Privacy Policy

1. Who we are and what this policy covers

Masheleng Wealth Institute is a registered business name of Ignytwealth Training Institute Proprietary Limited (registration number BW00002212913), a company registered in Botswana, of Plot 49, Unit 4, Commerce Park, Gaborone, Botswana. We are the data controller responsible for the personal information described here, including for members in South Africa.

This policy covers both of our websites: masheleng.com, where we publish information about our programmes and services, and institute.masheleng.com, the portal where you hold an account, take courses, subscribe and buy from our shop. It applies to everything we do with your information across both.

We are based in Botswana and most of our members are in Botswana, but our programmes are also open to members in South Africa. Where the two countries differ, we have applied the stricter standard rather than the more convenient one.

2. The law we work to

Depending on where you are, your information is protected by:

• Botswana — the Data Protection Act No. 18 of 2024, which came into force on 14 January 2025 and replaced the earlier 2018 Act. The regulator is the Information and Data Protection Commission.
• South Africa — the Protection of Personal Information Act 4 of 2013 (POPIA). The regulator is the Information Regulator (South Africa).

Our consumer obligations sit with the Competition and Consumer Authority in Botswana, and with the Consumer Protection Act and the Electronic Communications and Transactions Act in South Africa.

3. What we collect

We have set this out in full rather than in general terms, because some of what we hold is genuinely sensitive and you are entitled to know exactly what it is.

Depending on how you use our services, we hold:

• Account details — your name, surname, email address, phone number, country, and if you choose to give them, your date of birth, gender and a profile picture.
• Identity number — where you provide a Botswana national identity number (Omang), we store it encrypted, not as ordinary text.
• Your financial wellbeing profile — the answers you give in our onboarding survey and needs analysis. This includes your age band, employment status, monthly income band, dependants, and your debt and credit position: how much you owe, how many credit accounts you hold, whether you are up to date on repayments, whether you have garnishee orders against you, whether you are listed with a credit bureau, whether you are under debt counselling, whether you have missed payments in the last six months, whether debt collectors have contacted you, and what you believe caused your debt.
• Insurance information — where you use our cover and needs analysis tools, the policy details you enter and the details of any beneficiaries you name. Beneficiary details are information about someone else, so please only give them if you are entitled to.
• Learning activity — the courses you enrol in, your progress through lessons, quiz results and certificates issued to you.
• Purchases — your subscription, orders from our shop, delivery addresses, invoices and payment records. We never see or store your full card number; that stays with our payment provider.
• Employer-provided access — if your employer buys you a seat, we hold the fact of your seat, your invitation, your membership of their organisation, and your learning activity under that seat.
• Enquiries — what you send us through our contact, corporate enquiry and newsletter forms.
• Technical information — your IP address, browser and device type, and how you move through the site.

4. Your financial answers are treated differently

Questions about debt, missed payments, credit bureau listings, garnishee orders and debt counselling are sensitive personal information. Both Botswana and South African law treat them that way, and so do we.

Answering them is entirely voluntary. You can skip the survey and still use the platform — skipping does not limit your access to courses or your subscription. We ask because the answers let us point you at the right material rather than generic content, and we process them on the basis of your explicit consent, which you can withdraw at any time.

We do not sell this information. We do not use it for advertising. We do not pass it to credit bureaux, lenders, insurers or debt collectors.

If your employer paid for your seat, this is the part that matters most. Your employer never sees your individual answers — not your debt position, not your credit record, not anything you tell us about your finances. Your name is never attached to a financial answer we give them.

What an employer can receive is twofold. First, your participation: that you hold a seat, which courses you have taken and how far you have got. That is shown with your name, and it is what they are paying for. Second, statistics about their workforce as a whole — for example that a given percentage of staff are behind on repayments — with no names and no individual answers.

Those statistics are only produced for groups of at least 10 people who have completed the analysis, and any single question answered by fewer than 10 is withheld entirely. Below that size, a percentage starts to identify the person behind it. Where we hold an individual financial report, it is used inside Masheleng only, by the staff supporting you.

5. Why we use your information, and on what legal basis

We use your information only for the purposes below:

• To run your account and give you access to what you have paid for — because we need to in order to perform our contract with you.
• To take payment, issue invoices and handle refunds — to perform our contract and to meet our tax and accounting obligations.
• To personalise what we recommend, based on your financial wellbeing profile — with your explicit consent.
• To send you service messages such as password resets, receipts and course updates — to perform our contract.
• To send you marketing and newsletters — with your consent, which you can withdraw at any time using the unsubscribe link or your notification settings.
• To show prices in the right currency, by looking up the country your IP address is in — our legitimate interest in showing you a price you can act on.
• To keep the platform secure, prevent fraud and investigate misuse — our legitimate interest in protecting our members and our business.
• To meet legal obligations and to establish or defend legal claims.

6. Cookies

We use very few cookies, and none of them track you across other websites.

The cookies we set are:

• masheleng_token and masheleng_refresh_token — these keep you signed in. Without them you would have to log in on every page.
• mi_currency — remembers whether to show you Pula or Rand, so we do not have to look up your location on every visit.

We do not run advertising cookies, analytics cookies, or third-party tracking pixels on either site. You can block cookies in your browser, but you will not be able to stay signed in to the portal.

7. Who we share your information with

We do not sell your personal information to anyone, for any purpose.

We share it only with the following, and only as far as each needs it:

• Paystack — our payment provider, which processes card payments and holds your card details. Paystack operates from South Africa.
• Resend — sends our transactional emails, such as receipts, password resets and verification messages.
• Our hosting and storage providers — which run our servers, database and file storage.
• ipwho.is — receives your IP address when we look up your country to decide which currency to show you. It does not receive your name, email or any account information.
• Your employer — if it bought you a seat: your participation and course progress by name, and anonymous workforce statistics for groups of at least 10. Never your individual financial answers.
• Our professional advisers — such as auditors and lawyers, where they are bound by confidentiality.
• Regulators, courts or law enforcement — where we are legally required to disclose.

8. Sending information outside Botswana

Some of the services above operate outside Botswana, chiefly in South Africa. In particular, because our payment provider settles in South African Rand, payment information relating to Botswana members is processed in South Africa.

Botswana law restricts sending personal information abroad unless the destination country offers adequate protection. South Africa is among the countries recognised for this purpose, and South Africa has its own data protection law in POPIA. Where we use a provider elsewhere, we satisfy ourselves that the information is adequately protected and remains subject to this policy.

9. How long we keep it

We do not keep information indefinitely just because we can:

• Account and learning records — for as long as your account is open, and for two years afterwards so you can return without losing your progress and certificates.
• Your financial wellbeing profile — until you withdraw consent or delete your account, whichever is first. Withdraw consent and we delete the answers.
• Payment, invoice and order records — for seven years, because tax and company law requires us to keep them.
• Contact and enquiry messages — for two years.
• Marketing consents — until you unsubscribe, plus a record of the unsubscribe so we do not contact you again by mistake.

10. How we protect it

The measures we take include:

• Encryption in transit across both sites and our API.
• Passwords stored as one-way hashes, never in a form we can read.
• Identity numbers encrypted in our database.
• Access limited to staff who need it for their work.
• Card details never stored on our systems — they stay with our payment provider.

No system is completely secure, and we will not claim otherwise. If a breach occurs that is likely to put your rights at risk, we will notify the Information and Data Protection Commission within 72 hours as the law requires, and we will tell you.

11. Your rights

Under both Botswana and South African law you have the right to:

• Ask what personal information we hold about you, and get a copy.
• Have inaccurate or incomplete information corrected.
• Ask us to delete your information, where we are not legally required to keep it.
• Object to how we are using your information, including for direct marketing, which you can stop at any time.
• Withdraw a consent you previously gave, including your consent to the financial wellbeing questions.
• Ask us to restrict what we do with your information while a dispute is resolved.
• Receive your information in a portable form, or ask us to send it to someone else.
• Not be subject to a decision with legal or similarly significant effects made purely by automated means.

Exercising these rights is free, and we will not treat you differently for it.

12. How to contact us, and how to complain

For anything in this policy, including to exercise any of the rights above, write to mashelengtv@gmail.com, or to Plot 49, Unit 4, Commerce Park, Gaborone, Botswana. We will respond within 30 days.

If you are not satisfied with how we have handled it, you can complain to your regulator. In Botswana that is the Information and Data Protection Commission. In South Africa it is the Information Regulator (South Africa). You do not have to come to us first, but we would rather have the chance to put it right.

13. Children

Our services are intended for adults. You must be 18 or older to hold an account. We do not knowingly collect information from children, and if we discover that we have, we will delete it. If you believe a child has given us their information, please contact us.

14. Changes to this policy

We may update this policy as our services change or as the law does. The effective date at the top always reflects the current version. Where a change materially affects your rights or how we use your information, we will tell you directly rather than rely on you noticing.