Last Updated: 31 March 2026

Effective Date: 31 March 2026

1. Introduction

Reshift Africa ("we," "us," "our") is incorporated in Botswana and Rwanda and provides business development consulting services across the African continent, with a focus on clean energy, carbon markets, and emerging technologies. We are committed to protecting your privacy and complying with the Botswana Data Protection Act, 2018 (as amended 2024) and Rwanda Law No. 058/2021 Relating to the Protection of Personal Data and Privacy.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit www.reshift.africa (the "Site") or engage our consulting services.

2. Information We Collect

2.1. Personal Data You Provide

• Contact Information: Name, email address, phone number, company name, job title (via contact forms, email correspondence, or service inquiries)

• Business Information: Organization details, project requirements, sector interests

• Communication Records: Correspondence content, meeting notes, service feedback

2.2. Automatically Collected Data

• Device Information: IP address, browser type, operating system, device identifiers

• Usage Data: Pages visited, time spent, referral sources, click patterns

• Cookie Data: Information collected via cookies and similar tracking technologies (see Section 9)

2.3. Sensitive Personal Data

We do not routinely collect sensitive personal data (e.g., racial origin, health data, biometric data). If such data becomes necessary for a specific consulting engagement, we will obtain your explicit consent as required by Botswana and Rwanda law.

3. How We Use Your Information

We process your personal data for the following lawful purposes:

• Service Delivery: To provide consulting, advisory, market research, and partnership facilitation services

• Communication: To respond to inquiries, schedule meetings, and share relevant updates

• Business Development: To identify market opportunities and forge strategic partnerships on your behalf

• Legal Compliance: To comply with applicable laws in Botswana, Rwanda, and other jurisdictions where we operate

• Security: To protect our Site, systems, and data from unauthorized access, fraud, or cyber threats

Our processing adheres to the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.

4. Legal Basis for Processing

Under Botswana and Rwanda data protection laws, we process your data based on:

• Contractual Necessity: Processing required to perform consulting services you have requested

• Consent: Where you have given explicit consent (e.g., newsletter subscriptions, cookie usage)

• Legitimate Interests: For business development, security, and service improvement, provided these do not override your rights

• Legal Obligation: To comply with regulatory requirements in our jurisdictions of operation

5. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data. We may share data with:

• Service Providers: Trusted third parties (e.g., hosting providers, email services, CRM platforms) who process data on our behalf under strict confidentiality agreements

• Professional Advisors: Legal, accounting, or compliance advisors as necessary

• Government Authorities: When required by law, regulation, or legal process in Botswana, Rwanda, or other relevant jurisdictions

• Business Partners: Only with your explicit consent and solely for the purpose of facilitating partnerships you have requested

All third-party processors are contractually bound to implement appropriate security measures and comply with applicable data protection laws.

6. International Data Transfers

As a pan-African consulting firm, your data may be transferred to and processed in countries outside your residence, including Botswana, Rwanda, South Africa, and other African jurisdictions where we operate. We ensure adequate safeguards through:

• Standard Contractual Clauses or equivalent contractual protections

• Binding Corporate Rules where applicable

• Adequacy Determinations by relevant data protection authorities

7. Data Retention

We retain personal data only for as long as necessary to:

• Fulfill the purposes outlined in this Policy

• Comply with legal obligations (typically 5–7 years for business records under Botswana and Rwanda commercial law)

• Resolve disputes and enforce our agreements

Upon expiration of the retention period, data is securely deleted or anonymized.

8. Your Data Protection Rights

You have the following rights under Botswana and Rwanda law:

• Right to Access: Request a copy of your personal data

• Right to Rectification: Correct inaccurate or incomplete data

• Right to Erasure: Request deletion of your data ("right to be forgotten"), subject to legal exceptions

• Right to Restriction: Limit processing under certain circumstances

• Right to Data Portability: Receive your data in a structured, machine-readable format

• Right to Object: Object to processing based on legitimate interests

• Right to Withdraw Consent: Withdraw consent at any time (without affecting prior lawful processing)

• Right to Lodge a Complaint: File a complaint with the Data Protection Commissioner (Botswana) or National Data Protection Office (Rwanda)

To exercise these rights, contact us at info@reshift.africa. We will respond within a maximum of 30 days as required by law.

9. Cookies and Tracking Technologies

9.1. Cookie Banner

Our Site uses a cookie banner to obtain your consent before placing non-essential cookies on your device. By continuing to browse after accepting the banner, you consent to our use of cookies as described below.

9.2. Types of Cookies We Use

• Essential Cookies: Required for Site functionality (e.g., session management, security). No consent required.

• Analytics Cookies: Help us understand Site usage (e.g., Google Analytics). Require consent.

• Functional Cookies: Remember preferences (e.g., language, region). Require consent.

• Marketing Cookies: Used for targeted advertising (if applicable). Require consent.

9.3. Managing Cookies

You can manage cookie preferences via our cookie banner or by adjusting your browser settings. Note that disabling essential cookies may impair Site functionality.

10. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• Encryption: Data in transit (TLS/SSL) and at rest

• Access Controls: Role-based access, multi-factor authentication

• Regular Audits: Security assessments and penetration testing

• Employee Training: Data protection awareness for all staff

• Incident Response: Breach notification procedures compliant with Botswana (72-hour notification) and Rwanda requirements

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Updated versions will be posted on our Site with a revised "Last Updated" date. Material changes will be notified via email or prominent Site notice.

12. Contact Us

For privacy-related inquiries, data subject requests, or complaints:

• Email: info@reshift.africa

• Postal Address Botswana: Centric Works (Pty) Ltd t/a Reshift Africa, P O Box 1871, Francistown, Botswana

• Postal Address Rwanda: Reshift Africa Ltd., 1 KN 78 St, Kigali, Rwanda

You may also contact the supervisory authorities:

• Botswana: Data Protection Commissioner, Gaborone

• Rwanda: National Data Protection Office, Kigali