Performance Strategies Enterprises (Pty) Ltd
Website: www.performancestrategies.co
Effective Date: 22 October 2026
Country of Operation: Republic of Botswana
1. Introduction
Performance Strategies Enterprises (Pty) Ltd (“Performance Strategies”, “PSE”, “we”, “us” or “our”) is committed to respecting and protecting the privacy, confidentiality and personal information of individuals who interact with our organisation.
We recognise that protecting personal information is essential to maintaining the confidence of our learners, corporate clients, employees, facilitators, suppliers and other stakeholders.
This Privacy Policy explains how we collect, use, store, disclose, retain and protect personal information when individuals:
- Visit our website, www.performancestrategies.co
- Enquire about or register for our training programmes.
- Purchase and participate in online courses.
- Attend face-to-face workshops or live virtual training.
- Participate in customised corporate training programmes.
- Communicate with us through email, telephone, WhatsApp or website contact forms.
- Engage with our services in any other professional or commercial capacity.
This Privacy Policy is guided by Botswana’s Data Protection Act, 2024 (Act No. 18 of 2024), and other applicable laws. Where international privacy legislation applies to particular processing activities, we will take account of those additional obligations.
2. Identity of the Data Controller
Performance Strategies Enterprises (Pty) Ltd is generally the data controller responsible for determining the purposes and means of processing personal information collected through its website and training operations.
Data Controller:
Performance Strategies Enterprises (Pty) Ltd
P.O. Box AE763, AEH
Molapo Crossing
Gaborone, Botswana
Email: admin@performancestrategies.co
Website: www.performancestrategies.co
All enquiries regarding personal information, privacy rights or the handling of personal data may be directed to the email address above.
Where Performance Strategies processes personal information strictly on the documented instructions of a corporate client, the client may act as the data controller and Performance Strategies as a data processor for those specific activities. The applicable responsibilities will be determined by the actual processing arrangements and any relevant agreement.
3. Personal Information We Collect
We collect only personal information that is reasonably necessary for specified, legitimate purposes associated with our services.
Depending on how you interact with us, the information collected may include the following categories.
3.1 Personal Identification Information
- Full name.
- Email address.
- Telephone number.
- Country of residence.
- Job title or professional designation.
- Employer or organisation name.
- Other identification details reasonably necessary for enrolment, attendance verification or certification.
3.2 Learner Registration and Account Information
Individuals enrolling in our online courses may be required to create a learner account through our learning management platform.
We may collect and maintain:
- Learner name and registered email address.
- Username and account identification details.
- Securely stored authentication information.
- Courses purchased or enrolled in.
- Enrolment dates and course access records.
- Learning progress and completion status.
- Quiz results and assessment outcomes.
- Certificate eligibility and issuance records.
- Learner support requests and related communications.
Passwords are managed through the authentication systems used by our website. Learners should never disclose their passwords to Performance Strategies staff or other individuals.
3.3 Corporate Training Information
Where training is arranged by an employer or organisation, we may receive information from an authorised corporate representative, including:
- Names of nominated participants.
- Work email addresses and contact details.
- Job titles and departments.
- Training requirements and professional development needs.
- Attendance records.
- Assessment results and completion information, where relevant and lawfully reportable.
Corporate clients are responsible for ensuring that information supplied to Performance Strategies has been collected and disclosed on an appropriate lawful basis.
3.4 Payment and Transaction Information
When purchasing online courses or paying for other training services, we may process:
- Customer name and billing information.
- Course or service purchased.
- Transaction reference number.
- Payment amount, date, currency and status.
- Information necessary for invoicing, accounting, refunds or payment reconciliation.
Online payments may be facilitated through PayPal or another authorised payment provider.
Sensitive payment credentials, such as complete card numbers and card security codes, are handled by the relevant payment provider rather than being requested directly by Performance Strategies.
Payment providers may collect and process additional information under their own privacy policies.
3.5 Website and Technical Information
When you access our website, certain technical information may be collected automatically by our website, hosting provider or authorised technology services.
Such information may include:
- Internet Protocol (IP) address.
- Browser type and version.
- Device type and operating system.
- Website pages visited.
- Date and time of access.
- Login and security events.
- Cookie identifiers and similar technical information.
This information may be used to operate, secure, troubleshoot and improve our website and learning services.
3.6 Communications and Enquiries
Where you contact Performance Strategies through our website, email, telephone, WhatsApp or other communication channels, we may retain your contact details, the content of your enquiry and relevant correspondence.
These records assist us in responding to requests, providing learner support and maintaining appropriate business records.
4. How We Collect Personal Information
We may obtain personal information:
- Directly from individuals through registration forms, course enrolment, checkout pages and enquiries.
- Through learner accounts and participation in online training activities.
- From corporate clients who nominate employees or representatives for training.
- Through attendance registers, assessments and workshop administration.
- Through correspondence and communications with individuals.
- Automatically through website systems, cookies and essential technical processes.
- From authorised service providers, such as payment processors, where necessary to confirm transactions or deliver services.
Where information is obtained from another source, we will comply with applicable requirements concerning notification, transparency and lawful processing.
5. Purposes for Processing Personal Information
Performance Strategies processes personal information for the following purposes:
5.1 Course Registration and Enrolment
To register learners, create learner accounts, confirm bookings and provide access to purchased training programmes.
5.2 Training Delivery and Administration
To organise workshops, communicate training arrangements, manage attendance and facilitate participation in online or face-to-face learning.
5.3 Learning Progress and Assessments
To record participation, track course completion, administer assessments and establish whether learners have satisfied programme requirements.
5.4 Certification
To prepare, issue and email certificates of attendance or completion to eligible learners and maintain records necessary for certificate verification.
5.5 Payments and Financial Administration
To process transactions, issue invoices and receipts, confirm payments, administer refunds and maintain financial records.
5.6 Customer Service and Learner Support
To answer questions, resolve technical problems, respond to complaints and provide information necessary for the effective use of our services.
5.7 Corporate Training Administration
To coordinate training with client organisations, prepare agreed reports and fulfil contractual training obligations.
5.8 Service Improvement
To evaluate training effectiveness, analyse learner feedback and improve our educational materials, delivery methods and customer experience.
5.9 Marketing and Business Communications
To provide promotional information about courses, workshops and related services where permitted by applicable law.
Where consent is required, promotional messages will be sent only after appropriate consent has been obtained.
Individuals may withdraw marketing consent or opt out of promotional communications at any time.
5.10 Legal and Regulatory Compliance
To comply with applicable legislation, maintain required records, respond to lawful requests and establish, exercise or defend legal claims.
6. Lawful Basis for Processing Personal Information
We process personal information only where an appropriate lawful basis exists under applicable data protection legislation.
Depending on the activity, this may include:
Consent: Where an individual has freely provided valid consent for a specific processing activity, such as optional marketing communications.
Contractual necessity: Where processing is necessary to register learners, provide purchased courses, administer payments or fulfil training agreements.
Legal obligations: Where processing is required to comply with accounting, taxation, regulatory or other legal requirements.
Legitimate interests: Where processing is necessary for a legitimate business interest, such as protecting website security, preventing fraud, providing appropriate customer service or improving operations, provided that the legal requirements for relying on this basis are satisfied.
Other lawful grounds: Where another basis is expressly permitted under applicable legislation.
We do not treat general website use as blanket consent to every form of personal data processing.
Where consent is the legal basis, it may be withdrawn in accordance with applicable law.
7. Online Learning Platform and Learner Profiles
Our website uses a WordPress-based learning environment incorporating LearnPress to facilitate online education.
When a learner creates an account or enrols in a course, relevant personal information may be recorded in the website’s user management and learning systems.
This information may be used to:
- Authenticate the learner.
- Manage course access and enrolment.
- Display purchased and enrolled courses.
- Track learning progress.
- Record assessments and completion status.
- Support learners experiencing technical difficulties.
- Facilitate the issuance of certificates.
Access to learner information is restricted according to appropriate administrative permissions and operational requirements.
We do not intentionally make individual assessment results or private learner account information publicly available.
Learners are responsible for maintaining the confidentiality of their login credentials and notifying us promptly if they suspect unauthorised account access.
8. Certificates and Training Records
Performance Strategies may maintain records of course participation, assessment outcomes and certificates issued.
These records may be used for verification, learner support, quality assurance and compliance with applicable training or regulatory requirements.
Certificates may contain the learner’s name, course title, completion date and other appropriate programme information.
Certificates issued electronically will normally be sent to the learner’s registered email address or another verified address.
Where a corporate client sponsors training, relevant attendance and completion information may be shared with the authorised client representative where there is a lawful basis for doing so.
Detailed assessment outcomes and other personal information will not automatically be disclosed to an employer merely because the employer paid for the training.
9. Corporate Training and Employee Information
For in-house corporate training, Performance Strategies may receive personal information from participating organisations for the purpose of administering agreed training services.
We will use such information only for appropriate purposes associated with the training arrangement or another lawful purpose.
Where applicable, data protection responsibilities between Performance Strategies and the client organisation will be addressed in the relevant service agreement or data processing agreement.
We will take reasonable steps to ensure that personal information provided by corporate clients is accessed only by personnel who require it for authorised purposes.
Reports supplied to corporate clients will be limited to information that is necessary, proportionate and permitted by applicable law.
10. Confidentiality of Practical Exercises and Training Activities
Our training programmes may include case studies, practical exercises, workplace assignments and action plans.
Participants are encouraged to use fictional, anonymised or appropriately authorised information when completing training activities.
Unless specifically authorised through an appropriate arrangement, learners should not upload or submit:
- Confidential employer information.
- Customer or employee personal records.
- Personal identification numbers.
- Sensitive financial information.
- Medical or health records.
- Passwords or confidential access credentials.
- Other sensitive or restricted business information.
Where an activity is intended for personal workplace application rather than formal submission, learners should retain the completed document securely for their own use.
Performance Strategies will not require learners to submit confidential workplace information unless a specific, lawful and appropriately protected arrangement has been established.
11. Sharing and Disclosure of Personal Information
Performance Strategies does not sell personal information.
We may share limited personal information with authorised third parties where necessary for lawful business purposes.
Recipients may include:
11.1 Payment Service Providers
Payment providers, including PayPal where used, may process payment and transaction information in accordance with their own privacy policies.
11.2 Website Hosting and Technical Providers
Authorised hosting, website maintenance, security and technical service providers may process information necessary for the operation and protection of our website and learning platform.
11.3 Learning and Video Delivery Providers
Technology providers supporting our online learning services, including Bunny.net where used, may process technical information required to deliver learning content securely.
11.4 Email and Communication Providers
Authorised email and communication providers may process contact information and message content necessary to deliver enrolment confirmations, learner support communications and certificates.
11.5 Corporate Clients
Where appropriate and legally permitted, we may share relevant attendance, participation and completion information with organisations that have arranged or sponsored training.
11.6 Professional Advisers and Regulators
Personal information may be disclosed to professional advisers, regulators, public authorities or law enforcement agencies where disclosure is lawfully required or otherwise justified.
We seek to limit disclosures to information reasonably necessary for the relevant purpose and apply appropriate safeguards where required.
12. International Transfers of Personal Information
Some technology providers supporting our website, online courses, video delivery, payment processing and communications may operate servers or processing facilities outside Botswana.
Consequently, personal information may be transferred to, accessed from or processed in another country.
Where international transfers occur, Performance Strategies will comply with applicable requirements of Botswana’s Data Protection Act, 2024.
Such requirements may include assessing the destination country’s level of protection, implementing appropriate safeguards, entering into suitable contractual arrangements or relying on another lawful transfer mechanism.
Where applicable, we will also comply with legal requirements concerning the retention of copies of internationally transferred personal information within Botswana.
Individuals may contact us for further information about relevant international transfers and the safeguards applicable to their information.
13. Data Security
Performance Strategies recognises its responsibility to protect personal information against unauthorised access, accidental loss, alteration, misuse or unlawful disclosure.
We maintain, and seek to improve, security measures appropriate to the nature, sensitivity and risks of the information being processed.
These measures may include:
- Restricted access to administrative and learner records.
- Appropriate authentication and password protection.
- Secure website connections.
- Software and plugin security updates.
- Appropriate backup and recovery procedures.
- Protection against unauthorised system access.
- Confidential handling of learner and corporate client records.
- Security measures and contractual obligations for relevant service providers.
- Procedures for responding to suspected personal data breaches.
No internet-based platform can guarantee absolute security. However, we are committed to applying reasonable and legally required safeguards.
14. Personal Data Breaches
A personal data breach may involve the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal information.
Where Performance Strategies becomes aware of a suspected personal data breach, we will investigate the incident, assess the potential risks and take appropriate corrective measures.
Where notification thresholds are met, we will notify the Information and Data Protection Commission and affected individuals within the timeframes required by applicable legislation.
We will also take reasonable steps to minimise possible harm and prevent recurrence.
15. Data Retention and Deletion
Performance Strategies retains personal information only for as long as necessary to achieve the purpose for which it was collected or to comply with applicable legal, contractual, accounting or regulatory obligations.
Retention periods are determined by the nature of the information and the reason for processing.
For example:
Learner accounts: Retained while needed to provide course access and related services, followed by deletion or anonymisation when no longer required, subject to lawful retention obligations.
Training and certification records: Retained for the period necessary to verify participation, demonstrate completion and meet applicable quality assurance or regulatory requirements.
Payment and accounting records: Retained for periods required by applicable financial, tax or business recordkeeping legislation.
Enquiries and support correspondence: Retained for as long as reasonably necessary to resolve the enquiry, maintain appropriate business records or address potential disputes.
Marketing information: Retained until the individual withdraws consent, opts out or the information is no longer required for the relevant lawful purpose.
Where deletion is required or appropriate, information will be securely deleted, anonymised or otherwise handled according to applicable legal obligations.
An individual may request deletion of personal information, subject to any lawful grounds requiring its continued retention.
16. Cookies and Similar Technologies
Our website may use cookies and similar technologies to support functionality, improve security and enhance the user experience.
Cookies are small files stored on a user’s device when visiting certain websites.
Depending on the technologies enabled, cookies may be used for:
Essential website functions: Supporting core website functionality and secure access.
Learner authentication: Maintaining login sessions and supporting user account functions.
Course functionality: Assisting with learning platform operation and continuity of user sessions.
Security: Helping identify suspicious or unauthorised activity.
Analytics: Understanding website usage and performance where relevant analytics tools have been enabled.
Third-party services: Supporting embedded content or services that may set their own cookies.
Where required by applicable law, we will obtain consent before activating non-essential cookies or tracking technologies.
Users may also manage or restrict cookies through their browser settings, although disabling certain cookies may affect website or learning platform functionality.
Additional information may be provided through a cookie notice or preference management facility on our website.
17. Email, WhatsApp and Other Communications
Performance Strategies may communicate with learners and clients through email, telephone, WhatsApp or other appropriate channels.
These communications may relate to:
- Course enrolment and payment confirmation.
- Training dates, venues and programme arrangements.
- Learner support and technical assistance.
- Course completion and certification.
- Responses to enquiries.
- Relevant promotional information, where permitted.
Communications through third-party platforms may be subject to the privacy practices of those providers.
Where learners contact us through WhatsApp, we may process their telephone numbers and message content for the purpose of addressing their enquiries.
We will seek to avoid requesting unnecessary sensitive personal information through informal communication channels.
Individuals may request that non-essential communications be stopped or redirected to another available channel.
18. Marketing Communications
Performance Strategies may promote its training programmes, workshops and professional development services through email, social media, WhatsApp or other suitable channels.
Where consent is required for direct marketing, individuals will be provided with an appropriate opportunity to consent.
Marketing consent will be separate from acceptance of essential course enrolment or payment conditions.
Individuals may withdraw consent or opt out of marketing communications at any time by following the relevant unsubscribe instructions or contacting admin@performancestrategies.co.
Withdrawal from marketing communications will not prevent us from sending essential service-related information relating to an existing enrolment, payment or contractual arrangement.
19. Rights of Individuals
Subject to the conditions and limitations established by applicable law, individuals whose personal information is processed by Performance Strategies may have the following rights:
19.1 Right to Information
To receive clear information about the collection and processing of their personal data.
19.2 Right of Access
To request confirmation of whether personal information concerning them is being processed and obtain access to that information.
19.3 Right to Rectification
To request correction of inaccurate personal information or completion of incomplete information.
19.4 Right to Erasure
To request deletion of personal information where the legal requirements for erasure are satisfied.
19.5 Right to Restrict Processing
To request that certain processing activities be restricted in circumstances recognised by law.
19.6 Right to Object
To object to certain processing activities, including direct marketing and other processing where the applicable legal conditions are met.
19.7 Right to Data Portability
Where the applicable conditions are satisfied, to receive relevant personal information in a structured, commonly used and machine-readable format and request its transfer to another controller.
19.8 Right to Withdraw Consent
To withdraw consent where processing relies on that consent, without affecting the lawfulness of processing undertaken before withdrawal.
19.9 Rights Relating to Automated Decision-Making
To exercise applicable rights concerning decisions based solely on automated processing that produce legal or similarly significant effects.
19.10 Right to Lodge a Complaint
To submit a complaint to the appropriate data protection authority if an individual believes their personal information has been processed unlawfully.
Requests to exercise privacy rights may be submitted to:
admin@performancestrategies.co
We may request reasonable information to verify the identity or authority of a person submitting a request.
Requests will be handled within the periods prescribed by applicable law.
20. Children’s Personal Information
Our corporate training and professional development services are primarily intended for adults and individuals participating in employment-related or professional learning.
We do not knowingly seek to collect children’s personal information without an appropriate legal basis and any required parental or guardian authorisation.
Where a programme includes participants below the age of 18, Performance Strategies will apply the relevant legal safeguards and consent requirements.
If personal information relating to a child has been collected without an appropriate legal basis, we will take reasonable steps to address the matter in accordance with applicable law.
21. Third-Party Websites and External Links
Our website may contain links to third-party websites, payment portals, communication platforms or other online services.
These services may operate under privacy notices and terms separate from those of Performance Strategies.
We encourage users to review the privacy policies of third-party providers before submitting personal information.
Where such providers process information on our behalf, we remain responsible for meeting applicable obligations concerning our selection, instructions and oversight of those providers.
22. Automated Processing and Profiling
Our learning platform may automatically record routine activities such as course progress, quiz scores, completion status and certificate eligibility.
Such processing supports learning administration and does not necessarily involve automated decision-making with legal or similarly significant consequences.
Performance Strategies does not intend to use learner information for solely automated decisions producing legal or similarly significant effects without satisfying applicable legal requirements.
Where such processing is introduced, appropriate transparency and safeguards will be provided.
23. Privacy Complaints and Regulatory Authority
Individuals who believe that their personal information has been handled inappropriately are encouraged to contact Performance Strategies first so that the concern can be investigated.
Complaints may be submitted to:
admin@performancestrategies.co
Where a matter cannot be resolved satisfactorily, individuals may exercise their right to lodge a complaint with Botswana’s Information and Data Protection Commission, in accordance with applicable legislation.
Nothing in this Privacy Policy restricts an individual’s lawful right to seek regulatory assistance or judicial remedies.
24. Changes to This Privacy Policy
Performance Strategies may update this Privacy Policy periodically to reflect changes in its training services, learning technologies, operational practices or applicable laws.
The revised policy will be published on www.performancestrategies.co with an updated effective date.
Where changes materially affect the processing of personal information, we will provide appropriate additional notice or seek further consent where required by law.
25. Contact Information
For questions, privacy requests, complaints or concerns relating to this Privacy Policy, please contact:
Performance Strategies Enterprises (Pty) Ltd
P.O. Box AE763, AEH
Molapo Crossing
Gaborone, Botswana
Email: admin@performancestrategies.co
Website: www.performancestrategies.co
26. Our Privacy Commitment
Performance Strategies Enterprises (Pty) Ltd is committed to protecting the personal information entrusted to us by our learners, clients and stakeholders.
We aim to uphold the principles of lawful, fair and transparent processing, purpose limitation, data minimisation, accuracy, appropriate retention, security and accountability.
We recognise that responsible data protection is not only a legal obligation but also an important component of professionalism, trust and organisational excellence.
Performance Strategies Enterprises (Pty) Ltd
Be the Best.