1. Who We Are and How This Policy Applies

Cabanga is a pan-African business media and digital infrastructure network. Every regional edition runs the same architecture and the same standard, and this single policy governs all of them. References to "Cabanga" include the network as a whole and the individual edition whose website or publication you are engaging with.

The entity responsible for personal information collected through the network is Cabanga Africa Group (Pty) Ltd, together with the publisher of the relevant regional edition. Contact details are set out at the end of this policy.

2. The Information We Collect

Information you give us

• Subscriptions and newsletters - your name, email address and any preferences you set when you subscribe to an edition, newsletter or alert.
• Enquiries and correspondence - the contact details and message content you provide when you write to us, complete a form, or respond to a campaign.
• Accounts and registrations - where an edition offers an account, the details you supply to create and manage it.
• Commercial and advertising enquiries - the business and contact information you share when you approach us about advertising, branded content, partnerships or events.
• Contributions and comments - anything you submit for publication or post in a comment area, including your name and the content itself.

Information we collect automatically

• Usage and device data - pages viewed, time on site, referring source, approximate location, browser type, device and operating system.
• Cookies and similar technologies - small files and identifiers that help the site function, remember your preferences, and measure readership. See section 6.
• Log data - standard server records such as IP address and the date and time of your request.

Information from other sources

We may receive information from analytics providers, advertising partners, social platforms you use to interact with us, and event or list partners where you have consented to their sharing it. We combine this only as described in this policy.

3. How We Use Your Information

We use personal information to:

• deliver our editions, newsletters, alerts and the services you request;
• respond to your enquiries, comments and commercial approaches;
• operate, secure, maintain and improve our websites and publications;
• understand readership so we can commission and edit better journalism;
• personalise content and recommendations where you have not opted out;
• send marketing and editorial communications where you have consented or where the law otherwise permits, always with a clear way to opt out;
• administer advertising and measure its performance; and
• meet our legal, regulatory and accounting obligations.

4. Our Lawful Basis for Processing

We process personal information only where we have a lawful basis to do so under the data protection laws of the markets in which our editions are published, including the Protection of Personal Information Act (POPIA) in South Africa, the Data Protection Act in Botswana, the Cyber and Data Protection Act in Zimbabwe, the Data Protection Act in Zambia, and equivalent legislation elsewhere on the continent.

• Consent - for marketing communications, certain cookies, and where else the law requires it. You may withdraw consent at any time.
• Contract - to provide a subscription, account or service you have asked for.
• Legitimate interests - to run, secure and improve our publications and to understand our readership, balanced against your rights.
• Legal obligation - where we are required to process information to comply with the law.

5. How We Share Information

We do not sell your personal information. We share it only as needed to run the network and meet our obligations:

• Service providers - hosting, email delivery, analytics, payment and customer-support partners who process information on our instructions and under confidentiality obligations.
• Advertising and measurement partners - where you have not opted out, to deliver and measure advertising. See section 7.
• Within the network - between Cabanga Africa Group and its regional editions, so the reader experience is consistent across markets.
• Legal and protective disclosures - where required by law, regulation or legal process, or to protect our rights, our readers and the safety of others.
• Business transfers - in connection with a merger, acquisition or reorganisation, subject to this policy.

6. Cookies and Similar Technologies

Our sites use cookies and similar technologies to function correctly, remember your preferences, measure readership and, where permitted, support advertising. Strictly necessary cookies are always active because the site cannot work without them. For all others, we ask for your choice through our cookie settings, and you can change that choice at any time.

You can also control cookies through your browser settings. Blocking some cookies may affect how parts of the site work.

7. Advertising and Analytics

Some editions carry advertising and use analytics to understand how our journalism is read. These partners may set cookies or use identifiers to measure performance and, where you have consented, to show more relevant advertising. We hold our commercial partners to the editorial firewall described in our Editorial Policy: advertising never buys influence over our reporting.

8. International Data Transfers

As a pan-African network with operations across multiple countries, we may transfer and store personal information in markets other than your own, including across our operating bases in Botswana, South Africa, Zimbabwe and Zambia and the locations of our service providers. Where we do, we take steps to ensure your information remains protected to the standard set out in this policy and required by applicable law.

9. How Long We Keep Information

We keep personal information only for as long as we need it for the purposes set out in this policy, to provide the services you have requested, and to meet legal, accounting and regulatory requirements. When we no longer need it, we delete it or anonymise it securely.

10. How We Protect Information

We use appropriate technical and organisational measures to protect personal information against loss, misuse and unauthorised access. No system is perfectly secure, but we work continuously to safeguard the information you entrust to us and to respond promptly if something goes wrong.

11. Your Rights

Subject to the data protection law that applies to you, you may have the right to:

• access the personal information we hold about you;
• correct information that is inaccurate or incomplete;
• ask us to delete information where there is no lawful reason to keep it;
• object to or restrict certain processing, including direct marketing;
• withdraw consent where processing is based on it; and
• lodge a complaint with the data protection authority in your market.

To exercise any of these rights, contact us using the details in section 15. We will respond within the period required by applicable law.

12. Children's Privacy

Cabanga is a business publication written for operators and decision-makers. Our sites and services are not directed at children, and we do not knowingly collect personal information from anyone under the age of 18. If you believe a child has provided us with personal information, please contact us and we will remove it.

13. Third-Party Links

Our publications link to other websites, companies and sources because our journalism is built on the real economy. We are not responsible for the privacy practices of those third parties, and we encourage you to read their policies before sharing information with them.

14. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices, technology or the law. When we make material changes, we will update the effective date above and, where appropriate, tell you directly. Continued use of our publications after an update means you accept the revised policy.

15. How to Contact Us

For any question about this policy or about how we handle your personal information, including to exercise your rights, contact:

Privacy enquiries: [privacy@cabanga.africa]
Postal address: Cabanga Africa Group (Pty) Ltd, Gaborone, Johannesburg, Harare

Where a specific regional edition collects your information, you may also contact that edition directly using the details on its website.