Effective Date: 13 July 2026
1. Introduction
Noble Accountants (“Noble Accountants”, “we”, “us” or “our”) is committed to protecting the privacy, confidentiality, and security of the personal information entrusted to us.
As a professional accounting and advisory firm operating in Botswana and South Africa, we process personal information in the course of providing accounting, taxation, advisory, corporate, fiduciary, financial reporting, back-office support, and related professional services.
This Privacy Policy explains how we collect, use, store, disclose, protect, and otherwise process personal information relating to our clients, prospective clients, website visitors, suppliers, business partners, employees, job applicants, and other individuals who interact with Noble Accountants.
We process personal information in accordance with applicable privacy and data protection laws, including, where applicable, the Botswana Data Protection Act and the South African Protection of Personal Information Act, 2013 (“POPIA”).
By using our website, engaging our services, communicating with us, or otherwise providing personal information to Noble Accountants, you acknowledge the practices described in this Privacy Policy.
2. Responsible Party and Data Controller
Depending on the jurisdiction and the nature of the engagement, the relevant Noble Accountants entity will act as the responsible party, data controller, or data processor in respect of personal information processed.
Where Noble Accountants processes personal information on behalf of a client, we may act as an operator, processor, or service provider and will process such information in accordance with our contractual obligations and applicable law.
3. Personal Information We Collect
We may collect and process personal information including:
- Names, surnames, identification numbers, passport details, dates of birth, and other identification information;
- Residential, postal, registered office, and business addresses;
- Telephone numbers, email addresses, and other contact details;
- Banking details, financial information, accounting records, tax information, payroll information, and transaction records;
- Employment, remuneration, pension, and employee-related information;
- Information concerning directors, shareholders, beneficial owners, trustees, beneficiaries, partners, members, employees, and authorised representatives;
- Information required for client identification, verification, customer due diligence, risk assessment, anti-money laundering, counter-terrorist financing, sanctions screening, and regulatory compliance;
- Correspondence, instructions, agreements, engagement letters, and records of communications;
- Information submitted through our website, online forms, email communications, social media pages, or other electronic platforms;
- Technical information such as IP addresses, browser types, device information, website usage information, cookies, and similar technologies;
- Recruitment information, including curriculum vitae documents, qualifications, employment history, references, and other information submitted by job applicants; and
- Any other personal information reasonably necessary for the provision of our services, compliance with our legal obligations, or operation of our business.
Where permitted by applicable law and necessary for legitimate professional or legal purposes, we may process special or sensitive personal information.
4. How We Collect Personal Information
We may collect personal information:
- Directly from you;
- From your authorised representatives, employees, directors, shareholders, business partners, advisers, or agents;
- From companies, trusts, partnerships, estates, and other entities with which you are associated;
- From public registers, government departments, regulators, tax authorities, courts, credit bureaus, and publicly available sources;
- From banks, financial institutions, professional advisers, auditors, attorneys, and other service providers;
- Through our website, electronic communications, social media pages, and digital platforms; and
- Through third parties where the collection of such information is lawful and appropriate.
5. Purposes for Which We Process Personal Information
Noble Accountants may process personal information for purposes including:
- Providing accounting, taxation, payroll, financial reporting, advisory, corporate finance, fiduciary, transaction support, and other professional services;
- Establishing, managing, and maintaining client relationships;
- Preparing proposals, quotations, engagement letters, contracts, and service agreements;
- Conducting client acceptance procedures, identity verification, due diligence, risk assessments, and conflict checks;
- Complying with tax, accounting, auditing, anti-money laundering, regulatory, professional, and other legal obligations;
- Communicating with clients, prospective clients, suppliers, regulators, authorities, and business partners;
- Processing payments, collecting fees, managing accounts, and recovering outstanding amounts;
- Managing complaints, disputes, legal proceedings, investigations, and professional indemnity matters;
- Maintaining the security and integrity of our information systems and business operations;
- Managing recruitment, employment, and human resources activities;
- Improving our website, services, systems, and client experience;
- Sending professional updates, newsletters, invitations, and marketing communications where permitted by law; and
- Protecting our legitimate business interests and exercising or defending legal rights.
6. Legal Basis for Processing
Where required by applicable law, we process personal information on one or more lawful grounds, including:
- Your consent;
- Performance of a contract or taking steps at your request before entering into a contract;
- Compliance with a legal or regulatory obligation;
- Protection of your legitimate interests or those of another person;
- Performance of a task carried out in the public interest where applicable; and
- Pursuit of our legitimate business and professional interests, provided that such interests do not unjustifiably infringe your privacy rights.
7. Disclosure of Personal Information
We do not sell personal information.
We may disclose personal information where necessary and lawful to:
- Employees, directors, consultants, contractors, and authorised representatives of Noble Accountants;
- Other entities within the Noble Accountants business structure, where applicable;
- Banks, financial institutions, insurers, auditors, attorneys, tax advisers, and other professional advisers;
- Technology providers, cloud service providers, software providers, website hosting providers, data storage providers, and cybersecurity service providers;
- Payroll, accounting, document management, electronic signature, communication, and other operational service providers;
- Tax authorities, company registries, financial intelligence authorities, regulators, courts, law enforcement agencies, and other governmental or statutory authorities;
- Third parties involved in a business restructuring, merger, acquisition, financing transaction, sale of assets, or similar transaction; and
- Any other person where disclosure is authorised by you or required or permitted by law.
We require third parties that process personal information on our behalf to implement appropriate confidentiality, privacy, and information security safeguards.
8. Cross-Border Transfers of Personal Information
As Noble Accountants operates in Botswana and South Africa and may use service providers located in other jurisdictions, personal information may be transferred, stored, accessed, or processed outside the country in which it was originally collected.
Where personal information is transferred across national borders, we take reasonable steps to ensure that such transfers comply with applicable data protection laws and that appropriate safeguards are implemented to protect personal information.
9. Information Security
Noble Accountants implements reasonable and appropriate technical, organisational, and administrative measures designed to protect personal information against:
- Loss or destruction;
- Unauthorised access;
- Unlawful processing;
- Accidental disclosure;
- Alteration or misuse; and
- Cybersecurity threats and information security incidents.
Our safeguards may include access controls, passwords, authentication measures, data backups, cybersecurity systems, confidentiality obligations, employee training, secure document management practices, and restrictions on access to personal information.
No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.
10. Data Retention
We retain personal information only for as long as reasonably necessary to:
- Provide our professional services;
- Fulfil the purposes for which the information was collected;
- Comply with legal, regulatory, tax, accounting, professional, and record-keeping obligations;
- Resolve disputes and complaints;
- Enforce agreements; and
- Establish, exercise, or defend legal claims.
When personal information is no longer required, we will securely delete, destroy, anonymise, or de-identify it, where reasonably practicable and permitted by law.
11. Your Privacy Rights
Subject to applicable law and any relevant limitations or exemptions, you may have the right to:
- Request confirmation as to whether we hold personal information about you;
- Request access to your personal information;
- Request correction or updating of inaccurate or incomplete personal information;
- Request deletion or destruction of personal information where legally permissible;
- Object to certain processing of your personal information;
- Request restriction of processing in circumstances recognised by applicable law;
- Withdraw consent where processing is based on consent;
- Object to direct marketing communications;
- Lodge a complaint with the relevant data protection or regulatory authority; and
- Exercise any other rights available under applicable privacy and data protection legislation.
We may require reasonable proof of identity before responding to a privacy request.
12. Direct Marketing
Where permitted by applicable law, Noble Accountants may send communications concerning our professional services, regulatory updates, tax developments, business insights, events, or other information that may be relevant to you.
You may opt out of receiving direct marketing communications at any time by using the unsubscribe mechanism provided in the communication or by contacting us.
Opting out of marketing communications will not prevent us from sending communications necessary for the provision of our services, administration of your account, or compliance with legal and regulatory obligations.
13. Cookies and Website Technologies
Our website may use cookies and similar technologies to:
- Enable website functionality;
- Improve website performance and security;
- Understand how visitors use our website;
- Remember user preferences;
- Analyse website traffic; and
- Support marketing activities where permitted by law.
Where required, we will obtain appropriate consent before placing non-essential cookies on your device.
You may manage cookies through your browser settings or through any cookie preference management tools made available on our website.
14. Third-Party Websites
Our website may contain links to third-party websites or services.
Noble Accountants is not responsible for the privacy, security, or content practices of third-party websites. We encourage users to review the privacy policies of third-party websites before providing personal information.
15. Children’s Personal Information
Our website and professional services are not generally directed at children.
Where we process children’s personal information in connection with professional services provided to clients, we will do so only where there is an appropriate legal basis and in accordance with applicable law.
16. Information Security Incidents
Where Noble Accountants becomes aware of a personal information breach or security incident, we will investigate the incident and take reasonable steps to contain, mitigate, and remediate any adverse effects.
Where required by applicable law, we will notify the relevant regulatory authority and affected individuals.
17. Changes to This Privacy Policy
Noble Accountants may amend this Privacy Policy from time to time to reflect changes in our business operations, services, technology, legal obligations, or regulatory requirements.
The updated Privacy Policy will be published on our website together with the revised effective date.
We encourage website visitors and clients to review this Privacy Policy periodically.
18. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how Noble Accountants processes personal information, please contact us:
Noble Accountants
South Africa and Botswana
Email: jolandie@noble-acc.co.za
Website: noble-acc.co.za
Privacy / Information Officer: Jolandie Vermeulen
19. Complaints
If you believe that Noble Accountants has processed your personal information unlawfully or has not adequately addressed a privacy concern, you may lodge a complaint directly with Noble Accountants.
You may also have the right to lodge a complaint with the competent data protection or regulatory authority in Botswana or South Africa, as applicable.
Noble Accountants will endeavour to address privacy complaints promptly, fairly, and in accordance with applicable law.