Privacy Policy

Last updated: September 2026

1. Who we are

Carningham Insurance Brokers ("Carningham", "we", "us", "our") is a licensed, independent insurance broker based at Plot 1881 Lobengula Avenue, CBD, Francistown, Botswana, licensed by the Non-Bank Financial Institutions Regulatory Authority (NBFIRA) under registration number [NBFIRA REGISTRATION NUMBER]. This policy explains how we handle the personal information of our clients, prospective clients, and website visitors, in line with Botswana's Data Protection Act, 2024 (Act No. 18 of 2024).

2. What personal information we collect

Depending on how you interact with us, we may collect:

• Contact details: full name, phone number, email address, physical address.
• Identification details: Omang/passport number and date of birth, where required to arrange or administer a policy.
• Policy and claims information: policy numbers, cover selected, claim category, and a description of the incident you're claiming for.
• Financial information: premium payment details and, where relevant to a claim, supporting financial records.
• Sensitive information: for certain claims (for example, life, disability, or funeral cover), the incident description you provide may include health-related information. We treat this as sensitive personal information and handle it with additional care, as set out below.

3. How we collect it

We collect personal information directly from you, through the forms on this website (such as the claims form or a quote request), by phone, email, WhatsApp, or in person. Where relevant to managing your policy or claim, we may also receive information about you from the underwriter or insurer. The forms on this site are protected using Google reCAPTCHA to prevent spam and abuse; see Section 12 below for details.

4. Why we process your information

We use your personal information to:

• Provide quotes and arrange insurance cover on your behalf;
• Lodge, manage, and follow up your claims directly with the relevant underwriter;
• Communicate with you about your policies, claims, or enquiries;
• Meet our legal and regulatory obligations, including those owed to NBFIRA.

5. Our legal basis for processing

We process your personal information on the basis of your consent (for example, when you submit a form on this site), because it's necessary to perform our broking services for you, or because we're required to by law or by our regulator.

6. Who we share it with

As a broker, sharing certain information is essential to what we do for you. We may share your personal information with:

• The underwriter(s) or insurer(s) relevant to your policy or claim, so it can be assessed and settled;
• NBFIRA or other regulators, where required by law;
• Service providers who support our operations (for example, website hosting, email, and form-security providers), under confidentiality obligations.

7. International data transfers

Some of the service providers who support this website and our email operate servers outside Botswana, including in the United States and other jurisdictions. This means personal information submitted through this site (for example, via the quote or claims forms) may be processed or stored outside Botswana by those providers. Where this occurs, we only transfer personal information to a country recognised as providing an adequate level of data protection, or where appropriate safeguards are in place, such as contractual clauses binding the receiving provider to data protection standards equivalent to those required under Botswana's Data Protection Act, 2024. By submitting information through this website, you acknowledge that it may be transferred and processed outside Botswana on this basis.

8. Sensitive personal information

Where a claim requires you to share sensitive information (such as health details relevant to a life, disability, or funeral claim), we only use it for the purpose of lodging and managing that specific claim, and only with your consent given at the point of submission.

9. How long we keep it

We retain your personal information for as long as necessary to provide our services, manage your policy or claim, and meet our legal and regulatory record keeping obligations. After that, it's securely deleted or archived.

10. How we protect it

We take reasonable technical and organisational measures to protect your personal information against unauthorised access, loss, misuse, or disclosure. In the event of a personal data breach that is likely to affect you, we will notify the Information and Data Protection Commission within 72 hours of becoming aware of it, and will notify you directly without undue delay where the breach is likely to result in a high risk to your rights and freedoms, in line with Botswana's Data Protection Act, 2024.

11. Your rights

You have the right to:

• Ask us what personal information we hold about you, and request a copy;
• Ask us to correct information that's inaccurate or incomplete;
• Ask us to delete or restrict the use of your information, subject to our legal and regulatory obligations;
• Object to, or withdraw your consent for, certain processing;
• Lodge a complaint with Botswana's Information and Data Protection Commission if you believe your rights have been infringed.

To exercise any of these rights, contact us using the details below.

12. Website usage, cookies and reCAPTCHA

This website does not use tracking cookies for advertising purposes. If that changes in future, this policy will be updated to reflect it. The quote and claims forms on this site use Google reCAPTCHA to help prevent spam and automated abuse. reCAPTCHA may collect hardware and software information (such as device and application data) and send it to Google for analysis. Use of reCAPTCHA is subject to Google's Privacy Policy and Terms of Service.

13. Children's information

Our services are directed at adults. We do not knowingly collect personal information from anyone under 18 without the involvement of a parent or guardian.

14. Complaints about our service

This section covers complaints about our service generally, separate from the data protection rights in Section 11 above. If you're unhappy with the service you've received from us, please contact us first using the details below so we can try to resolve it directly. If we're unable to resolve your complaint to your satisfaction, you may refer it to NBFIRA as our regulator, using the contact details published on nbfira.org.bw.

15. Changes to this policy

We may update this policy from time to time. The "last updated" date at the top of this page reflects the most recent revision.

16. Contact us

For any questions about this policy, or to exercise your rights over your personal information, contact us at carningham@btcmail.co.bw or +267 71 609 426, or write to us at Plot 1881 Lobengula Avenue, CBD, Francistown, Botswana.