Privacy Policy
Performance Strategies Enterprises (Pty) Ltd
Effective date: 3 November 2026
Who we are and how to contact us
Performance Strategies Enterprises (Pty) Ltd (PSE) provides corporate training, self-paced online courses, public workshops, live virtual training and customised organisational training through www.performancestrategies.co and directly to clients.
PSE is the controller of information used for its own enrolment, payment, training, certification and business administration. An employer and PSE may each be independent controllers for their own activities. Where we act solely on a client’s documented instructions, the relevant agreement will define our processor responsibilities.
Privacy contact: admin@performancestrategies.co. Postal address: P.O. Box AE763, AEH, Molapo Crossing, Gaborone, Botswana. WhatsApp support: +267 76 579 789. Contact our privacy email for requests involving identity documents or sensitive information rather than sending documents through WhatsApp.
Information we process and why
We process account names, usernames, email addresses and authentication records to create accounts and provide access; enrolment, progress, quiz attempts, scores and completion records to administer training and verify certificates; billing and transaction references to confirm payment, issue receipts and handle refunds; support correspondence to resolve enquiries; and relevant device, IP address, session and security records to operate and protect the service.
We receive information directly from learners, through their use of the course platform, from payment providers and from employers arranging training. Where an employer supplies details, we will provide applicable privacy information and use those details only for a defined purpose. Passwords must never be sent to our staff. Card credentials are handled by the payment provider, not requested through our support channels.
Optional HRDC claim information
Learners whose employers intend to seek Human Resource Development Fund reimbursement may provide their first names and surname as shown on official identification, Omang number, gender, cellphone number and employer name. We use these details to match training records, prepare supporting documents, correct discrepancies and respond to authorised claim verification requests.
The additional HRDC fields are optional for ordinary course registration. Leaving them blank does not prevent access to a purchased course or a certificate earned under the published academic requirements. Missing information may, however, prevent PSE from preparing complete claim-support documents. We will explain any later information needed for a specific claim.
An employer’s claim requirements do not automatically require every learner to upload identification at registration. Where certified identification or another supporting document is needed, we will explain why, who needs it, and how to provide it securely. We will avoid holding copies where the employer can supply them directly to HRDC.
We share necessary claim-support information only with the learner, a verified employer representative, HRDC or another authorised recipient with a lawful reason to receive it. Omang numbers and gender are not made public, placed on public learner profiles, used for marketing or routinely printed on certificates. We do not provide one employer with another employer’s learner records.
Lawful grounds
We use contractual necessity for information needed to provide agreed learning services; applicable legal obligations for records or disclosures required by law; and legitimate interests for proportionate security, fraud prevention, business administration and claim-support activities where our assessment shows that these interests are not overridden by individual rights.
For optional activities that rely on consent, including promotional communications, consent must be separate, specific and withdrawable. Requesting HRDC support is not blanket consent to unrelated use. We assess the actual ground for each HRDC processing activity; an employer’s wish to claim is not by itself a legal obligation imposed on PSE. Where sensitive information is involved, we also identify an applicable additional legal condition.
Learning activities and confidentiality
For the self-paced Data Protection Compliance course, reflection responses and the final Data Protection Compliance Action Plan remain with the learner and are not submitted to PSE. Do not send organisational records, customer or employee information, passwords, incident files or confidential workplace examples through exercises, email or WhatsApp. Use fictional or effectively anonymised examples when asking questions. HRDC learner-identification details requested through the designated process are separate from confidential organisational learning exercises.
Employers, results and certificates
We may provide necessary attendance, completion and claim-support records to a verified sponsoring employer where lawful and explained to the learner. Payment by an employer does not grant unrestricted access to the learner’s account, messages or every quiz response. Requests for detailed marks or reports are assessed against the stated purpose and lawful basis.
Quiz marking and progress calculations may be automated. Learners can ask PSE to investigate an apparent marking or completion error. Certificate requests are checked against the relevant records before issue. We do not use HRDC fields to grade learners.
Providers, disclosures and international processing
Our service uses website hosting, WordPress and LearnPress software, video delivery, email, security, backup, payment and communication services. Providers may include HostGator, Bunny.net, PayPal and WhatsApp/Meta where those services are used. Software installed on our website does not necessarily mean its developer receives all learner information. We will disclose the actual external recipients and processing arrangements on request.
We limit provider access and apply appropriate contracts and safeguards. We may disclose information to professional advisers or authorities where lawfully necessary. We do not sell learner information.
Some providers process information outside Botswana. Before using such arrangements, we must establish a permitted transfer basis and safeguards, review relevant locations and onward transfers, and comply with applicable Botswana requirements for keeping a copy in Botswana during processing. Contact us for details of the arrangements relevant to your information. Accepting this policy is not blanket consent to unrestricted international transfers.
Retention
The 14-day course access period is not a deletion deadline. We retain minimum enrolment, assessment, payment and certification records beyond expiry when needed for verification, disputes, quality assurance or legal duties.
HRDC identifiers and supporting documents are retained only for the necessary claim, verification and applicable audit or legal period. Unneeded copies are deleted securely. Records required by law or a genuine dispute may be held longer; access is restricted during such holds. Security logs and support correspondence are retained according to their purpose and risk. Backups expire through the documented backup cycle and are protected from ordinary use.
We review retention and remove or anonymise information no longer needed. Individuals may ask for the applicable period or criteria for a particular record.
Security and incidents
We apply proportionate technical and organisational safeguards, including authorised access, secure authentication, updates, protected backups and provider oversight. No online service is risk-free. We assess suspected breaches, contain harm, document our response and make legally required notifications to the regulator and affected people.
Your choices and rights
Subject to applicable conditions, you can request information, access, correction, erasure, restriction, portability, withdrawal of consent, or object to processing, including direct marketing. Applicable safeguards also cover solely automated decisions with significant effects. Send requests to admin@performancestrategies.co. We verify identity proportionately and explain any lawful limitation. Withdrawal does not invalidate earlier lawful use or automatically require deletion of records we must retain.
Marketing, cookies and children
Marketing preferences are separate from enrolment and HRDC support. You may unsubscribe without losing your purchased course. Necessary course, payment and certificate messages may still be sent.
See our Cookie Notice for website technologies and choices. Our programmes are primarily for adults. Contact us before registering a child so we can assess programme suitability and any required authorisation and safeguards.
Changes
We publish revised notices with their effective date and provide additional notice or seek fresh consent where required. Changes do not remove existing legal rights.