PRIVACY POLICY

Tonota Football Club

Effective Date: 7 September 2026
Last Updated: 7 September 2026

1. INTRODUCTION

Tonota Football Club (“Tonota FC”, “the Club”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal information entrusted to us by players, parents and guardians, members, supporters, coaches, officials, volunteers, staff, sponsors, visitors to our website and other individuals who interact with the Club.

This Privacy Policy explains how Tonota Football Club collects, uses, stores, protects and, where necessary, shares personal data.

This Policy applies to personal data collected through:

• the Tonota Football Club website;

• player and team registration;

• membership applications;

• player profiles and statistics;

• contact and enquiry forms;

• newsletter and mailing-list subscriptions;

• competitions, promotions and events;

• photographs, video recordings and match coverage;

• social-media interactions;

• sponsorship and commercial activities;

• communications with the Club; and

• other services or activities operated by or on behalf of Tonota Football Club.

Tonota FC is committed to processing personal data in accordance with applicable laws of Botswana, including the Data Protection Act, 2024 (Act No. 18 of 2024) and other applicable legislation.

The Data Protection Act, 2024 provides a framework for protecting personal data and maintaining individuals’ privacy and gives data subjects rights concerning their personal information.

2. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

For the purposes of applicable data-protection legislation, Tonota Football Club may act as a data controller in relation to personal data that it determines the purposes and means of processing.

Where we engage another organisation to process personal data on our behalf, that organisation may act as a data processor.

Our details are:

Tonota Football Club
Tonota, Botswana

Privacy/Data Protection Contact: Data Protection officer

Email:
dpo@tonotafc.com

Telephone:
+267 363 0003

Postal Address:
P.O Box 676, Tonota, Botswana

3. WHAT IS PERSONAL DATA?

“Personal data” generally means information relating to an identified or identifiable individual.

Depending on how you interact with Tonota FC, this may include:

• full name;

• date of birth;

• age;

• gender;

• nationality;

• photograph;

• video or audio recording;

• email address;

• telephone number;

• postal or physical address;

• emergency contact details;

• parent or guardian details;

• player registration information;

• membership information;

• team information;

• playing position;

• shirt number;

• player statistics;

• match appearances;

• goals, assists and disciplinary information;

• identification information where required for legitimate Club purposes;

• payment and transaction information;

• communications with the Club;

• website usage information;

• IP address;

• device and browser information;

• cookies and similar technologies;

• social-media account information where you interact with the Club;

• information provided when entering competitions or Club activities; and

• any other information that can reasonably be associated with an identifiable individual.

4. SENSITIVE PERSONAL DATA

Some information receives additional protection under Botswana’s data-protection framework.

Depending on the circumstances, Tonota FC may process information relating to matters such as:

• physical or mental health;

• medical conditions;

• injuries;

• fitness information;

• biometric information;

• racial or ethnic origin;

• religious or philosophical beliefs;

• criminal convictions or offences where lawfully relevant;

• or other information classified as sensitive personal data under applicable law.

Tonota FC will only collect or process sensitive personal data where there is a lawful basis and where the processing is necessary and appropriate for the relevant purpose.

For example, limited medical information may be required to protect the health and safety of players participating in football activities.

We will not use sensitive personal data for unrelated purposes merely because it has been provided to us.

5. HOW WE COLLECT PERSONAL DATA

We may collect personal data directly from you when you:

• register as a player;

• register as a member;

• complete an online form;

• contact the Club;

• subscribe to communications;

• purchase a Club product or service;

• participate in Club activities;

• attend or participate in an event;

• communicate with Club officials;

• submit information relating to a player;

• interact with our website;

• interact with our social-media pages; or

• otherwise voluntarily provide information to us.

We may also receive information from:

• parents or legal guardians;

• coaches and team officials;

• football associations or competition organisers;

• affiliated clubs or sporting organisations;

• service providers;

• sponsors or event partners where lawful;

• publicly available sources; and

• third-party platforms used to administer football activities.

Where we obtain personal data from another source, we will handle it in accordance with applicable data-protection requirements.

6. INFORMATION ABOUT CHILDREN AND YOUNG PLAYERS

Tonota FC recognises that many football players may be children or young persons.

Where a player is a child, we will take additional care when collecting and processing their personal data.

Depending on the circumstances and applicable law, we may require consent or involvement from a parent, guardian or other person legally authorised to act on behalf of the child.

Information relating to children will only be collected and used for appropriate Club purposes, such as:

• player registration;

• team administration;

• safeguarding;

• competition participation;

• communication with parents or guardians;

• medical and emergency purposes;

• player development;

• match administration;

• legitimate publication of football information; and

• compliance with football or legal requirements.

We will not knowingly use children’s personal information for unrelated commercial purposes.

Where the Club publishes player photographs, profiles, names, statistics or other information concerning minors, appropriate safeguards will be considered based on the nature and purpose of the publication.

Parents or guardians may contact the Club using the details in this Privacy Policy if they have concerns regarding a child’s personal data.

7. WHY WE COLLECT AND USE PERSONAL DATA

Tonota FC may process personal data for the following purposes:

7.1 Club administration

We may use personal data to:

• administer Club membership;

• maintain player records;

• organise teams;

• manage registrations;

• communicate with players and members;

• manage coaches, officials and volunteers;

• maintain Club records; and

• administer Club activities.

7.2 Football administration

We may process information to:

• register players for competitions;

• manage fixtures;

• record match results;

• maintain player statistics;

• maintain league tables;

• publish match reports;

• maintain player profiles;

• manage disciplinary records;

• communicate team information; and

• comply with requirements of relevant football governing bodies.

7.3 Player safety

We may process relevant information to:

• protect player health and safety;

• manage injuries;

• respond to emergencies;

• maintain emergency contact information;

• accommodate relevant medical requirements; and

• fulfil safeguarding responsibilities.

7.4 Website operation

We may process information to:

• operate and maintain our website;

• improve website performance;

• diagnose technical problems;

• prevent fraud or abuse;

• protect website security;

• understand website usage; and

• provide requested online services.

7.5 Communications

We may use contact information to:

• respond to enquiries;

• provide Club announcements;

• send fixture information;

• provide membership communications;

• communicate important administrative information;

• send newsletters where permitted; and

• communicate about Club events.

7.6 Marketing

Where permitted by law, we may use personal data to send information about:

• Club activities;

• merchandise;

• events;

• sponsorship opportunities;

• promotions;

• fundraising activities; and

• other Club-related activities.

Where marketing requires consent, we will obtain appropriate consent.

You may unsubscribe from marketing communications at any time.

8. PLAYER PROFILES AND FOOTBALL STATISTICS

Tonota FC may publish football-related information concerning players as part of normal sporting administration and reporting.

This may include:

• player name;

• photograph;

• team;

• squad number;

• playing position;

• age or date of birth where appropriate;

• nationality where appropriate;

• appearances;

• goals;

• assists;

• cards;

• match statistics;

• player achievements;

• team history; and

• other football-related information.

The purpose of publishing such information may include:

• documenting Club activities;

• providing supporters with football information;

• reporting match results;

• maintaining historical records;

• promoting players and teams;

• supporting competition administration; and

• communicating the Club’s sporting activities.

Tonota FC will seek to ensure that published player information is relevant, proportionate and appropriate to the context.

9. PHOTOGRAPHS, VIDEO AND AUDIO

Football is a public sporting activity and Tonota FC may photograph, film or otherwise record matches, training sessions, events and other Club activities.

Images and recordings may be used for:

• the Club website;

• match reports;

• player profiles;

• social media;

• promotional materials;

• newsletters;

• media coverage;

• historical archives;

• sponsorship activities; and

• other legitimate Club communications.

Where required, Tonota FC will obtain appropriate permission or consent for the relevant use.

Special care will be taken regarding photographs and recordings involving children.

If you believe a photograph, video or other recording has been published inappropriately, please contact us using the details in Section 20.

10. LEGAL BASES FOR PROCESSING

Tonota FC will process personal data only where there is a lawful basis for doing so.

Depending on the circumstances, this may include:

• your consent;

• performance of a contract or agreement;

• compliance with a legal obligation;

• protection of vital interests;

• performance of a task or function permitted by law;

• legitimate interests, where applicable and appropriate;

• establishment, exercise or defence of legal claims; or

• another lawful basis recognised by applicable Botswana law.

Where processing is based on consent, consent will be requested in a manner that is clear, specific, informed and capable of being withdrawn.

The Data Protection Act, 2024 expressly provides for withdrawal of consent and requires consent to be appropriately obtained.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

11. DATA MINIMISATION

Tonota FC will seek to collect only personal data that is reasonably necessary for the purpose for which it is being processed.

We will not intentionally collect excessive personal information merely because it may be useful in the future.

Where information is no longer necessary for its original purpose and there is no legal or legitimate reason to retain it, we will consider deleting, anonymising or securely disposing of it.

12. ACCURACY OF PERSONAL DATA

We seek to maintain accurate and up-to-date personal information.

You should notify us if information you have provided to Tonota FC changes or is inaccurate.

You may request correction of inaccurate or incomplete personal data in accordance with your rights under applicable law.

13. HOW WE USE COOKIES

Our website may use cookies and similar technologies.

Cookies are small text files stored on your device that can help a website remember information about your visit.

We may use cookies for:

• essential website functionality;

• security;

• remembering preferences;

• website analytics;

• performance monitoring;

• improving user experience; and

• other legitimate website purposes.

Where applicable, non-essential cookies will be used only in accordance with applicable requirements.

You may be able to control cookies through your browser settings.

Disabling certain cookies may affect website functionality.

14. WEBSITE ANALYTICS

Tonota FC may use analytics services to understand how visitors interact with our website.

Analytics information may include:

• pages visited;

• approximate location;

• browser type;

• device type;

• referring website;

• time spent on pages;

• interactions with website features; and

• technical information such as IP address.

Where third-party analytics providers are used, their processing will be subject to their own terms and privacy policies as well as our contractual and data-protection obligations.

15. THIRD-PARTY SERVICES

Tonota FC may use third-party providers to operate aspects of its website and Club administration.

These may include providers of:

• website hosting;

• email;

• cloud storage;

• website analytics;

• payment processing;

• membership management;

• football statistics;

• registration services;

• security services;

• communication platforms;

• social-media services; and

• other technical or administrative services.

We will seek to ensure that third-party processors process personal data only for authorised purposes and provide appropriate security measures.

Where required by applicable law, appropriate agreements and safeguards will be put in place.

16. SOCIAL MEDIA

Tonota FC may operate or maintain accounts on social-media platforms.

If you interact with us through a social-media platform, the relevant platform may independently collect and process your personal information.

Your use of those platforms is subject to the privacy policies and terms of the relevant platform.

Tonota FC does not control how independent social-media companies process personal data outside the Club’s control.

17. DISCLOSURE OF PERSONAL DATA

Tonota FC will not sell your personal data.

We may disclose personal data where reasonably necessary and lawful to:

• football governing bodies;

• competition organisers;

• affiliated sporting organisations;

• coaches and authorised Club officials;

• medical or emergency personnel;

• parents or guardians where appropriate;

• service providers;

• technology providers;

• payment providers;

• professional advisers;

• insurers;

• legal authorities;

• law-enforcement authorities where legally required;

• courts or tribunals;

• auditors;

• sponsors or partners where there is an appropriate lawful basis; or

• other recipients where disclosure is authorised or required by law.

We will seek to ensure that disclosures are limited to information that is reasonably necessary for the relevant purpose.

18. INTERNATIONAL DATA TRANSFERS

Some of our technology providers may store or process information outside Botswana.

This may occur where Tonota FC uses:

• cloud hosting;

• international email providers;

• website platforms;

• analytics services;

• social-media platforms;

• payment platforms; or

• other technology services whose infrastructure is located outside Botswana.

Where personal data is transferred outside Botswana, Tonota FC will comply with applicable requirements governing international transfers.

The Data Protection Act, 2024 contains specific requirements for transfers of personal data to third countries and international organisations. Among other requirements, the Act provides safeguards concerning the level of protection available in the receiving jurisdiction and requires that a copy of transferred personal data remain in Botswana for the period of processing.

Where required, Tonota FC will use appropriate safeguards, contractual protections, approved mechanisms or other lawful transfer mechanisms.

19. DATA SECURITY

Tonota FC takes reasonable and appropriate measures to protect personal data against:

• unauthorised access;

• unauthorised disclosure;

• accidental loss;

• destruction;

• alteration;

• misuse;

• theft; and

• other unlawful or unauthorised processing.

Security measures may include:

• access controls;

• passwords and authentication;

• restricted administrative access;

• secure hosting;

• backups;

• encryption where appropriate;

• malware and security monitoring;

• staff and volunteer awareness;

• contractual safeguards with service providers; and

• secure disposal of information.

However, no electronic system can be guaranteed to be completely secure.

You should avoid sending highly sensitive information through unsecured communication channels unless specifically requested by the Club.

20. PERSONAL DATA BREACHES

If Tonota FC becomes aware of a personal-data breach, we will assess the incident and take appropriate steps to contain, investigate and remediate it.

Where required by applicable law, we will notify the relevant regulatory authority and affected individuals within the applicable statutory timeframes.

The Botswana Data Protection Act, 2024 provides specific requirements concerning personal-data breaches, including notification obligations and measures intended to protect affected data subjects.

If you believe your personal information has been compromised, please contact us immediately using:

Email: dpo@tonotafc.com

21. HOW LONG WE KEEP PERSONAL DATA

Tonota FC will retain personal data only for as long as reasonably necessary for the purpose for which it was collected, unless a longer retention period is required or permitted by law.

Retention periods may depend on:

• the purpose for which the information was collected;

• whether you remain a player or member;

• legal obligations;

• accounting requirements;

• safeguarding obligations;

• dispute resolution;

• insurance requirements;

• football record-keeping requirements;

• historical or archival purposes; and

• legitimate Club interests.

Some football records may be retained as historical sporting records.

Where information is retained for archival purposes, we will consider whether it can be anonymised or otherwise protected where appropriate.

22. YOUR DATA PROTECTION RIGHTS

Subject to applicable legal conditions and limitations, you may have rights including:

Right of access

You may request confirmation of whether we process personal data about you and, where applicable, request access to that information.

Right to rectification

You may request correction of inaccurate or incomplete personal data.

Right to erasure

In appropriate circumstances, you may request deletion of personal data.

This right is not absolute and may not apply where Tonota FC is legally required or otherwise permitted to retain the information.

Right to restriction of processing

In certain circumstances, you may request that processing of your personal data be restricted.

Right to data portability

Where applicable, you may have the right to receive certain personal data in a structured and commonly used machine-readable format or request its transmission to another controller.

Right to object

In appropriate circumstances, you may object to certain processing of your personal data.

You may also object to direct marketing.

Right to withdraw consent

Where processing is based on consent, you may withdraw your consent.

Rights concerning automated decision-making

Where applicable, you may have rights relating to decisions based solely on automated processing, including profiling, where such processing produces legal or similarly significant effects.

The Data Protection Act, 2024 expressly provides for rights including access, rectification, erasure, restriction, data portability, objection and safeguards concerning automated decision-making.

23. HOW TO EXERCISE YOUR RIGHTS

To exercise a data-protection right, please contact:

Data Protection Officer / Privacy Officer
Tonota Football Club

Email: dpo@tonotafc.com

Telephone: +267 363 0003

Postal Address: P,O Box 676, Tonota, Botswana

Your request should, where possible, include:

• your full name;

• contact details;

• the nature of your request;

• information that will help us identify the relevant records; and

• any other information reasonably necessary to process your request.

We may need to verify your identity before releasing personal data or making changes to personal information.

This is intended to protect personal data from being disclosed to an unauthorised person.

We will handle valid requests within the applicable statutory period.

Where permitted by law, we may decline or limit a request where a legal exemption applies.

24. IDENTITY VERIFICATION

Because personal information is confidential, Tonota FC may need to verify your identity before responding to certain requests.

We will request only information reasonably necessary for verification.

Where an identity document is provided solely for verification, we will seek to avoid retaining unnecessary copies or will securely delete them when they are no longer required.

25. DIRECT MARKETING

Where permitted by law, Tonota FC may send you information about Club activities, events, merchandise, fundraising, sponsorship and other Club-related opportunities.

You may opt out of marketing communications at any time.

Every electronic marketing communication should provide an appropriate way to unsubscribe or request that marketing communications stop.

Opting out of marketing does not necessarily stop essential administrative communications, such as:

• registration information;

• fixture changes;

• competition information;

• safety notices;

• account information; or

• other communications necessary to administer your relationship with the Club.

26. PAYMENT INFORMATION

Where the Club accepts payments electronically, payments may be processed by third-party payment providers.

Tonota FC may receive limited transaction information, such as:

• payer name;

• transaction reference;

• amount paid;

• date of payment;

• payment status; and

• other information necessary for accounting and reconciliation.

Where payments are processed by a third-party payment provider, payment-card details may be handled directly by that provider rather than stored by Tonota FC.

You should review the privacy policy of the relevant payment provider before completing a transaction.

27. PLAYER REGISTRATION AND FOOTBALL GOVERNING BODIES

Where registration with a football association, league, competition organiser or other governing body is required, Tonota FC may be required to submit relevant player information.

This information may include:

• name;

• date of birth;

• registration information;

• identification information;

• photograph;

• team;

• playing information;

• disciplinary information; and

• other information required by the relevant sporting authority.

Such processing may be necessary for legitimate sporting administration, contractual obligations, legal obligations or another lawful basis.

28. MEDICAL AND EMERGENCY INFORMATION

For player safety, Tonota FC may collect limited information concerning:

• allergies;

• medical conditions;

• injuries;

• medication;

• emergency contacts;

• fitness restrictions; and

• other information relevant to safe participation.

Such information will be treated confidentially and accessed only by persons who reasonably require it for safety, medical, safeguarding or Club administration purposes.

Medical information will not be publicly displayed as part of ordinary player profiles unless there is an appropriate lawful basis and specific justification.

29. DATA FROM THIRD PARTIES

Tonota FC may receive personal data about players, members or other individuals from authorised third parties.

Examples include:

• parents or guardians;

• coaches;

• football associations;

• leagues;

• competition organisers;

• team managers;

• authorised Club officials;

• event organisers; and

• service providers.

Where required, we will provide appropriate privacy information concerning such processing.

30. LINKS TO OTHER WEBSITES

Our website may contain links to external websites.

These websites are not controlled by Tonota FC.

We are not responsible for the privacy practices, security or content of external websites.

We encourage you to review the privacy policy of any website before providing personal information.

31. THIRD-PARTY EMBEDDED CONTENT

Our website may contain embedded content such as:

• social-media posts;

• videos;

• maps;

• match information;

• statistics;

• external forms;

• advertisements;

• payment services; or

• other third-party content.

Third-party content may cause your browser or device to communicate directly with the third-party provider.

Such providers may collect information in accordance with their own privacy policies.

32. SERVER LOGS AND TECHNICAL INFORMATION

When you visit our website, our hosting or security systems may automatically record technical information such as:

• IP address;

• browser type;

• operating system;

• device type;

• referring page;

• pages requested;

• date and time of access;

• security events; and

• other technical information.

This information may be used for:

• website operation;

• security;

• troubleshooting;

• fraud prevention;

• performance monitoring; and

• statistical analysis.

33. AUTOMATED DECISION-MAKING AND PROFILING

Tonota FC does not ordinarily make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.

If this changes, we will provide appropriate information and safeguards as required by applicable law.

34. DATA PROTECTION BY DESIGN

Tonota FC seeks to consider privacy and data protection when introducing new systems, websites, registration processes or technologies involving personal data.

Where a proposed processing activity presents a high risk to individuals’ rights and freedoms, Tonota FC will consider whether a Data Protection Impact Assessment or other privacy assessment is required.

35. ACCOUNTABILITY

Tonota FC seeks to maintain appropriate internal measures to demonstrate responsible handling of personal data.

These measures may include:

• privacy policies;

• data-protection procedures;

• access controls;

• staff and volunteer guidance;

• processor agreements;

• data-retention procedures;

• security measures;

• incident-response procedures; and

• periodic review of data-processing activities.

36. CONFIDENTIALITY

Persons authorised by Tonota FC to access personal data will be expected to maintain appropriate confidentiality.

Personal information will only be accessed where there is a legitimate reason to do so.

37. YOUR RESPONSIBILITIES

When providing personal data to Tonota FC, you should ensure that information provided is accurate and, where you provide information concerning another person, that you are authorised to provide it.

Parents and guardians should take particular care when submitting information concerning children.

You should also inform us if your contact information or other relevant information changes.

38. CHANGES TO THIS PRIVACY POLICY

Tonota FC may update this Privacy Policy from time to time.

Changes may be made to reflect:

• changes in legislation;

• regulatory guidance;

• changes to Club activities;

• changes to technology;

• new services;

• changes to third-party providers; or

• improvements to our privacy practices.

The latest version will be published on our website.

The “Last Updated” date at the beginning of this Policy indicates when the Policy was most recently revised.

39. COMPLAINTS

If you believe that Tonota FC has processed your personal data unlawfully or has failed to respect your privacy rights, we encourage you to contact us first so that we can investigate and attempt to resolve your concern.

Complaints should be submitted to:

Tonota Football Club
Attention: Data Protection Officer

Email: dpo@tonotafc.com

Telephone: +256 363 0003

Address: P.O Box 675, Tonota, Botswana

You may also have the right to lodge a complaint with Botswana’s Information and Data Protection Commission (IDPC) or seek another remedy available under applicable law.

The IDPC is the regulatory body responsible for oversight and enforcement of Botswana’s data-protection framework.

40. GOVERNING LAW

This Privacy Policy is governed by the laws of the Republic of Botswana.

Nothing in this Privacy Policy is intended to limit any mandatory rights or protections available to an individual under applicable Botswana law.

41. CONTACT US

If you have questions about this Privacy Policy, your personal data or how Tonota FC processes information, please contact us.

Tonota Football Club

Privacy/Data Protection Officer:
–

Email:
dpo@tonotafc.com

Telephone:
+256 363 0003

Physical Address:
Tonota FC, Manyanfa Complex, Tonota, Botswana

Postal Address:
P.O Box 675, Tonota, Botswana

Website:
[Insert Website]

42. SUMMARY OF OUR PRIVACY COMMITMENT

Tonota Football Club is committed to:

• collecting personal data responsibly;

• being transparent about how information is used;

• collecting information for legitimate purposes;

• avoiding unnecessary collection of personal information;

• maintaining accurate information;

• protecting personal information against unauthorised access;

• limiting access to authorised persons;

• protecting children’s personal data;

• respecting data-subject rights;

• not selling personal data;

• using appropriate safeguards when working with third parties;

• securely disposing of information when it is no longer required; and

• complying with applicable Botswana data-protection law.

By interacting with Tonota Football Club, you can expect us to treat your personal information with care, respect and appropriate security.