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Data Protection Statement

Version 1.0 · effective 8 October 2026 · Beta Clean (Pty) Ltd, Gaborone, Botswana

Contents
  1. 1. Purpose and scope
  2. 2. Roles
  3. 3. What we process for the Customer
  4. 4. Our commitments as processor
  5. 5. Security measures
  6. 6. Sub-processors and where data is held
  7. 7. Cross-border transfers
  8. 8. Personal data breaches
  9. 9. Helping with data subject requests
  10. 10. Retention, return and deletion
  11. 11. Audits and records
  12. 12. Contact, redress and changes

This statement sets out how Beta Clean (Pty) Ltd of Gaborone, Botswana, protects personal data that customers put on Stratum ESG, and the commitments it makes as their processor under the Botswana Data Protection Act, 2024 (Act No. 18 of 2024). Every user accepts it before using the platform.

1. Purpose and scope

1.1 This statement applies to personal data contained in Customer Data on Stratum ESG: ESG values, evidence, disclosures and reports that relate to identifiable people.

1.2 It forms part of the Terms and Conditions and works as the data processing agreement between Beta Clean and each Customer. How Beta Clean handles its own users' account data is covered by the separate Privacy Statement.

1.3 Words such as controller, processor, data subject, personal data, sensitive personal data and personal data breach have the meanings given in the Act.

2. Roles

For ESG data the Customer is the controller and Beta Clean is its processor. For the data Beta Clean needs to run its own business (accounts, billing, KYC, security logs) Beta Clean is the controller.

DataControllerProcessorCovered by
Customer Data: ESG values, evidence, disclosures, narratives, reportsCustomerBeta CleanThis statement
User accounts: name, email, role, sign-in and security dataBeta CleanSupabase, ResendPrivacy Statement
Customer and Partner KYC: company details, directors, beneficial owners, documentsBeta CleanSupabasePrivacy Statement
Billing: tokens, usage, invoices, paymentsBeta CleanSupabasePrivacy Statement
Audit logs and acceptance recordsBeta Clean (kept as evidence for both parties)SupabaseBoth

The Customer is responsible for having a lawful basis to put personal data on the platform, for telling its own employees and others what it does with their data, and for the instructions it gives through its use of the platform.

3. What we process for the Customer

Most ESG data is aggregate and not personal: litres of fuel, kWh, tonnes of waste. Personal data appears mainly in evidence documents and in social and governance metrics.

CategoryExamplesData subjects
Aggregate workforce figuresHeadcount by gender, injury rates, training hours, pay ratiosUsually none identifiable
Evidence documentsPayroll extracts, incident reports, invoices, meter readings with namesEmployees, contractors, suppliers
Governance disclosuresBoard members, committee members, executives' roles and remunerationDirectors and senior managers
Report contactsForeword author, report contact name and emailCustomer staff
Notes and commentsFree-text notes by contributors and reviewersCustomer staff, and anyone named in them

Purpose: solely to provide the platform to the Customer: storing, calculating, reviewing, reporting and exporting its ESG information.

Duration: for the term of the agreement, then the export and deletion periods in clause 10.

Sensitive personal data: the platform is not designed for health, biometric or other sensitive personal data about named individuals. The Customer should report such matters in aggregate and redact evidence where it can.

4. Our commitments as processor

As processor, Beta Clean will:

  1. Process Customer personal data only on the Customer's documented instructions, which are these terms and the Customer's use of the platform, and tell the Customer if it believes an instruction breaks the Act.
  2. Ensure everyone who can access it is bound by confidentiality.
  3. Apply the security measures in clause 5.
  4. Use sub-processors only as set out in clause 6.
  5. Transfer data outside Botswana only as set out in clause 7.
  6. Notify the Customer of personal data breaches as set out in clause 8.
  7. Help the Customer answer data subject requests (clause 9), and with data protection impact assessments and consultations with the Information and Data Protection Commission where they concern the platform.
  8. Return and delete data at the end of the service (clause 10).
  9. Make available the information needed to show compliance, and allow reasonable audits (clause 11).

Beta Clean will not sell Customer personal data, use it for its own purposes, or combine it with other data, except anonymised statistics that identify no one.

5. Security measures

Beta Clean applies technical and organisational measures suited to the risk, as the Act requires of controllers and processors.

AreaMeasures
Access controlEach Workspace is isolated in the database by row-level security; five roles; owners and admins can limit people by department to sections of the workspace and pillars of data, and contributors to sites; auditors see approved data only; partners see no ESG data
AuthenticationPasswords of at least 10 characters with breached-password checks; optional authenticator app; optional passkeys (fingerprint, face or device passcode, checked on the device, with only a public key stored); sessions expire after an hour without refresh
Document uploadsThree factors: sign-in, authenticator app or passkey, and a one-time email code valid 10 minutes
StoragePrivate storage; files served only through links valid for 60 seconds
EncryptionTLS for all traffic with HSTS; encryption at rest provided by the hosting provider
IntegrityTamper-evident SHA-256 hash chain over every change; immutable invoices and payments
SecretsAPI keys and one-time codes stored only as hashes; server keys never sent to browsers
Application securityStrict content security policy, no framing, no caching of private pages
MonitoringHealth checks; audit log of document views and downloads
PeoplePlatform administration limited to named Beta Clean staff; confidentiality duties
TestingAutomated tests of the access rules on every change

6. Sub-processors and where data is held

Beta Clean uses three sub-processors. Each is bound by written terms that protect the data at least as well as this statement.

Sub-processorServiceDataLocation
Supabase Inc.Database, authentication, file storage, scheduled jobsAll platform dataLondon, United Kingdom (AWS eu-west-2)
Vercel Inc.Application hostingData in transit while pages are served; no permanent storageLondon, United Kingdom (lhr1)
Resend, Inc.Email deliveryUser names and email addresses, email contentUnited States

Beta Clean will give Customers at least 30 days' notice of a new or replacement sub-processor by email and on the platform. A Customer may object on reasonable data protection grounds; if the parties cannot resolve the objection, the Customer may close its Workspace and receive a refund of unused purchased Tokens.

If Beta Clean moves hosting to Docker on its own or another provider's servers, it will update this list.

7. Cross-border transfers

Customer Data is hosted in the United Kingdom, so it leaves Botswana. The Act allows such transfers only where the destination gives adequate protection, as recognised by the Minister or authorised by the Information and Data Protection Commission, or where another lawful ground or safeguard applies.

Beta Clean transfers Customer personal data to the United Kingdom (hosting) and, for email delivery only, to the United States, and only on a ground the Act allows: to a country recognised as giving adequate protection, or with written contractual safeguards with each sub-processor and, where the Act requires it, the authorisation of the Information and Data Protection Commission.

Beta Clean will not transfer Customer personal data to any other country without updating this statement and giving notice under clause 6. A Customer that needs its data held in Botswana or South Africa may ask about a Galaxy workspace with a chosen hosting region.

8. Personal data breaches

Beta Clean will tell an affected Customer of a personal data breach without undue delay, and in any case within 48 hours of becoming aware of it, so the Customer can notify the Commission within the Act's 72 hours.

The notice will say, as far as then known:

  • what happened and when;
  • the categories and approximate number of people and records affected;
  • the likely consequences;
  • what Beta Clean has done and proposes to do to contain it and limit harm;
  • a contact for more information.

Beta Clean will add details as they become known, cooperate with the Customer's notifications to the Commission and to people at high risk, and keep a record of every breach. Where Beta Clean is itself the controller (clause 2), it notifies the Commission directly within 72 hours where the Act requires.

9. Helping with data subject requests

People whose data is in Customer Data may ask to access, correct or delete it, or object to its use. Those requests are the Customer's to decide.

  1. If Beta Clean receives such a request directly, it will pass it to the Customer within 5 business days and will not answer it itself unless the Customer asks.
  2. The platform lets the Customer find, export, correct and delete values, notes and evidence itself.
  3. Where the Customer cannot do something itself, Beta Clean will help on request, at no charge for reasonable requests.
  4. Approved data in a locked period and audit log entries are kept as records. A correction is made by reopening and amending, which leaves the history visible.

10. Retention, return and deletion

WhatKept forThen
Customer Data in an active WorkspaceAs long as the Customer keeps itCustomer may delete drafts and evidence at any time
Customer Data after the agreement ends30-day export windowDeleted from the live platform within 90 days; removed from backups as they expire
Audit log entriesLife of the Workspace, then 8 yearsDeleted
Invoices, payments, KYC records, acceptance records8 years after the year they relate to (Botswana tax and company law)Deleted
API request logs13 monthsDeleted automatically
One-time upload codesUntil used or expired (10 minutes); stored as hashesPurged

On request, Beta Clean will confirm deletion in writing.

11. Audits and records

11.1 Beta Clean keeps a record of its processing for each Customer, and of every personal data breach.

11.2 Customers can verify much of this themselves: the audit log shows every change and download in their Workspace and can be re-checked against its hash chain at any time.

11.3 Once a year, or after a breach, a Customer may audit Beta Clean's compliance with this statement, by questionnaire or, on 30 days' notice, through an independent auditor bound by confidentiality, at the Customer's cost. Beta Clean may meet the request with third-party certifications or reports of its sub-processors where they cover the point.

11.4 Beta Clean will cooperate with the Information and Data Protection Commission in the performance of its duties.

12. Contact, redress and changes

12.1 Data Protection Officer: Onkabetse Gwamulumba, Beta Clean (Pty) Ltd, Block 6, Gaborone, Botswana; P.O. Box 20327, Bontleng, Gaborone; +267 77402001; [email protected].

12.2 Redress. A Customer or data subject with a concern should first contact the Data Protection Officer, who will acknowledge it within 5 business days and respond within 30 days. Anyone may also complain to the Information and Data Protection Commission of Botswana in Gaborone, and may seek a remedy in the courts of Botswana sitting in Gaborone. Disputes between Beta Clean and a Customer are resolved as set out in clause 18 of the Terms and Conditions.

12.3 Changes: new versions are published with a version number and effective date, with 30 days' notice of material changes. Every user must accept the new version before continuing to use the platform.

12.4 Order of precedence: on personal data, this statement prevails over the Terms and Conditions.

Beta Clean (Pty) Ltd · Block 6, Gaborone · P.O. Box 20327, Bontleng, Gaborone · +267 77402001 · [email protected]