling personal information;
  • the categories of third parties with whom we share personal information (if any); and
  • the specific pieces of personal information that we have collected about you.

 

In connection with any personal information we may sell or disclose to a third party for a business purpose, you also have the right to know:

  • the categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
  • the categories of personal information that we disclosed about you for a business purpose.
     

You have the right to deletion of your personal information from our records and those of our service providers, unless an exception applies under the CCPA.

 

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • deny goods or services to you;
  • charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • provide a different level or quality of goods or services to you; or
  • suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

 

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To request access to or deletion of your personal information, please use the contact information in the section below entitled Contact UsPlease note that you may only make a CCPA related disclosure or deletion request twice within a 12-month period. 

 

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To protect the security of your information, for all access and deletion requests you will need to provide us with enough information to verify your identity. The information you provide must match the information we know about you. Additionally, if you request specific pieces of your personal information or the deletion of certain personal information, you may be required to provide a signed declaration under penalty of perjury and otherwise authenticate your identity. We are not obligated to process a request if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

 

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The table here sets forth the categories of personal information we collect with respect to California residents.

 

How Your Personal Information is Collected:

 

The section of this Privacy Policy entitled Information We Collect describes how we collect your personal information.

 

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We are not in the business of selling personal information, and do not believe that our business practices constitute a sale of your personal information. As described under the section titled Affiliates, Joint Marketing Partners; and Authorized Distributors, we may provide your information to our authorized distributors if, in your communication to us, you expressed an interest in or inquired about any betway botswana Air products that are provided via such authorized distributors.

 

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You are permitted to designate an authorized agent to make a CCPA request on your behalf. Your authorized agent can use the methods described above to submit the request and will be required to provide proof of authorization.

 

 

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In addition to any other provisions of this Privacy Policy applicable to your information, the following provisions apply to information that is received from the European Union (“EU”).

 

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The EU General Data Protection Regulation (“GDPR”) requires us to explain the legal justification for our use of your information. As described above under the section entitled How We Use the Information We Collect, we use the information we collect from you for various purposes. We rely on the following legal bases in connection with our processing of such information: 

  • Processing is necessary to provide a service or feature you request. This includes processing, evaluating, and respond to your requests, inquiries, and applications; monitoring compliance with and enforcing our Terms; and providing Site features and functions you use.
  • Processing is necessary to pursue our legitimate interests and we have taken steps to ensure that our interests do not unduly intrude on your privacy. We rely on this justification when we monitor aggregate Site usage metrics such as total number of visitors and pages viewed; analyze the information we collect to improve performance and better understand the preferences of our customers; record telephone conversations in connection with our CX Centers for record-keeping, quality and training purposes; develop and improve our marketing materials, and, where permitted, contact you with marketing communications; and to protect our legal rights, resolve disputes, troubleshoot problems or assist with investigations.
  • Processing is necessary to comply with our legal obligations, such as to meet our record-keeping obligations.
  • Any purpose for which you actively consent, such as to place non-essential cookies and if you agree that we may contact you with relevant marketing information.
     

Where we rely on consent, you have the right to withdraw your consent to the processing of your information at any time by providing notice to us using the contact information below in the section entitled Contact Us.

 

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We transfer information we collect about you to the United States and other countries that do not have the same data protection laws as the country in which you initially provided such information. When we transfer your information to countries that are not considered by the European Commission to provide adequate protection, we rely on European Commission-approved agreements in accordance with Article 46 of the GDPR to protect your information in the countries to which it is transferred.

 

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We will store the information of individuals in the EU for the following periods:

  • Information Collected from Cookies: the cookies we use expire after 13 months, after which we will ask your consent again to place cookies.
  • Customer Service: we retain information about any customer service inquiries (including recorded conversations with our CX Centers) for 10 years after the question is resolved.
  • Business Transactions: we retain information about transactions with you (including recorded conversations with our CX Centers) for 10 years after we terminate our business relationship.
     
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You have the right to request that we take any of the following actions with respect to your information:

  • Rectify any of the information about you that is inaccurate;
  • Complete any of your information that is incomplete;
  • Erase or restrict the processing of information about you, where we do not have the right to retain or continue using it in light of the circumstances of your request; and
  • Provide you a copy of the information you have provided us directly in a structured, commonly used and machine-readable format that can be transmitted to a third-party (i.e., portability).

You may also object to our use of your information for our legitimate interests as described above. We are not required to comply with your request if we have compelling interests or are legally required to override your request.

 

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We do not currently respond to browser “Do Not Track” signals.

 

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Under California Civil Code, Section 1789.3, California residents are entitled to the following consumer rights notice: If you have a question or complaint regarding the Sites, or any products offered through the Sites, California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834 or by phone at 916-445-1254 or 800-952-5210.

 

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We may update this Privacy Policy periodically without prior notice to you to reflect changes in our information practices or with respect to applicable laws. We will post the updated version on our Sites and indicate at the top when it was last updated.

Please revisit this page periodically to stay aware of any changes to this Privacy Policy. Our amended Privacy Policy will automatically take effect upon the date that an update is published. Your continued use of the Sites after the updated Privacy Policy has become effective indicates that you have read, understood and agreed to the then-current version of the Privacy Policy.

 

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We have established procedures to receive complaints and inquiries about this Privacy Policy and our practices for the management of information. The complaints procedure is easily accessible and simple to use. We will inform any person making an inquiry or complaint of the existence of the relevant procedures. Should you have any complaints regarding the use of your information by us, please contact us using the contact information provided below. We will investigate all complaints. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices. For individuals in the EU, you also have the right to lodge a complaint with a supervisory authority in the country you reside, work or where you feel an infringement has occurred.


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If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us as indicated below:

Phone: 877-722-3741
Email: dataprivacy@sealedair.com

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