Privacy Policy

1. Introduction

DULA is a mobile-first property marketplace "Rooms. Rentals. Roommates." connecting Property Owners, Estate Agents, and Seekers across Botswana, accessible at dulabw.com and through the DULA mobile application. DULA is a product of Bele Technologies (Pty) Ltd, registration number BW00006518156, a Botswana-registered technology company.

This Privacy Policy explains how we collect, use, disclose, and protect personal data when you create a DULA account, list a property, search for accommodation, communicate with another user, or make or receive a payment through the Platform. It is issued in accordance with Botswana's Data Protection Act, 2024 (Act No. 18 of 2024), which came into force on 14 January 2025, and is supervised by the Information and Data Protection Commission (the "Commission").

This Policy should be read together with the DULA Terms of Service and the DULA Cookie Policy, each available at dulabw.com.

2. Who This Policy Applies To

• Seekers browsing or searching dulabw.com or the DULA app for rooms, rentals, or roommates
• Property Owners listing a property for rent or sale
• Estate Agents managing listings on behalf of owners or clients
• Visitors browsing the Platform before registering an account
• Users making or receiving a payment through DULA's mobile money integrations

3. Information We Collect

3.1 Account and profile information

• Full name, email address, phone number, and password (or mobile/social sign-in credentials) provided on registration
• Role selection — Seeker, Property Owner, or Agent — and, for Agents, agency name and licensing details where provided
• Profile photo and any biographical details you choose to add
• Your DULA Digital Address, generated or linked to your account (format DULA-BW-[CountryCode]-[CityCode]-[UniqueHash])

3.2 Listing information

• Property address, description, photographs, rent or price, availability, and amenities
• Ownership or authority-to-list representations made by the Owner or Agent
• Viewing, save, and enquiry activity connected to a listing

3.3 Communications and contact-unlock data

• Messages exchanged between Seekers, Owners, and Agents through the Platform's messaging feature
• Records of when a Seeker unlocks a listing's contact details, including the date, time, and which contact details were revealed

3.4 Payment and subscription information

• Subscription tier selected (daily, weekly, monthly, or annual), billing history, and one-time listing fee records
• Mobile money transaction references processed via Orange Money, Mascom MyZaka, or BTC Smega. DULA does not collect or store your mobile money PIN or full mobile money account credentials — these are entered and held directly with the relevant mobile money provider

3.5 Device and usage data

• IP address, device identifiers, operating system and app version, screens or pages visited, and time spent on the Platform, collected via server logs and analytics tools

3.6 Cookies and similar technologies

See the DULA Cookie Policy for full details of the cookies, SDKs, and analytics tools used on dulabw.com and in the DULA app.

3.7 Information from other sources

• Publicly available property or business information used to verify a listing
• Information passed to us by a mobile money or payment partner in connection with a transaction you have authorised

3.8 Identity verification (KYC) information

Certain DULA features may require identity information and supporting documentation for verification, fraud prevention, trust and safety, service delivery or compliance purposes. We process such information only for identified purposes and on a lawful basis under the Act.

• Identity documents and supporting information provided by Property Owners and Estate Agents to verify their identity, ownership of or authority to list a property, and, for Agents, licensing status
• The outcome and date of a verification check. Identity documents are held separately from your public listing or profile information and are not displayed publicly

4. How We Use Your Information

• To create and administer your DULA account and Digital Address
• To publish, display, and match property listings to Seekers
• To process subscriptions, listing fees, and contact-unlock payments via our mobile money partners
• To facilitate communication between Seekers, Owners, and Agents
• To verify the identity of Property Owners and Estate Agents, and their authority to list a property (KYC), for trust and safety, fraud prevention and compliance purposes
• To verify listings and detect fraudulent, duplicate, or misleading listings
• To provide customer support
• To send transactional notifications (for example, listing expiry, payment confirmation, or unlock confirmation) and, where you have opted in, marketing communications
• To maintain, secure, and improve the Platform
• To detect, investigate, and prevent fraud, abuse, or security incidents
• To comply with our legal obligations, including under the Act and Botswana's tax and consumer protection legislation

5. Legal Basis for Processing

Under the Act, we rely on one or more of the following legal bases, depending on the activity:

• Contractual necessity to create your account, publish or display a listing, and process a subscription, listing fee, or contact-unlock payment
• Consent for marketing communications and for non-essential cookies
• Legitimate interest to secure the Platform, prevent fraud and duplicate or fraudulent listings, and improve our services, balanced against your rights
• Legal obligation where processing is required by Botswana law, including tax, anti-money-laundering, and consumer protection requirements
• Legitimate interest and, where applicable, legal obligation to verify the identity of Property Owners and Estate Agents (KYC), balanced against your rights and interests

6. Cookies and Tracking Technologies

DULA uses cookies, mobile SDKs, and similar technologies on dulabw.com and in the DULA app for essential platform functionality, analytics, and where you consent, personalisation. Where required by the Act, we request your consent before setting non-essential cookies via a consent banner, and you may withdraw that consent at any time through your browser or in-app settings. Full details are set out in the DULA Cookie Policy.

7. How We Share Your Information

We do not sell personal data. We share it only as follows:

• With other DULA users, as core to the Platform's function — for example, when a Seeker unlocks a listing's contact details
• Open Hive (Pty) Ltd, our technical development and delivery partner, which processes data on our behalf to build, host, and maintain the Platform
• Mobile money and payment service providers — Orange Money, Mascom MyZaka, and BTC Smega — to process subscription, listing fee, and contact-unlock payments
• Hosting, cloud infrastructure, and analytics providers who process data on our behalf under appropriate data processing agreements
• Professional advisers (legal, audit, compliance) where necessary
• Government or regulatory bodies, including the Commission, the Botswana Unified Revenue Service, and law enforcement, where required by law
• A successor entity in connection with a merger, acquisition, or restructuring of Bele Technologies or the DULA business

8. Cross-Border Data Transfers

Some of our service providers may process data outside Botswana. Where this occurs, we take the steps required by Part XIV of the Act. In accordance with Section 76, where the Commission has not recognised the destination country as providing adequate protection, we transfer data only where appropriate safeguards (such as standard contractual clauses or binding corporate rules) are in place with the receiving party and enforceable data-subject rights and legal remedies remain available to you.

9. Data Retention

We retain personal data only for as long as necessary for the purpose it was collected, or to comply with legal, accounting, tax, or reporting obligations. Working retention schedule:

• Active account and profile data: for as long as your account remains active, and for 24 months after account deletion or closure
• Property listings: for as long as the listing is live, and for 12 months after removal or expiry
• Transaction, subscription, and payment records: 5 years from the date of the transaction, in line with Botswana tax record-keeping requirements
• Support enquiries and complaints: 24 months from resolution
• Identity verification (KYC) documents and records: retained only for the minimum period necessary for verification, fraud prevention, dispute resolution and audit purposes, then securely deleted or anonymised
• Marketing and newsletter opt-ins: until you unsubscribe or withdraw consent

10. Data Security

We implement appropriate technical and organisational measures consistent with Bele Technologies' Cybersecurity division standards to protect personal data against unauthorised access, loss, misuse, or alteration, including access controls, encryption in transit, and restricted internal access. Payment card and mobile money credentials are processed directly by our licensed mobile money and payment partners and are never stored on DULA's systems.

In the event of a personal data breach affecting your personal data, we will notify the Commission without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach, in accordance with Section 63 of the Act.

11. Your Rights

Under the Act, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request deletion of your data, subject to legal exceptions
• Restrict or object to certain processing
• Request a portable copy of the data you provided to us, in a structured, machine-readable format
• Withdraw consent at any time, without affecting processing carried out before withdrawal
• Object to decisions based solely on automated processing
• Lodge a complaint with the Information and Data Protection Commission

To exercise any of these rights, contact us using the details in Section 16. We will respond within the timeframe required by the Act.

12. Children's Privacy

DULA is not directed at, and may not be used by, children under 18 years of age. If we become aware that we have collected personal data from a child without appropriate parental or guardian consent, we will take steps to delete that data.

13. Relationship to Bele Technologies' Other Products

DULA is a product of Bele Technologies (Pty) Ltd. Personal data collected through DULA is not combined with data collected through Bele Technologies' Autonomous Security as a Service (ASaaS), drone, or CCTV operations, which are governed by separate, site-specific surveillance and privacy notices agreed with each client.

14. Third-Party Links

The Platform may link to third-party sites, including mobile money provider apps and social media platforms. We are not responsible for the privacy practices of those sites, and we encourage you to review their policies separately.

15. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Reviewed" date at the top of this document indicates when it was last updated. Material changes will be highlighted on the Platform and, where appropriate, notified to you directly.

16. Contact Us

• Bele Technologies (Pty) Ltd
• Email: info@beletechno.co.bw
• Website: dulabw.com | beletechno.com
• Registration No.: BW00006518156
• Registered address: P.O. Box 71AAD, Poso House, Gaborone, Botswana
• Data Protection Officer: Utlwang Theophilus Elliot, Founder & Managing Partner, Bele Technologies

17. Complaints to the Regulator

If you believe we have not handled your personal data in accordance with the Act, you have the right to lodge a complaint with the Information and Data Protection Commission, Botswana's national supervisory authority for data protection, at www.idpc.org.bw.