Privacy notice
Collegene, at collegene.app and cic.collegene.app
1. About this notice
Collegene is a student information platform. Colleges use it to run applications, admissions, enrolment and student records. Cyber Intelligence College (CIC) is the first college to use it, at cic.collegene.app.
This notice explains what personal data is collected through Collegene, who is responsible for it, and the rights you have. It is written to meet the requirements of Botswana's Data Protection Act, 2024 (Act No. 18 of 2024), which came into force on 14 January 2025.
2. Who is responsible for your data
Two roles matter here.
The controller decides why and how your personal data is used, and answers to you for it.
The processor handles personal data on the controller's behalf and only on its instructions.
If you are a CIC applicant, student or member of staff, CIC is the controller of your personal data. Collegene is CIC's processor. It provides and runs the system that holds your records, but CIC decides how your data is used. Questions and requests about your data go to CIC.
- Cyber Intelligence College, Oodi, Botswana, hosted at Oodi College of Applied Arts and Technology (OCAAT)
- Email: admissions@cic.ac.bw
If you use collegene.app outside a CIC context, for example by visiting the main site or using a demonstration, you can contact CIC at admissions@cic.ac.bw with any question about your data.
3. What we collect
When you sign in
You can sign in with Google, Microsoft, Apple, Facebook, a passkey or your email address. If you use Google, Microsoft, Apple or Facebook, the platform receives only your name, your email address and basic profile details from that provider. It does not receive your password for that account, your contacts or your posts. A passkey stays on your device and no personal details come from a third party.
When you apply or study at CIC
CIC collects the information it needs to run admissions and your studies. This includes your contact details, the details in your application, and the records CIC keeps while you study. This notice is linked from the footer of the public pages and the sign-in page.
The assistant
Collegene can include an assistant that answers questions. It is used only where the college switches it on, and it is not switched on yet. Once it is on, it will keep a record of your conversation:
- for 6 months, if you are signed in; and
- for 30 days, if you are not signed in.
After that, the conversation will be deleted.
Technical data
When you use the platform, technical data such as your IP address, browser type and the pages you request is processed so that the service can work and stay secure.
4. Automated assistance and human decisions
Collegene can use automated tools, including AI, to help staff. These tools are used only where the college switches them on, and they are not switched on yet. Once they are on, they may, for example, sort documents, check an application is complete, or draft a recommendation.
People make every consequential admissions decision, such as whether to make an offer. An AI tool may prepare work, but it acts only under a named member of staff's approval, and that person makes the decision.
The Act gives you the right not to be subject to a decision based solely on automated processing, including profiling, that has legal effects for you or significantly affects you (section 49). Collegene is designed so that admissions decisions are not made that way.
If you do not want automated tools used on your application, tell CIC at admissions@cic.ac.bw.
5. Why your data is used and the lawful basis
The Act allows personal data to be used only where a lawful basis applies (section 26). For CIC applicants, students and staff, CIC relies on the following.
| Purpose | Lawful basis |
|---|---|
| Considering your application, at your request | Steps taken at your request before entering into a contract |
| Running your studies, fees and records once you enrol | Performance of a contract with you |
| Keeping records the law requires | Compliance with a legal obligation |
| Keeping the platform secure and working, and answering assistant questions once the assistant is switched on | Legitimate interests |
| Sensitive information you choose to give, such as disability or support needs | Your explicit consent, or another condition the Act allows (section 30) |
Where we rely on your consent, you can withdraw it at any time. This does not affect anything done lawfully before you withdrew it (section 28).
Your data is not sold.
6. Who can see your data
- Authorised CIC staff, according to their role.
- Collegene, as CIC's processor, only to provide, secure and support the platform.
- Service providers who host and run the platform for Collegene (section 7).
- Regulators, courts or law enforcement, where the law requires it.
7. Service providers and where your data is stored
The platform is hosted on Vercel. Its database is provided by Supabase and is located in the London region (eu-west-2), in the United Kingdom. Vercel may also process data outside Botswana.
8. Transfers outside Botswana
Storing data in London is a transfer of personal data outside Botswana. The Act sets rules for such transfers (Part XIV, sections 74 to 78).
- A transfer may rely on a decision by the Information and Data Protection Commission that the receiving country gives adequate protection (section 75).
- Without such a decision, a transfer needs appropriate safeguards (section 76) or must fall within a specific situation the Act lists (section 78).
- The Act also says a copy of transferred personal data must remain in Botswana for the period of processing (section 74).
9. How long data is kept
| Data | Period |
|---|---|
| Assistant conversations, signed in (once the assistant is switched on) | 6 months |
| Assistant conversations, not signed in (once the assistant is switched on) | 30 days |
When a period ends, the data is deleted or made anonymous.
10. Security
The Act requires technical and organisational security measures appropriate to the risk (section 62). Collegene and CIC use such measures to protect personal data. The platform is designed so that each person sees only the records their role needs.
If a personal data breach is likely to put you at high risk, you will be told without undue delay (section 64).
11. Your rights
Under the Act you have the right to:
- be told how your data is used, which is the purpose of this notice;
- access your data and receive a copy (section 42);
- have inaccurate data corrected, and incomplete data completed (section 43);
- have your data erased in certain circumstances (section 44);
- restrict how your data is used in certain circumstances (section 45);
- data portability, meaning you can receive data you provided in a structured, machine-readable format where the Act allows (section 47);
- object to use based on legitimate interests or public interest, and to object at any time to direct marketing (section 48);
- not be subject to decisions based solely on automated processing with legal or similarly significant effects (section 49); and
- withdraw consent at any time, where consent is the basis (section 28).
How to use your rights
If you are a CIC applicant, student or member of staff, or you use collegene.app outside a CIC context, email admissions@cic.ac.bw.
You may be asked to confirm your identity. The Act requires a response within one month. That can be extended by up to two months for complex or numerous requests, with the Commission's approval, and you will be told of any extension, with reasons, within the first month (section 38). Using your rights is normally free.
To delete your account, see Data deletion.
12. Children and young people
Some applicants may be under 18. If you are under 18, please ask a parent or guardian to read this notice with you before you apply. Where the law requires it, a parent or guardian will be asked to give consent or to be involved.
13. Cookies
The platform uses cookies or similar technologies that are needed to keep you signed in and to keep the service secure.
It also uses one preference cookie, which is not strictly necessary:
| Cookie | What it does | How long it lasts |
|---|---|---|
| cg-mode | Remembers whether you chose the light or dark display. It holds only that choice and no personal data. It is set only when you use the Light mode or Dark mode button. | 1 year |
14. Complaints
If you have a concern, please contact CIC first, so that it can be put right.
You also have the right to complain to the Information and Data Protection Commission, Botswana's data protection regulator (section 80).
15. Changes to this notice
This notice will be updated when the platform or the law changes.