headoffice@cash.co.bw +267 311 0824
Responsible Lending Group

Privacy Policy

Last updated: 11 September 2026

About this document. This Privacy Policy is a template prepared for Responsible Lending Group (Pty) Ltd and its operating companies, drafted with reference to Botswana's Data Protection Act, 2018 and related legislation. It is provided as a starting point for your website and should be reviewed and approved by qualified Botswana legal counsel before publication, and updated to reflect your actual data practices.

Contents

  1. Introduction
  2. Definitions
  3. Information We Collect
  4. How We Use Your Information
  5. Legal Basis for Processing
  6. Sharing and Disclosure of Information
  7. Cross-Border Transfers
  8. Data Security
  9. Data Retention
  10. Your Rights
  11. Cookies and Similar Technologies
  12. Marketing Communications
  13. Children's Privacy
  14. Changes to this Policy
  15. Contact Us and Complaints

1. Introduction

Responsible Lending Group (Pty) Ltd ("RLG", "the Group", "we", "us" or "our") respects your privacy and is committed to protecting the personal information of our customers, website visitors, and other individuals we deal with. This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and what rights you have in relation to it.

This Policy is drafted with reference to the Botswana Data Protection Act, 2018 (Act No. 32 of 2018), the Non-Bank Financial Institutions Regulatory Authority Act, 2016, and other applicable Botswana law. By using our websites or engaging any of our Companies for products or services, you acknowledge that you have read and understood this Policy.

2. Definitions

In this Policy, unless the context requires otherwise:

  • "our Companies" or "the Companies" means, collectively, the operating companies of Responsible Lending Group, namely Pawn Express (Pty) Ltd, Mortgage Express (Pty) Ltd, Capital Express (Pty) Ltd, and Lanny Holding (Pty) Ltd, together with Responsible Lending Group (Pty) Ltd itself. Wherever this Policy refers to "our Companies", it means any or all of these entities, as the context requires.
  • "personal information" means information about an identifiable individual, including but not limited to a name, identity or passport number, contact details, financial information, employment information, and any other information that relates to you.
  • "processing" means any operation performed on personal information, including collection, storage, use, disclosure, or deletion.
  • "data subject" means the individual to whom personal information relates, including our customers, guarantors, next-of-kin, and website users.
  • "IDPC" means the Information and Data Protection Commission of Botswana, the regulatory authority responsible for administering the Data Protection Act, 2018.
  • "NBFIRA" means the Non-Bank Financial Institutions Regulatory Authority of Botswana, which regulates the lending activities of our Companies.

3. Information We Collect

Depending on your relationship with our Companies, we may collect the following categories of personal information:

  • Identification information — full name, date of birth, national identity (Omang) or passport number, and photograph.
  • Contact information — physical and postal address, telephone number, and email address.
  • Financial information — income, employment details, bank account details, credit history, collateral or security details (including title deeds and vehicle registration where relevant), and repayment history.
  • Application and account information — details you provide in loan or finance applications, including next-of-kin and guarantor details.
  • Technical information — IP address, browser type, device information, and website usage data collected through cookies and similar technologies (see Section 11).
  • Communications — records of calls, emails, and messages between you and our Companies, including for training and quality purposes.

4. How We Use Your Information

We use personal information for purposes that include:

  • Assessing and processing applications for loans, pawn, mortgage, or other finance products;
  • Verifying your identity and conducting affordability and credit assessments, including responsible lending checks as required by applicable law;
  • Administering and servicing your account, including collecting repayments and managing security or collateral;
  • Complying with our legal and regulatory obligations, including those owed to NBFIRA and other authorities;
  • Communicating with you about your application, account, or our products and services;
  • Improving our products, services, and websites, including through analytics;
  • Preventing fraud, money laundering, and other unlawful activity; and
  • Any other purpose to which you have consented.

6. Sharing and Disclosure of Information

We may share your personal information with:

  • Our Companies — for group administration, risk management, and where you have applied for or hold products with more than one of our Companies;
  • Credit bureaus and reference agencies — to conduct credit checks and report on your repayment history, as permitted by law;
  • Regulators and authorities — including NBFIRA, the IDPC, the Botswana Unified Revenue Service, and law enforcement agencies, where required by law or a valid legal process;
  • Service providers — such as IT, hosting, debt collection, valuation, and professional advisory service providers who process information on our behalf, under confidentiality obligations;
  • Guarantors and next-of-kin — to the extent necessary to administer your application or agreement; and
  • Any other third party — with your consent, or as otherwise permitted or required by law.

We do not sell your personal information to third parties.

7. Cross-Border Transfers

Where any of our service providers or systems are located outside Botswana, your personal information may be transferred to and processed in another country. Where this occurs, we take reasonable steps to ensure that the receiving party provides an adequate level of protection for your personal information, consistent with the requirements of the Data Protection Act, 2018.

8. Data Security

We implement reasonable technical and organisational measures designed to protect personal information against loss, misuse, unauthorised access, and disclosure, including restricted access controls, secure storage, and staff confidentiality obligations. While we take reasonable steps to protect your information, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Data Retention

We retain personal information for as long as necessary to fulfil the purposes described in this Policy, including to satisfy any legal, regulatory, accounting, or reporting requirements applicable to our Companies. Where information is no longer required, we take reasonable steps to securely delete or anonymise it.

10. Your Rights

Subject to the Data Protection Act, 2018, you have the right to:

  • Request access to the personal information we hold about you;
  • Request correction of inaccurate or incomplete personal information;
  • Request deletion of personal information, where applicable law permits;
  • Object to, or request that we restrict, certain processing of your personal information; and
  • Lodge a complaint with the IDPC if you believe your personal information has been processed unlawfully.

To exercise any of these rights, please contact us using the details in Section 15. We may need to verify your identity before responding to your request, and may take reasonable time to respond as permitted by law.

11. Cookies and Similar Technologies

Our websites may use cookies and similar technologies to remember your preferences, understand how our websites are used, and improve your browsing experience. You can control or disable cookies through your browser settings; however, some parts of our websites may not function properly if you do so.

12. Marketing Communications

We may use your contact information to send you information about products and services offered by our Companies that may be of interest to you, where you have consented to receive such communications or as otherwise permitted by law. You may opt out of marketing communications at any time by contacting us or using the unsubscribe option provided in the communication.

13. Children's Privacy

Our products and services are intended for individuals who are at least 18 years old. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child, we will take reasonable steps to delete it.

14. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this Policy periodically.

15. Contact Us and Complaints

If you have any questions about this Privacy Policy, or wish to exercise any of your rights, please contact us at:

Responsible Lending Group (Pty) Ltd
Email: headoffice@cash.co.bw
Telephone: +267 311 0824

If you are not satisfied with our response, you have the right to lodge a complaint with the Information and Data Protection Commission (IDPC) of Botswana.