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Cloud Raptor Privacy Policy

Last Updated: 23-04-2026

Introduction

Sharp Thoughts (Pty) Ltd trading as Cloud Raptor ("Cloud Raptor", "we", "us", or "our") is committed to protecting the privacy and security of your personal data.

This Privacy Policy explains how we collect, use, disclose, and safeguard the personal information of our clients, prospective clients, and website visitors in accordance with the Botswana Data Protection Act, Act 33 of 2022 (DPA).

Important Distinction: Controller vs. Processor

  • Data Controller: For the administrative data we collect to manage your account, bill you, and provide support (e.g., your name, email, billing address), Cloud Raptor acts as the Data Controller. This Privacy Policy applies to this data.
  • Data Processor: For the data, applications, and content you host on our servers or manage through our Managed IT Services (MSP), you are the Data Controller, and Cloud Raptor acts strictly as the Data Processor. The processing of hosted data is governed entirely by our Master Services Agreement (MSA) and is not covered by this Privacy Policy.

Information We Collect

We may collect the following types of personal information:

  • Contact & Administrative Information: Full name, job title, company name, email address, physical address, and telephone numbers.
  • Financial Information: Billing address, VAT numbers, and payment details required for invoicing. (Note: Credit card or bank transfer details are processed securely by our authorized payment gateways; we do not store full credit card numbers on our servers).
  • Technical & Support Data: Information provided when you open a support ticket, including IP addresses, device identifiers, and details regarding your IT infrastructure necessary to resolve the issue.
  • Website Usage Data: Information collected automatically when you visit our website, including your IP address, browser type, operating system, referring URLs, and pages viewed, often collected via cookies.

How We Use Your Information (Legal Basis)

Under the Botswana DPA, we must have a valid legal basis to process your personal data. We use your information for the following purposes:

  1. Performance of a Contract: To provision our cloud hosting and MSP services, manage your account, process payments, and provide technical and emergency support.
  2. Legitimate Business Interests: To improve our website, monitor network security, prevent fraud, and analyze service usage trends.
  3. Direct Marketing (Existing Clients): As an existing client, we may use your contact details to send you information about new services, cybersecurity alerts, or promotions that we believe are relevant to your business, based on our legitimate interest in developing our business relationship.
  4. Consent: For non-clients or specific marketing campaigns, we will obtain your explicit consent before sending promotional materials.
  5. Legal Obligations: To comply with Botswana tax laws, accounting requirements, and other statutory or regulatory obligations.

How We Share Your Information

We do not sell, rent, or trade your personal information to third parties. We may share your data only in the following circumstances:

  • Service Providers: We may share necessary administrative data with trusted third-party vendors who assist us in operating our business (e.g., payment processors like FNB, accounting software, or ticketing systems). These providers are bound by strict confidentiality agreements.
  • Software Licensing (e.g., Microsoft): Where we provide third-party software licenses (such as Microsoft SPLA), we may be required to share basic administrative details to provision the license and report usage to the vendor.
  • Legal Compliance: We may disclose your information if required to do so by law, court order, or lawful request from Botswana government authorities or law enforcement.

Data Security & Residency

Cloud Raptor implements robust, industry-standard technical and organizational security measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction.

Data Residency: As a Botswana-based cloud provider, our primary physical servers and data centers are located within the borders of the Republic of Botswana.

Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law.

  • Client Account Data: Retained for the duration of our business relationship.
  • Financial Records: Retained for the statutory period required by the Botswana Unified Revenue Service (BURS) (typically 7 years) after the termination of services.

Your Data Protection Rights

Under the Botswana Data Protection Act (Act 33 of 2022), you have the right to:

  • Access: Request a copy of the personal data we hold about you.
  • Correction: Request that we correct any inaccurate or incomplete personal data.
  • Erasure: Request the deletion of your personal data, subject to our legal and contractual retention obligations.
  • Objection: Object to the processing of your personal data for direct marketing or where we rely on legitimate interests.
  • Restriction: Request the restriction of processing your personal data under certain circumstances.

Direct Marketing & Your Communications Preferences

We want to keep our clients informed about the latest cloud technologies, cybersecurity threats, and Cloud Raptor service offerings.

How to Opt-Out of Marketing 
You have the absolute right to object to receiving direct marketing from us at any time. You can opt out by:

  • Clicking the "Unsubscribe" link at the bottom of any marketing email we send you.
  • Emailing our support team or Data Protection Officer directly to request removal from our marketing lists.

Service Communications (No Opt-Out)
Please note that even if you opt out of marketing communications, Cloud Raptor will continue to send you critical, non-promotional Service Communications. These include invoice notifications, SLA breach alerts, scheduled maintenance warnings, and security incident reports. Because these are essential for the performance of our contract, you cannot opt out of Service Communications while remaining an active client.

Cookies and Tracking Technologies

Our website uses cookies to enhance user experience, analyse site traffic, and assist in our marketing efforts. You can control cookie preferences through your web browser settings. Disabling essential cookies may limit your ability to use certain features of our website or client portal.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be indicated by an updated "Last Updated" date at the top of this page. We encourage you to review this policy periodically.

Contact Us

If you have any questions, concerns, or wish to exercise your data protection rights regarding this Privacy Policy, please contact our Data Protection Officer (DPO) at:

Sharp Thoughts (Pty) Ltd t/a Cloud Raptor

Physical Address: Unit 3, Setlhoa Showrooms, Plot 75748, Gaborone, Botswana
Email: [email protected]
Phone: +267 391 0020