TERMS OF USE

Bots Voucher (Pty) Ltd
TERMS OF USE
Last Updated: 11.03.2026
1. INTRODUCTION
1.1. These terms and conditions govern the purchase of OTT Vouchers, and the use of OTT’s website, OTT’s services and OTT’s platform (“the App”).
1.2. These terms and conditions apply to the Website (www.ottvoucher.com) and to any related mobile sites (mobi-sites) or software applications made available by OTT from time to time.
1.3. These terms and conditions contain provisions which may limit the risk or liability of OTT or a third party, compel you to indemnify OTT, or create risk or liability for you. If there is any provision in these terms and conditions that you do not understand, or that may affect you materially, it is your responsibility to seek independent professional advise and/or ask OTT to explain it to you before you purchase an OTT voucher or use the Website.
1.4. By using or registering a profile on the Website, by purchasing or redeeming an OTT Voucher, or by using OTT’s services or App, you represent that you have read, understood and agree to be bound by these terms and additions.
1.5. These terms and conditions are subject to change from time to time. Updated versions of OTT’s terms and conditions are available herein or on request via email or WhatsApp. OTT’s contact details are on the Website. OTT will endeavour to notify registered users of any material changes in advance when a user opens/signs in to the App. Your continued use of the Website after such notice will constitute your acceptance of the updated terms.
1.6. OTT provides digital payment services. OTT is not a bank, financial services provider or a financial advisor. The contents of the Website are for information and marketing purposes only and must not be construed as financial advice.
1.7. You are responsible for ensuring that all information provided to OTT when registering a profile or purchasing an OTT Voucher is true and correct. OTT assumes that all information provided by you is correct and assumes no liability whatsoever as a result of incorrect or incomplete information provided.
1.8. It is your responsibility to immediately notify OTT upon suspecting or becoming aware of any unauthorised access to or use of your profile or your username and password by third parties. You must take prompt action to mitigate any resultant loss or harm, including changing your password and informing OTT of any suspected breach.
1.9. In certain circumstances OTT may be required by law (including under KYC, AML or other regulatory obligations) to request documentation and information from you, for example, for verification purposes. OTT may in its sole discretion suspend or terminate the selling of vouchers to you or the redeeming of vouchers by you and your use of the Website until OTT is satisfied that the requested information or documentation has been provided.
1.10. OTT Vouchers can be purchased on the Website, App or at any one of our participating issuing merchants. OTT Vouchers can be redeemed at any accepting merchant.
2. EXCLUSION OF LIABILITY AND DISCLAIMER
2.1 By purchasing or redeeming OTT Vouchers, registering an OTT profile or using the Website, you assume the risks associated with those activities and you agree to indemnify OTT to the extent permitted by law.
2.2 The use of the Website is entirely at your own risk, and you assume all responsibility for any risk or loss resulting from your use or reliance on the Website. OTT disclaims, to the fullest extent permitted by the applicable laws, liability for any damage, loss or expenses, whether direct, indirect or consequential in nature, arising out of or in connection with your access to or use of the Website or any content therein.
3. OTT VOUCHERS
3.1 OTT Vouchers are redeemable in the Territory of issue, as identified by the voucher’s unique code. Redemption is subject to local laws and regulations.
3.2 OTT Vouchers can be purchased in denominations ranging P5 to P5,000. OTT reserves the right, in its sole discretion, to impose further limits or vary the transaction volumes at any time.
3.3 Nothing in these terms and conditions is intended to or shall be interpreted to unlawfully restrict, limit, or avoid any rights or obligations created for consumers under the Consumer Protection Act 2018 (CPA).
3.4 Unless required by law (including the CPA), OTT Vouchers are not refundable, and OTT will not accept the return of its vouchers.
3.5 OTT’s refund process (if and where applicable) will be conducted within a reasonable period after verification and may require supporting documentation or proof of purchase.
3.6 Consumers have the right to request written reasons for any decision to decline a refund or redemption, and OTT shall provide such reasons upon request.
3.7 Vouchers cannot be replaced if lost or stolen. OTT Vouchers that are damaged or destroyed cannot be used. In case of loss or theft, you must notify us immediately, but replacement is not guaranteed and is subject to the issuer/merchants’ terms and conditions.
3.8 Once an OTT Voucher is redeemed, that transaction cannot be cancelled or reversed by OTT, except where required by law.
3.9 OTT Vouchers expire after 36 (thirty-six) months from date of purchase. If an OTT voucher expires, any remaining balance on that OTT Voucher will not be redeemable.
3.10 The redemption of OTT Vouchers is dependent on third parties and OTT cannot be responsible for delays, interruptions or other events that prevent you from redeeming OTT Vouchers as such redemption is subject to the relevant issuer’s system availability.
4. USE OF THE WEBSITE
4.1 By using the Website, you warrant that you are 18 years or older and of full legal capacity if you are a juristic person or acting on behalf of a juristic person.
4.2 You agree that you will not in any way use any device, software or other instrument to interfere or attempt to interfere with the proper working of the Website. In addition, you agree that you will not in any way use any robot, spider, other automatic device, or manual process to monitor, copy, distribute or modify the Website or the information contained herein, without the prior written consent from an authorised OTT representative (such consent is deemed given for standard search engine technology employed by Internet search websites to direct Internet users to this Website).
4.3 You may not use the Website to distribute material which is defamatory, offensive, contains or amounts to hate speech or is otherwise unlawful.
4.4 You may not in any way display, publish, copy, print, post or otherwise use the Website and/or the information contained therein without the express prior written consent of an authorised OTT representative.
4.5 OTT gives no warranty that the Website is free of viruses, or that your system will not be corrupted, damaged, or affected by your use of the Website. Your access to and use of the Website is at your own risk. OTT will notify users of any security breaches or data losses that may affect their personal information or account security.
4.6 The Website may not always be available to you. There are many reasons for this such as technical problems, maintenance and other circumstances beyond our control. OTT is entitled to discontinue providing the Website or any part thereof to you.
4.7 OTT may in its sole discretion terminate, suspend and modify the Website. You agree that OTT will not be liable to you if it chooses to suspend, modify or terminate this Website other than for processing OTT vouchers purchased by you prior to such time, to the extent possible.
4.8 OTT may suspend or terminate your access to the Website if you fail to comply with your obligations under these terms and conditions, if OTT suspects fraud or if required for legal or regulatory reasons.
5. OTT WALLET TERMS OF USE
5.1 The OTT Wallet (“Wallet”) is a digital store-of-value feature available through the App and Website, linked to your registered OTT profile and unique mobile number or identifier.
5.2 The primary purpose of the Wallet is to hold unused or remaining value (“Change”) resulting from the partial redemption of an OTT Voucher at an accredited OTT merchant or retailer.
5.3 The Wallet is not a bank account, deposit account, electronic money account, payment account, or financial services product, and does not constitute legal tender.
5.4 No interest, yield, or other return is earned on any Wallet balance.
5.5 To access and use the Wallet, you must register an OTT profile in accordance with clause 2 and provide accurate and complete personal information, including a valid Botswanan identity number and a secure PIN.
5.6 You may only register and operate one Wallet, linked to one OTT profile.
5.7 The Wallet and its functionality are intended for use solely within the Republic of Botswana.
5.8 You are responsible for maintaining the confidentiality and security of your login credentials and PIN, and for all activity conducted through your Wallet.
5.9 When an OTT Voucher is partially redeemed at an accredited merchant, any unused value will automatically be credited to your Wallet.
5.10 Wallet balances may be viewed within the App or Website interface at any time.
5.11 You may use your Wallet balance to generate one or more new OTT Vouchers for future redemption, subject to applicable minimum and maximum denomination rules determined by OTT.
5.12 OTT Vouchers generated from Wallet balances may only be redeemed at approved OTT merchant or retail partner platforms.
5.13 Wallet balances and vouchers are non-transferable, non-refundable, and may not be exchanged for cash.
5.14 Unless a voucher or token is expressly designated by OTT as a “no-change” voucher, any unused value after redemption will be credited to your Wallet.
5.15 Wallet balances associated with expired or forfeited vouchers will not be recoverable.
5.16 You use the Wallet at your own risk. OTT will not be liable for any loss or damage arising from unauthorised access to your Wallet where the correct username, password, or PIN has been used, unless such loss is caused by OTT’s gross negligence or wilful misconduct.
5.17 OTT is an accountable institution for purposes of the Financial Intelligence Act, 2019 (“FICA”).
5.18 OTT may request additional information or documentation to verify your identity, monitor transactions, or comply with anti-money laundering and counter-terrorist financing obligations. Failure to provide requested information may result in the suspension or restriction of your Wallet and related services.
5.19 To the maximum extent permitted by law, OTT shall not be liable for any indirect, incidental, consequential, or economic loss arising from the use of the Wallet. Nothing in these Terms limits or excludes any liability that cannot be excluded under the Consumer Protection Act 2018.
6. PROMOTIONS & COMPETITIONS
6.1 OTT may from time-to-time conduct or promote competitions, promotions, or prize draws through the App or other OTT platforms.
6.2 Participation in any competition is voluntary and subject to the specific competition rules and OTT’s Competition Terms and Conditions, which are available at https://ottvoucher.com/wp-content/uploads/2026/01/Competition-Terms.pdf.
6.3 By entering a competition, you acknowledge that you have read, understood, and agree to be bound by the applicable Competition Terms and Conditions.
7. REGISTRATION OF A PROFILE ON THE WEBSITE
7.1 You may register a profile only if you complete the profile registration requirements and are:
7.1.1 a natural person and at least 18 years of age and possess a valid identity document; or
7.1.2 a juristic person acting through an authorised natural person who meets the criteria in 7.1.1;
7.2 You may only register and use one profile, and OTT may suspend or terminate the use of your profile if it suspects that you have created multiple profiles. You may not permit another person to access your profile.
7.3 When registering a profile, you must provide a unique username and password and provide certain information and personal details to OTT. You will need to use your unique username and password to access your profile.
7.4 You agree and warrant that your username and password shall:
7.4.1 be used for personal use only; and
7.4.2 not be disclosed by you to any third party.
7.5 OTT recommends that you use a strong and unique password and that you change your password regularly.
7.6 You agree that, once the correct username and password relating to your account have been entered, irrespective of whether the use of the username and password is unauthorised or fraudulent, OTT cannot be held liable for any transactions on your behalf.
7.7 You must provide accurate and up-to-date information when registering a profile on the website. You are responsible for maintaining the accuracy of your profile information.
8. SUSPENSION AND TERMINATION OF SERVICES
8.1 OTT processes payments in accordance with your instructions, subject to these terms and conditions and the law.
8.2 OTT Vouchers are not intended for re-sale or for any fraudulent, illegal or unlawful activity or purpose. If OTT suspects that your profile or an OTT voucher purchased by you is being or will be used for illegal or fraudulent purposes, OTT may in its sole discretion suspend, terminate or deactivate your use of the Website or any OTT voucher purchased by you.
8.3 OTT may its sole discretion suspend, terminate or deactivate your profile or your use of OTT’s services if OTT suspects that your use of OTT Vouchers or the Website is suspicious, unlawful, illegal or not in line with the intended purpose of OTT Vouchers and OTT’s services.
8.4 If your account is suspended or terminated, you may appeal the decision by contacting our customer support team.
8.5 OTT is not obliged to enable transactions if there are not sufficient funds to enable that transaction.
9. OWNERSHIP AND COPYRIGHT
9.1 The contents of the Website, including any material, information, data, software, icons, text, graphics, lay-outs, images, sound clips, advertisements, video clips, trade names, logos, trade-marks, designs and service marks which are displayed on or incorporated in this Website (“Website Content”) are protected by law, including but not limited to copyright and trade mark law. The Website Content is the property of OTT, its advertisers and/or sponsors and/or is licensed to OTT.
9.2 You will not acquire any right, title or interest in or to the Website or the Website Content.
9.3 Any use, distribution or reproduction of the Website Content is prohibited unless expressly authorised in terms of these terms and conditions or otherwise provided for in law. All rights not expressly granted herein are reserved. Contact us to obtain permissions for the commercial use of any Website Content.
9.4 OTT reserves the right to act against users who infringe on its intellectual property rights, including but not limited to, terminating their account or seeking legal remedies.
9.5 Where any of the Website Content has been licensed to OTT or belongs to any third party, your rights of use will also be subject to any terms and conditions which that licensor or third party imposes from time to time, and you agree to comply with such third-party terms and conditions.
10. LINKING TO THIRD PARTY WEBSITES
10.1 This Website may contain links or references to other websites (“Third Party Websites”) which are outside of our control, including those of advertisers. These terms and conditions do not apply to those Third-Party Websites and OTT is not responsible for the practices and/or privacy policies of those Third-Party Websites or the “cookies” that those sites may use.
10.2 Notwithstanding the fact that the Website may refer to or provide links to Third Party Websites, your use of such Third Party Websites is entirely at your own risk and OTT is not responsible for any loss, expense, claim or damage, whether direct, indirect or consequential, arising from your use of such Third Party Websites or your reliance on any information contained thereon.
11. BREACH
11.1 OTT may give you written notice, including via e-mail, requiring you to remedy any breach within 5 days. If you fail to remedy the breach within that time, OTT may stop you from using the Website.
11.2 OTT may terminate or suspend your use of the Website immediately (without prior notice) if we suspect that your profile is being used wrongfully or illegally or that continuation of your access would expose OTT or its users to risk, or if OTT is required to do so for legal or regulatory reasons.
12. PRIVACY NOTICE
12.1 OTT takes the protection of your personal information and privacy seriously. OTT will only collect, use, store, and disclose your personal information in accordance with the Data Protection Act, 2018 and Data Protection Act, 2024 (Act 18 of 2024) and OTT’s Privacy Notice, which is available at which can be found at https://ottvoucher.com/wp-content/uploads/2026/01/Privacy-Notice.pdf .
12.2 You acknowledge and agree to the terms of our Privacy Notice, which is incorporated into and forms part of these terms and conditions.
12.3 OTT’s Privacy Notice sets out how we collect, use, store, and disclose your personal information, including but not limited to:
12.3.1 Your name, address, and contact information; and
12.3.2 Your transaction history with us.
12.4 OTT complies with its obligations under the Data Protection Act, 2018 and new Data Protection Act, 2024 (Act 18 of 2024) and any applicable Regulations promulgated thereunder. If your personal information is to be transferred outside the Republic of Botswana, such transfer will be subject to the safeguards required under that Act.
12.5 If you have any questions or concerns about how we handle your personal information, please refer to our Privacy Notice which can be found at https://ottvoucher.com/wp-content/uploads/2026/01/Privacy-Notice.pdf .
13. FORCE MAJEURE
13.1 OTT shall not be liable for any failure, delay, or default in the performance of its obligations under these terms and conditions, if and to the extent that such failure or delay is caused by circumstances beyond its reasonable control, including but not limited to: acts of God, fire, flood, earthquake, storm or other natural disaster, war, civil unrest, acts of terrorism or sabotage, strikes, lockouts, or industrial disputes, failure or interruption of electricity, telecommunications, or network services, government actions, orders, or restrictions, pandemics, epidemics, or quarantine restrictions or any other event which is not within OTT’s reasonable control (“Force Majeure Event”).
13.2 In such an event, OTT’s obligations will be suspended for the duration of the Force Majeure Event, and OTT shall use reasonable efforts to mitigate the effects and resume performance as soon as reasonably possible.
14. DISPUTE RESOLUTION
14.1 OTT aims to resolve all disputes in a fair, transparent, and efficient manner. If you have a dispute, complaint, or query, you must first contact OTT’s customer support team at:
WhatsApp: +267 73 444 101
Email: support@tylersoft.net
Call: +267 73 444 101
Address: [JC1.1]Plot 75782, Pinnacle Park, Building 1, Setlhoa
14.2 OTT will endeavour to acknowledge your complaint within 48 hours and provide a written response within 10 business days.
14.3 If the matter is not resolved through OTT’s internal complaints process, you may choose one of the following options:
14.3.1 refer the matter to mediation through the Competition & Consumer Authority (CCA) or another recognised ombud service; or
14.3.2 refer the matter to a Small Claims Court (for claims below the monetary threshold prescribed under Botswanan law); or
14.3.3 refer the matter to binding arbitration under the Arbitration Foundation of Botswana (AFSA), if both parties agree that arbitration is appropriate.
14.4 Nothing in this clause limits your rights under the Consumer Protection Act 2018 or any other applicable legislation to seek redress through a competent court, tribunal, or regulator.
14.5 Where arbitration is agreed, it shall be conducted by a single arbitrator appointed by agreement between the parties or, failing agreement, by AFSA. The arbitration shall be conducted in English and held in Botswana. The arbitration proceedings shall be confidential unless disclosure is required by law
15. COMPLIANCE WITH LAWS
15.1 You agree to comply with all applicable laws, regulations and rules when using the Website or services, including without limitation consumer protection law, data protection law, payments and financial regulation, electricity supply regulation and export controls.
15.2 You are responsible for ensuring that your use of the website or services complies with the laws and regulations of your country or region.
15.3 OTT reserves the right to suspend or terminate your use of the website or services if we determine that your use is not in compliance with applicable laws or regulations.
16. NOTICES & CONTACT INFORMATION
16.1 All legal notices, communications, and service of process required or permitted under these terms and conditions shall be in writing and delivered to OTT at:
Address: Plot 75782, Pinnacle Park, Building 1, Setlhoa
Email: support@ott-mobile.com
Website: www.ottvoucher.com [JC2.1]
16.2 Notices to you will be delivered to the most recent e-mail address, mobile number, or postal address provided in your OTT profile, or by notice published on the Website.
16.3 Any notice:
16.3.1 sent by e-mail shall be deemed received on the day it is sent (if sent during business hours) or the next business day;
16.3.2 delivered by hand shall be deemed received upon delivery;
16.3.3 posted on the Website shall be deemed received within 24 hours of publication.
16.4 You are responsible for ensuring that your contact details are accurate and up to date. Failure to do so may result in you not receiving important communications
17. GENERAL
17.1 Each provision of these terms and conditions is severable from the other provisions. Should any provision be or become invalid or unenforceable for any reason the remaining provisions shall nevertheless remain binding and continue to be of full force and effect.
17.2 Should a discrepancy exist between any clause in these terms and conditions and any other terms or agreement that we may have with you, the relevant clause(s) in these terms and conditions shall prevail.
17.3 OTT will not be bound by any representation not recorded in these terms and conditions which are the sole record of OTT’s services offered to you.
17.4 By using the Website or by purchasing or redeeming an OTT voucher, you consent to receiving direct marketing communications in respect of OTT-related goods and services, unless you opt-out of receiving such directing marketing communications.
17.5 These terms and conditions shall be governed by and construed in accordance with the laws of the Republic of Botswana. Subject to clause 15 (Dispute Resolution), the courts of the Republic of Botswana shall have exclusive jurisdiction to resolve any proceeding in respect of these terms and conditions.
17.6 These terms (together with the Privacy Notice and any voucher terms) constitute the entire agreement between you and OTT regarding the subject matter herein and supersede all prior agreements.
17.7 OTT will communicate any material changes to these terms and conditions via notice on the Website.

VOUCHER TERMS & CONDITIONS

Bots Voucher (Pty) Ltd
VOUCHER TERMS & CONDITIONS
Last Updated: 11.03.2026
1. By purchasing, activating, redeeming, or attempting to use an OTT Voucher (“Voucher”), you agree to be bound by these Voucher Terms and Conditions, our General Terms of Service, and our Privacy Notice.
2. These terms constitute a legally binding agreement between you and Bots Voucher (Pty) Ltd [JC1.1](“OTT”, “we”, “us”, or “our”).
3. If you do not agree to these terms, do not purchase or use an OTT Voucher.
4. Vouchers are issued at OTT’s sole discretion and may only be purchased from OTT or authorised resellers or platforms.
5. OTT shall not be liable for Vouchers purchased from unauthorised or fraudulent sources.
6. Once purchased, Vouchers cannot be reloaded or have additional value added.
7. Vouchers are available in denominations ranging from P5 – P5000. OTT may vary available denominations or impose transaction limits at any time.
8. Vouchers are redeemable only within the Territory of issue, as identified on the Voucher, and subject to applicable laws and regulations.
9. Vouchers cannot be exchanged, sold, bartered, or redeemed for cash, nor combined with other rewards, discounts, or vouchers.
10. IMPORTANT NOTICE: Redemption depends on third-party systems (including banks, networks, retailers, or service providers). OTT is not responsible for delays, interruptions, or failures in those third-party systems that prevent redemption, to the extent permitted by law
11. Once a Voucher is redeemed, that transaction cannot be cancelled or reversed, except as required by law.
12. Vouchers are valid for 36 (thirty-six) months from the date of issue (which is the date the Voucher is first purchased).
13. Any remaining balance on a Voucher after expiry will be forfeited and cannot be reactivated, extended, or refunded.
14. Lost, stolen, damaged, or destroyed Vouchers may not be recoverable.
15. In the event of loss, theft, or damage to a Voucher, you must notify OTT immediately. In such circumstances replacement is not guaranteed and remains at OTT’s discretion.
16. OTT shall not be liable for any unauthorised use of a lost or stolen Voucher.
17. Unless otherwise required by law (including the Consumer Protection Act 2018 [“CPA”]), Vouchers are non-refundable.
18. Where refunds are permitted, OTT will process them within a reasonable time following verification and may require proof of purchase or supporting documentation.
19. Consumers may request written reasons for any refusal of a refund or redemption, and OTT will provide such reasons upon request.
20. Any fraudulent, abusive, or unlawful conduct aimed at obtaining or using a Voucher will constitute a breach of these terms.
21. OTT reserves the right to suspend, cancel, or deactivate any voucher or related account in such circumstances.
22. OTT processes personal information in accordance with the Data Protection Act, 2018 and Data Protection Act, 2024 (Act 18 of 2024)and its Privacy Notice. Personal information may be processed where it is necessary to issue, administer, redeem, or investigate Voucher transactions, to comply with legal obligations, or on another lawful basis under the Data Protection Act, 2018 and Data Protection Act, 2024 (Act 18 of 2024).
23. OTT may amend, update, or withdraw these Terms, or the Voucher programme, where required by law or for operational reasons, by publishing updated Terms.
24. Continued purchase or use of vouchers after amendments are published constitutes acceptance of the revised terms. Amendments will apply from the effective date stated and will not reduce the remaining value or validity period of any Voucher already issued, unless required by law.
25. You are responsible for reviewing the current Terms when purchasing or redeeming a Voucher.
26. Nothing in these terms is intended to unlawfully limit or avoid any consumer rights under the CPA.
27. These terms are governed by the laws of the Republic of Botswana.

11. Privacy Policy

Bots Voucher (Pty) Ltd
PRIVACY NOTICE
Last Updated: 11.03.2026
Please read this Privacy Notice carefully to understand how we handle your Personal Data. If you object to any part of this Privacy Notice, please refer to the ‘Contact us’ section of this Notice, and provide reasons for your objection, as soon as possible.
TABLE OF CONTENTS
1. INTRODUCTION
1.1. This OTT Mobile Technologies Privacy Notice explains how and why Bots Voucher (Pty) Ltd and all of its affiliated and associated entities within the Cliquefin group (collectively the “Cliquefin Group Entities”), - see full list available at https://cliquefin.com/, (“OTT”, “we”, “us”, or “our”) collects and processes your ‘personal data’ as a ‘data controller’ in relation to the OTT Platform, as a computer application and technology company which facilitates a digital payments ecosystem (“the Services”). https://cliquefin.com/.
1.2. We may share your personal data with the Cliquefin Group Entities only for specific and defined purposes, including but not limited to: (i) facilitating and verifying payment transactions; (ii) fulfilling regulatory and compliance obligations (including anti-money laundering and fraud prevention); (iii) providing customer support and account management services; and (iv) maintaining and improving the functionality, security, and performance of the OTT Platform. Each Cliquefin Group Entity processes personal data in accordance with this Privacy Notice and applicable data protection laws.
1.3. This Privacy Notice complies with applicable Data Protection Laws, and specifically facilitates the obligations required from the Data Protection Act, 2018 and Data Protection Act, 2024 (Act 18 of 2024) as well as the European Union General Data Protection Regulation, 2016/679 (“EU GDPR”).
1.4. The definitions of terms used in this Notice shall have the same meaning as in the applicable Data Protection Laws and its cognate terms shall be construed accordingly.
2. APPLICATION OF PRIVACY NOTICE
2.1. This Privacy Notice applies to all processing of Personal Data carried out by OTT as Data Controllers for the purpose of conducting its business operations, including e-commerce activities related to the sale, purchase, and payment for goods through OTT's platform.
2.2. This Privacy Notice applies to the following external parties:
2.2.1. our potential and existing clients;
2.2.2. users of our website and / or platform;
2.2.3. recipients of our Services; and
2.2.4. suppliers and contractors (“Vendors”);
2.3. Our commitments to job applicants, employees, and consultants are governed by separate privacy notices.
3. CONTACT US
3.1. For questions regarding this Privacy Notice, data protection rights, access to information rights, and any complaints, please contact our Information Officer or Deputy Information Officer at:
3.1.1. Information Officer
Ryan Muller
ryan@ott-mobile.com
3.1.2. Deputy Information Officer
Justin Course
justinc@ott-mobile.com
3.2. Further contact information and forms are attached to our PAIA Manual which is available on our website.
4. PERSONAL INFORMATION COLLECTED
In order to conduct its business and provide its services, OTT may collect the following personal data:
4.1 Account information - We collect the data you or your organization provide when creating an account or profile for the Services offered on our platform, such as:
4.1.1 First and Last Name;
4.1.2 Date of Birth;
4.1.3 Citizenship;
4.1.4 Passport / Identity Number;
4.1.5 Email address;
4.1.6 Contact number; and
4.1.7 Gender.
4.2 Payments and transaction details – We keep reasonable business records of your charges, payments, financial information, billing details and issues.
4.3 Platform settings and configurations – We record your configuration and settings, including resource identifiers and attributes, server information, passwords, service and security settings for data and other resources.
4.4 Your direct communications – We keep records of your communications and interactions with us and our partners (for example, when you provide feedback, ask questions or seek technical support).
4.5 Feedback – We collect your personal data when you use our site forms or live chat. We further record your responses to our surveys or when submitting reviews, feedback forms, or complaints. Participation in surveys and feedback submissions is entirely voluntary. Where possible, responses are anonymized to protect individual identities.
4.6 Technical and Usage Data – We collect information about usage, operational status, software errors and crash reports, authentication details, quality and performance metrics, and other technical details necessary for us to operate and maintain the Services and related software. This information includes device identifiers, identifiers from cookies or tokens, IP addresses and any other data collected by way of automated technologies.
4.7 OTT do not process special personal information or information relating to children in the ordinary course of business. We will only process special personal information only if we obtain your consent or have another valid justification to do so.
5 HOW DATA IS COLLECTED
5.1 Direct (Voluntary) Interactions: When you provide it directly to us, such as during user registration, account setup or when you submit support requests or enquiries.
5.2 Automated Technologies:
5.2.1 When you interact with our website, platform, or Services, we may collect technical and usage information automatically from your browser or device using cookies and similar technologies. This includes browsing data and cookies. For example, when you view our website, we can see:
5.2.1.1 what you click,
5.2.1.2 what you view,
5.2.1.3 how long you spend on pages,
5.2.1.4 your device and internet connection details such as type of device you are using, IP address and details about your internet connection, technical details such as your screen size and the software you are using, such as your web browser,
5.2.1.5 your country or region (not exactly where you are unless we ask permission), and
5.2.1.6 your unique advertising or other identification numbers allocated to your browser or device.
5.2.2 We do not often know exactly who you are from this data. But sometimes we may connect this data with other information we hold about you, for example, when you submit a ‘Contact Us’ request.
5.2.3 Cookies and similar technologies are set on your device by us and our trusted partners, such as Google Analytics.
To opt out of being tracked by Google Analytics across all websites, visit: http://tools.google.com/dlpage/gaoptout.
5.3 Third-Party Sources: We will only receive your personal data from third parties when (i) you have provided your consent to share such data with us, (ii) when required by law, (iii) when it is strictly necessary for us to fulfil our contractual obligations to you, or (iv) when it is strictly necessary to protect our or our Customer’s legitimate interests, or (v) to protect the vital interests of the data subject. These circumstances may include, but are not limited to:
5.3.1 Third-party payment processors: When processing your payments via payment gateways or payment processors, we may receive confirmation of payment or refund details from these providers to ensure successful completion of your transaction, and
5.3.2 Public sources: Public sources, such as Credit Bureau’s, are used solely for verifying customer information during onboarding. We implement safeguards to ensure no over-collection or misuse of publicly available data.
6 PROCESSING PURPOSE
6.1 OTT undertakes to process Personal Data only to the extent and in such a manner as is necessary to provide the services.
6.2 OTT further undertakes to process Personal Data reasonably and is committed to processing Personal Data in an adequate and non-excessive manner.
6.3 OTT will process Personal Data for the following purposes:
6.3.1 Consent - Where required by law, we will obtain your explicit consent (opt-in) to process your Personal Data. You may opt-out and withdraw this consent at any time.
6.3.2 Contract – Upon your registration, acceptance of our terms and conditions and/or completion of your profile with us, a valid contract comes into existence in terms of which we provide our services to you. We process your Personal Data, when it is necessary to perform our obligations under a contract we have with you as a customer, including to:
6.3.2.1 To act on or respond to instructions or requests for the provision of vouchers, competitions, computer applications, technological and other related services;
6.3.2.2 receive and process your orders for specific Services. This includes processing Data as needed to bill for the Services used or to ensure those services are delivered or working as intended, to detect and avoid outages or other technical problems, and to secure your data and services;
6.3.2.3 provide you with customer support;
6.3.2.4 process your payments, service credits or refunds;
6.3.2.5 respond to inquiries or complaints you make about our products or services, or enforce and collect on any agreement we have with you when you’re in default or breach our terms and conditions.
6.3.3 Legal Obligations - We process your Personal Data when required by law. For example, we may need to:
6.3.3.1 Verify your identity for compliance with the Consumer Protection Act or other legal requirements.
6.3.3.2 Retain transaction records for tax or regulatory purposes.
6.3.3.3 to process data subject access requests under applicable data protection laws;
6.3.3.4 to meet our record-keeping and data retention obligations;
6.3.3.5 to protect your vital interests or the vital interests of another natural person; and
6.3.3.6 for any other related and lawful purposes brought to your attention from time to time.
6.3.4 Legitimate Interests - We process Personal Data under legitimate interests only where such interests are not overridden by the rights and freedoms of the data subject. We process your Personal Data when pursuing our legitimate interests to offer the best service we can, and ensure our customers know how to get the most out of our Services, and to improve our Services to meet our customers’ needs. For example, we may process your Personal Data to:
6.3.4.1 answer any requests or questions you might have;
6.3.4.2 make recommendations to optimise the use of the Services, and provide information about new or related products and features;
6.3.4.3 use secure and effective third-party technology platforms to administer and manage the Services, our technology, and our infrastructure and communication systems;
6.3.4.4 prevent fraud, enhance security, and protect against unauthorized access to your account or our systems;
6.3.4.5 maintain the safety, security and integrity of the Services, our intellectual property, databases, networks, and other technology assets;
6.3.4.6 protect our rights in any litigation that may involve you;
6.3.4.7 perform general due diligence and risk assessments;
6.3.4.8 enforce and defend other legal claims;
6.3.4.9 manage business continuity incidents and emergencies;
6.3.4.10 determine the effectiveness of our sales, marketing, and advertising;
6.3.4.11 analyse and gather metrics to better understand how Customers and potential clients use our Services; and
6.3.4.12 achieve purposes otherwise described to you when collecting your data.
7 CONSEQUENCES OF FAILURE TO PROVIDE THE INFORMATION
If we are legally required to process certain Personal Data or need to do so under a contract with you, failure to provide the requested data (e.g., identification verification documents) may prevent us from fulfilling our contractual obligations. In such cases, we may be unable to proceed with or continue the contract and may have to terminate the agreement and/or our relationship with you. Any termination will be carried out with due notice and in accordance with the terms of the contract and applicable legislation.
8 PERSONAL INFORMATION SHARING
8.1 We may share your Personal Data with OTT Personnel or Suppliers/Vendors who perform technical services for us or on our behalf and under our instruction or authority as ‘Processors’ for the purposes listed under “Processing Purpose”.
8.2 We do not share Personal Data with companies, organizations, or individuals outside of OTT except in the following cases:
8.2.1 With your consent;
8.2.2 for external processing. We share Personal Data with trusted third-party providers to process it for us as we instruct them to in accordance with a contractual arrangement and in compliance with this Privacy Notice and appropriate confidentiality and security measures. For example:
8.2.2.1 billing data is shared with payment processors, vendors and suppliers, while technical details may be shared with server hosts, password managers, data centres and cloud service providers for troubleshooting purposes;
8.2.2.2 Personal Data is shared with our third-party providers when you request technical support services. We share the information you provide in the support ticket, and those providers may communicate with you or your administrator in that ticket, including providing updates and closing the ticket;
8.2.2.3 we share your contact details to enable communication and collaboration when you request professional services; and
8.2.2.4 Personal Data may be shared with backup and disaster recovery related service providers or software, as required.
8.2.3 for legal reasons. We share Service Data outside of OTT when we have a good-faith belief that access to, or disclosure that Service Data is reasonably necessary to:
8.2.3.1 comply with applicable law, regulation, legal process, or enforceable governmental requests,
8.2.3.2 enforce applicable agreements we have entered with you, including to investigate potential violations, detect, prevent, or otherwise address fraud, security or technical issues, or
8.2.3.3 protect and defend the rights, property or safety of OTT, our customers, users, employees, contractors, suppliers, service providers, the public or any third party, as required or permitted by law.
9 STORAGE AND CROSS BORDER TRANSFER OF PERSONAL INFORMATION
9.1 Your Service Data will be primarily stored and processed in the Republic of Botswana (“Botswana”) where OTT operates.
9.2 OTT will not transfer personal information about a Client to a third party who is in a foreign country unless the third party who is the recipient of the information is subject to a law, binding corporate rules or binding agreement which provides an adequate level of protection that is the same or substantially similar to the level of protection offered by the Data Protection Act, 2018 and Data Protection Act, 2024 (Act 18 of 2024).
9.3 If OTT is required to transfer Personal Data outside of Botswana to servers, service providers or third parties located in foreign territories, OTT undertakes to:
9.3.1 Ensure such territories will be governed by data protection laws which, in the sole opinion of OTT, adequately protect personal information; or
9.3.2 if the foreign territory has inadequate data protection laws, OTT will make reasonable efforts to enter binding agreements with the recipient to ensure adequate safeguarding measures are in place to protect the transferred personal information.
9.4 When transferring Personal Data outside of Botswana, we have implemented appropriate safeguards as required by the Data Protection Act, 2018 and Data Protection Act, 2024 (Act 18 of 2024) and other applicable data protection laws, including but not limited to:
9.4.1 Transfer Impact Assessments (“TIA”): We conduct TIAs before any cross-border data transfer takes place to a territory with inadequate data protection laws. TIAs help identify and mitigate potential risks associated with the transfer of Personal Data to non-Botswana countries, ensuring compliance.
9.4.2 Standard Contractual Clauses (“SCCs”): Ensure that we, as the Data Controller, have SCCs in place when transferring Personal Data to non-Botswana countries or to third-party Processors outside these territories. These clauses serve as legally binding agreements that guarantee the protection of Personal Data at the same level as within Botswana.
9.4.3 Encryption of data: Encrypting Personal Data before transfer helps to ensure that it cannot be accessed by unauthorised parties.
9.5 OTT may also transfer the personal information of a Client to a third party who is in a foreign country in the following circumstances where:
9.5.1 the Data Subject explicitly consents to the transfer; or
9.5.2 Where the transfer is necessary for the performance of a contract between the Client and OTT (This derogation can only be used if the data subject is a party to the contract);
9.5.3 Personal data may be transferred to a third country if the transfer is necessary for important reasons of public interest;
9.5.4 Personal data may be transferred to a third country if the transfer is necessary to protect the data subject’s vital interests;
9.6 For more information about the safeguards we implement to protect your Personal Data during international transfers, please contact our Information Officer.
10 SECURITY SAFEGUARDS
10.1 OTT has implemented appropriate security measures which are required in order to protect all Personal Data that it holds from and against loss, damage, unauthorised destruction, unlawful access and processing, such as:
10.1.1 Access control: Restricting access to your Service Data to OTT employees, contractors, and agents who need it to perform their duties for us. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations,
10.1.2 Secure Storage and Encryption: Ensuring Service Data is securely stored according to reasonable industry standards and Encrypting Service Data at rest and while in transit between our facilities,
10.1.3 Review: Regularly reviewing our processing practices and systems for vulnerabilities and implementing updates and patches to secure our infrastructure,
10.1.4 Incident management: Implementing a response plan to quickly address and mitigate any data breaches or security incidents.
10.2 While OTT takes all reasonable efforts to safeguard the personal information which it holds, it cannot be held responsible for any loss or unauthorised processing of personal information beyond OTT’s reasonable control.
10.3 If we become aware of a data breach that may compromise your Personal Data, we will notify you and the relevant regulatory authorities in accordance with applicable legal requirements.
10.4 OTT further undertakes to promptly take action, at its own reasonable expense, to investigate any such suspected breach and to identify, prevent, and mitigate the effects of any such breach.
11 LINKS TO THIRD PARTY SERVICES
OTT Services may contain links to third-party platforms or websites outside of OTT’s control. OTT is and is not responsible for the content, privacy or security of these other third-party controlled platforms. We encourage you to read the privacy policies of any third-party websites or platforms you interact with.
12 DATA RETENTION
12.1 OTT will only retain your Personal Data for as long as is necessary to achieving the purposes for which the information was collected, stored, transferred, used, processed or as required by law.
12.2 The retention period is determined by various factors, including:
12.2.1 The type of data and its sensitivity.
12.2.2 The purposes for which the data was collected and whether those purposes can still be achieved.
12.2.3 How you configure your settings.
12.2.4 Legal obligations that may require us to retain certain data for a specific period (e.g., tax laws, accounting regulations, or litigation holds).
12.3 Once we determine that your Personal Data is no longer necessary for the purpose it was collected and / or there are no other lawful grounds for us to continue processing it, we will securely delete, destroy, or anonymize it, ensuring that it is no longer identifiable.
13 DATA SUBJECT PARTICIPATION AND INFORMATION QUALITY
13.1 Where we act as a Data Controller, we are required to take all necessary steps to ensure that your Personal Data is accurate, complete, relevant not misleading, and up to date.
13.2 Any Data Subject whose Personal Data we maintain may request, in the prescribed manner:
13.2.1 To inspect and, if necessary, correct the Personal Data held by us. It is your responsibility to inform us should your Personal Data be incorrect, incomplete, irrelevant, misleading or out-of-date by contacting us.
13.2.2 The deletion or destruction of a record of Personal Data.
13.3 Such requests must be submitted using the prescribed form which is available in our Access to Information Manual. A copy of this Manual is available on our website.
13.4 We may require additional information from the requesting party to confirm the legitimate basis for the request and your identity and authority to do so. Upon receipt and verification of the corrected Personal Data, we will adjust or delete our information or records accordingly.
14 PROMOTIONAL CAMPAIGNS
14.1 In the event you enter any of OTT’s promotional competitions offered via its platform, OTT will collect and process your personal information for the purposes of the competition. This will include communication from OTT and OTT’s partners about the competition and other product offerings.
14.2 We refer you to the relevant competition rules, terms and conditions which will notify you of any further or additional processing of your personal information.
14.3 In the event of any marketing activity, such as publishing photographs of winners, OTT will obtain your consent.
14.4 You have a right to request that your personal information not be published on any of the social media platforms by sending an email to support@ott-mobile.com.
15 REVISION OF POLICY
OTT reserves the right to and may update or amend this Privacy Notice from time to time, and we will take reasonably practicable steps to inform you when changes are made. Without limiting the manner in which we may inform you, we may notify you by email, or by posting on our website and OTT. By continuing to use OTT or any of the other OTT services following any updates or amendments, you will be deemed to have consented to such changes.
16 DATA SUBJECT ACCESS RIGHTS
You have several rights in relation to the Personal Data that we hold about you, as provided for in the applicable data protection laws, you have the right to:
16.1 Request access to your personal information – You may ask us free of charge to confirm that we hold your personal information, or ask us to provide you with details, at a fee, how we process your personal information.
16.2 Request the correction of your personal information – to ensure any incomplete or inaccurate personal information is corrected.
16.3 Request erasure of your personal information – where there is no lawful basis for the retention or continued processing of your personal information.
16.4 Object to the processing of your personal information for a legitimate interest (or those of a third party) – reasonable grounds relating to your particular situation unless legislation provides for such processing.
16.5 Request restriction of processing of your personal information – to restrict or suspend the processing of your information to limited circumstances.
16.6 in some circumstances, the right to receive certain information you have provided to us in an electronic format and/or ask that we send it to a third party.
16.7 Lodge a complaint – to our Information Officer. If you believe our attempts to resolve the issue have been inadequate, alternatively, you can file a complaint with the Information Regulator. Complaint Forms and procedures are available on the Information Regulator’s website.
16.8 Institute civil legal proceedings – regarding the alleged interference with the protection of your personal information.
16.9 Withdraw consent given for the processing of your personal information at any time – where we rely on your consent to process certain personal information for a specific purpose, you can withdraw your consent at any time. This will not affect the continued processing of your personal information in instances where we have another legitimate reason for doing so.
16.9.1 To withdraw your consent – email our Information Officer. In the body of your email, please refer to the specific activity and type of personal information which you no longer consent to OTT collecting or using.
16.10 All requests and objections must be submitted to our Information Officer using the contact details listed under “Contact Us”.
16.11 On receipt of a request/objection, we will respond within 30 calendar days. If consent is withdrawn, we will acknowledge this action as soon as reasonably practicable.

Contact

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