This Privacy Notice describes how Pachi Micro Solutions Proprietary Limited ("PMS", "we", "us") collects, uses, discloses, retains and protects your personal data in accordance with the Data Protection Act 18 of 2024 and all other applicable laws of Botswana.
It applies to all interactions with PMS — including our website, loan management system, mobile app, and WhatsApp communications. By applying for a loan or using our services, you confirm you have read and understood this Notice.
Who We Are
PMS is a micro-finance company licensed and regulated by the Non-Bank Financial Institutions Regulatory Authority (NBFIRA), licence number NBFIRA 8/3/378/LA, to operate a micro-lending business in Botswana.
PMS is the data controller in respect of personal data collected from you. Our registered address is Plot 1271, Travaglini House, Gaborone West Industrial, Gaborone, Botswana.
Where Your Data Is Stored
Your personal data — including certified copies of identity documents required under applicable lending regulations — is processed and stored on secure servers hosted in Germany (European Union). Germany operates under the EU General Data Protection Regulation (GDPR), one of the world's most rigorous data protection frameworks.
This cross-border transfer is permitted under the DPA because the EU maintains data protection standards equivalent to or exceeding those required by Botswana law.
What this means for you: Your data is protected by both Botswana's Data Protection Act 2024 and EU GDPR standards simultaneously — giving you a higher level of protection than most local providers.
What Information We Collect
Identity & Personal Information
- Full name, identity number, date of birth, gender, nationality, and occupation
- Certified copies of identity documents (e.g. Omang, passport)
- Physical address, postal address, email address, and phone number
Financial Information
- Income, employment details, bank account information, and payslips
- Existing credit obligations and financial commitments
- Credit bureau data obtained through authorised credit reference checks
Contractual Information
- Loan application details, repayment history, and all related correspondence
- Signed loan agreements and supporting documentation
Digital & Technical Information
- IP address, browser type, and website usage data
- WhatsApp and other digital communication records
- App usage data and device identifiers
Sensitive data: Where we collect sensitive personal data, we will always seek your explicit written consent and handle it with heightened care in accordance with Part VI of the DPA.
How We Collect Your Information
- Directly from you when you complete a loan application — in person, online, via our app, or via WhatsApp.
- From authorised third parties, including credit bureaus, NBFIRA, and fraud prevention databases.
- Automatically through our website and app via cookies and usage data.
- From partially completed applications — if you begin but do not finish an application, we may contact you to assist with completion.
Legal Basis for Processing
Under the DPA, we are required to have a lawful basis for processing your personal data. We rely on the following grounds:
- Performance of a contract — processing necessary to assess, approve, and administer your loan application and ongoing relationship with PMS.
- Legal obligation — processing required to comply with NBFIRA regulations, anti-money laundering laws, and other applicable legislation.
- Legitimate interests — processing for fraud detection, risk management, debt recovery, and security of our systems, where these interests are not overridden by your rights.
- Consent — where we rely on your consent (e.g. for marketing), we will ask for it explicitly. You may withdraw consent at any time without affecting earlier processing.
How We Use Your Information
- To assess, process, and administer your loan application and any subsequent requests.
- To verify your identity and conduct authorised credit reference checks.
- To execute transactions and manage your loan account.
- To communicate with you about your loan, account updates, and important notices.
- To comply with NBFIRA regulations, anti-money laundering requirements, and other legal obligations.
- To detect, investigate, and prevent fraud, money-laundering, and other unlawful activity.
- For debt recovery or tracing where necessary.
- To maintain the security and integrity of our digital systems and app.
- For audit, record-keeping, and legal proceedings.
- For risk analysis and statistical research (using anonymised or aggregated data where possible).
- Subject to your consent, to send you marketing communications about PMS products and services.
Automated decision-making: Our loan assessment process may involve automated credit scoring. You have the right to request human review of any automated decision that significantly affects you. Contact us to exercise this right.
Sharing Your Information
We will only share your personal data where there is a legitimate reason to do so. We may share your information with:
- NBFIRA and regulatory authorities — as required by law.
- Credit reference bureaus — for credit assessment and fraud prevention.
- Technology and service providers — including our loan management system, hosted in Germany (EU) and bound by data processing agreements providing equivalent protection.
- Financiers — who provide funding to PMS, solely for assessing PMS facility applications.
- Law enforcement and fraud prevention bodies — where legally required or permitted.
- Professional advisers — legal, financial, and audit professionals, subject to strict confidentiality obligations.
We will never sell, rent, or trade your personal data to any third party for commercial purposes.
How Long We Keep Your Information
We retain personal data only as long as necessary for the purposes for which it was collected, including legal and regulatory requirements.
| Data Category | Retention Period |
|---|---|
| Active loan account records | Duration of the loan relationship |
| Closed accounts & identity documents | Minimum 5 years after relationship ends (NBFIRA & AML requirements) |
| Unsuccessful loan applications | Up to 12 months from application date |
| Marketing preferences | Until consent is withdrawn or opt-out request received |
| Website & app technical data | Up to 12 months |
When data is no longer required, it is securely deleted or anonymised.
Your Rights
Under the Data Protection Act 2024, you have the following rights:
Request a copy of the personal data we hold about you.
Request correction of inaccurate or incomplete data.
Request deletion of your data in certain circumstances.
Request that we limit how we process your data.
Object to processing based on legitimate interests or for direct marketing.
Request your data in a structured, machine-readable format.
Withdraw consent at any time where processing is consent-based.
Request human review of any automated decision that significantly affects you.
To exercise any of these rights, contact us at support@pachi.co.bw or 72 136 941. We will respond within 30 days and may need to verify your identity before processing your request.
Data Security
PMS is committed to protecting your personal data. Our security measures include:
- Encryption of data at rest and in transit.
- Secure, access-controlled server infrastructure hosted in Germany (EU).
- Contractual data protection obligations placed on all third-party processors.
- Regular review and testing of our security practices.
Data breach notification: In the event of a breach that poses a risk to your rights and freedoms, we will notify the Information and Data Protection Commission within 72 hours of becoming aware of it, and will inform affected individuals without undue delay, as required by the DPA.
Cookies & Website Data
Our website uses cookies to improve your experience. Essential cookies are necessary for the site to function. Analytics cookies (including Google Analytics) help us understand how visitors use our site — these collect only anonymous, aggregated data that cannot identify you personally.
You may disable cookies in your browser settings. Disabling essential cookies may affect site functionality. Our website respects any "do not track" settings in your browser.
Eligibility & Minors
PMS lending services are available exclusively to individuals aged 21 years and older, in line with our NBFIRA licensing requirements. We do not accept applications from, or knowingly collect personal data from, persons under the age of 21. If we become aware that personal data has been submitted by someone under this age, we will delete it promptly.
Third-Party Platforms
PMS communicates with customers via third-party platforms including WhatsApp, Facebook, and Instagram. When you interact with us on these platforms, those services may collect your data under their own privacy policies, which are independent of this Notice. We encourage you to review the privacy terms of any third-party platform you use to interact with us.
Marketing
Where you have provided consent, we may send you information about PMS products, services, and promotions. You may opt out of marketing communications at any time by contacting us at support@pachi.co.bw or 72 136 941. Please allow up to 30 days for us to action your request.
Changes to This Notice
We may update this Privacy Notice from time to time to reflect changes in the law, our services, or how we process data. Material changes will be communicated via our website and, where appropriate, directly to affected customers. The current version is always available at pachi.co.bw/privacy-policy. This version supersedes all previous versions.
How to Complain
If you have concerns about how we handle your personal data, please contact us first:
If you are not satisfied with our response, you have the right to lodge a complaint with:
Information and Data Protection Commission
Gaborone, Botswana
We would always appreciate the opportunity to address your concerns directly before escalation to the Commission.