Captive Labs(PTY)LTD(Kalahari Fresh/ We/ Our/Us”) is a private company registered in Botswana, with its office at Unit 2, Plot 61053, Block 8 Industrial, Gaborone, Botswana. We operate the Kalahari Fresh mobile application (“App”) and the website (“Website”), [together referred to as the “Sites”]. Except as set in this Privacy Notice, we do not share, or sell, or disclose to a third party, any personal information collected at the Sites. We respect your privacy and will protect your personal information. Kalahari Fresh considers important and protects the privacy interests and personal information of visitors to and users of (“users/ you/ your”) the Sites. This Privacy Notice will help you understand our privacy practices and what Personal Information we collect, why we collect it and what we do with it. Please read this Privacy Notice carefully to understand our privacy practises and let us know if you have any questions by submitting a request through the “Contact Us” form on our Sites. This Privacy Notice should be read together with and as part of our Terms, which can also be found on the Sites. Words, phrases and expressions which are used in this Privacy Notice will have the meanings given to them in the Terms, unless it is stated otherwise.

Acceptance of Privacy Notice

By submitting your details or visiting or using the Sites you accept this Privacy Notice and updates thereto and expressly consent to the use and disclosure of your Personal Information in the way described herein. If you object to any of the potential uses described in this Privacy Notice please do not use or register on the Sites. We review our privacy policies regularly and occasionally may need to change or update them. The most current version of this Privacy Notice will always be posted under the Privacy Notice tab of the Sites and will be effective from the date of posting. You agree that you will check the Privacy Notice from time to time. By continuing to access and/or use the Sites after we make changes to this Privacy Notice, you agree to be bound by the revised Privacy notice. If you do not agree to the Privacy Notice from time to time, you should stop using the Sites.


Personal Information

Personal information is any information that identifies or relates specifically to you, including, for example, Your name, age and identity number, your contact address, your location, your banking details, your identification number and contact numbers. In short, any information that we know about you will be regarded as your personal information.


Collection of Personal Information

Personal Information may be collected by Kalahari Fresh or on behalf of Kalahari Fresh either from You, the documentation you provide to us or from information about you that is publicly available as well as from third parties from whom we are authorised by you or entitled by law to collect. We may combine Personal Information collected from all sources with other information in its possession for the purposes listed in this Privacy Notice. You understand and agree that when you register on and use our Sites you become a customer of Kalahari Fresh.

Personal Information collected

When you register and create or update your Account on the Sites, we require you to provide us with basic identification and contact information which includes but is not limited to your name and surname, email address, mobile number, login name and password, physical address, payment, credit card details or banking information, identification numbers, birth date and delivery information. Sometimes we may collect “special categories of Personal Information” about you with your explicit consent. This will include all information given to us in the course of your use of the Sites and Services and the purchase of Products, and any personal information you give us in your capacity as a user and our customer. We also collect Personal Information you provide us when you sign up for a marketing newsletter, complete a survey, enter a competition. Information you send to us by posting to a forum or blog or in your advertisement, is stored on our servers. We do not specifically use that information except to allow it to be read, but you will see in our Terms that we reserve a right to use it in any way we decide. Information required and given when you Contact us, including for customer support. We want to provide you with the best possible service, so calls to Kalahari Fresh will be recorded and/or monitored for quality checks and staff training. Recordings may also be used to help us combat fraud.

We collect the following information when you visit and use our Sites and Services:

  • Location information - depending on the Services that you use, and Your app settings or device permissions, we may collect your precise or approximate location information as determined through data such as GPS, IP address and WIFI.
  • Transaction information - We collect transaction details relating to your use of Our Sites and Services, Products purchased, (including the type of Services and Products you requested, date and time of the Service, and number of Products).
  • Usage and preference information - We collect information about how you interact with Our Sites, preferences expressed, and settings chosen. In some cases, we do this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers. For more information please see our Cookie Notice.
  • Device information - We may collect information about the devices you use to access and use Our Sites.
  • Log information – information about your interaction with and access to the Sites.
  • Information from referring websites/applications.
  • Information about how you use our or a third party’s services and products, such as the types of content you view or engage with, the type of product you buy, or the frequency and duration of your activities.

We receive and store certain types of Personal Information whenever you interact with us online. For example, we use cookies and tracking technologies (to find out more, see our Cookie Notice) to obtain Personal Information when your web browser accesses our Sites or advertisements and other content served by or on our on other websites. Your Personal Information is also collected when you search, buy, post, participate in a contest or questionnaire or communicate with our customer service teams. We track the Products you buy when you click on one of our display adverts and go on to purchase something from a selection of our Sellers. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes. When you send a message, we collect the data you have given to us in that message in order to obtain confirmation that you are entitled to receive the information and to provide to you the information you need. We record your request and our reply in order to increase the efficiency of our business / organisation.

We collect Personal Information from other sources including our trusted partnerships with third-parties and where we operate accounts on third-party platforms: For example, when you use the “like” functionality on Facebook or the +1 functionality on Google+.  We receive information about you and other visitors’ interactions with our advertising to measure whether our advertising is relevant and successful. We collect information about you and your activities from a third-party when we jointly offer services or products, or from third-party data analytics and enrichment providers who may deliver insights to us about the Personal Information we hold. We collect information from Sellers, Delivery Agents and payment processors, marketing service providers, third party business partners and relevant governmental departments.

What do we use your Personal Information for?

  • To provide you with the Services which you request.
  • To verify your identity for security purposes.
  • To market our Sites and Services, and the Products of third-party Sellers.
  • In other ways naturally associated with the circumstances in which you provided the information. For example, we may use your e-mail address to send you a confirmation notice.
  • To process your payments, if you purchase Products, to provide you with your order status, deal with your enquiries and requests, and assess and handle any complaints.
  • To facilitate delivery.
  • To process and answer your inquiries or to contact you to answer your questions and/or requests.
  • To develop and improve the products, services, communication methods and the functionality of our Sites.
  • For the purposes of competitions or promotions that you have entered.
  • To communicate information to you and to manage your registration on our Sites and/or subscription to our newsletter or other communications.
  • To manage our everyday business needs regarding your participation in our contests, or promotional activities.
  • To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise.
  • For internal training and quality assurance purposes.
  • To understand and assess the interests, wants, and changing needs of consumers, to improve our Sites, our Services, and/or developing new products and services.
  • To provide personalised Services, communications and targeted advertising as well as product recommendations to you.
  • If you have asked to receive emails or SMS communications from us, we track whether you open, read or click on the content to see what you are interested in so that we can give you more content that we think you are more likely to enjoy. We use this data to profile your likes and dislikes.
  • Based on this profile information, we may also give you advertising that we think you will like and want to see as you view content from us or from our network of publishers that we advertise with. Sometimes, with your consent, we may use your current location to serve advertising to you that is to do with promotions or events that are happening nearby that we think you might be interested in.
  • We may also use information you have provided to selected third-parties and consented to be shared, like your age, gender, life stage, lifestyle and wider interests to identify people who we think will have similar interests to you and who we believe will be interested in similar advertising.
  • Information we collect about your computer, which may at times be able to identify you, for any lawful business purpose, including without limitation to help diagnose problems with our servers, to gather broad demographic information and to otherwise administer our Sites.
  • Information which does not identify any individual may be used in a general way by us or third parties, to provide class information, for example relating to demographics or usage of a particular page or service.
  • Your domain name and e-mail address are recognised by our servers and the pages that you visit are recorded. We shall not under any circumstances, divulge your e-mail address to any person who is not identified in this Privacy Notice. This information is used:  to correspond with you or deal with you as you would expect; in a collective way not referable to any particular individual, for the purpose of quality control and improvement of our Sites; to send you news about the Services to which you have signed up; to tell you about other of our Services or services of related web sites.
  • You may opt-out from receiving future promotional information from us or our affiliated companies, or direct that we not share your information with any affiliated companies.
  • We may use, transfer and share aggregated, anonymous data about our users as a group for any business purpose, such as analysing usage trends and seeking compatible advertisers and partners.

Who will your Personal Information be shared with?

  • You agree that We may disclose Your personal information to the following persons:
  • to our employees and/or third party service providers, such as Sellers, Delivery Agents and payment processors (including their employees and/or third party service providers), to process use of the Services by You properly and efficiently and in order for them to interact directly with You via email or any other method for purposes of sending You marketing material regarding any current or new goods or services, new features, special offers or promotional items offered by them (unless you have opted out from receiving such marketing material);
  • to law enforcement, government officials, fraud detection agencies or other third parties when We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report or support the investigation into suspected illegal activity, or to investigate violations of the Terms;
  • to our service providers (under contract with us) who help with parts of our business operations (fraud prevention, marketing, technology services etc.). Our contracts dictate that these service providers may only use your Personal Information in connection with the services they perform for us and not for their own benefit;
  • to Sellers in order for them to liaise directly with you regarding any sale, complaint and/ or faulty Products you have purchased which requires their involvement;
  • to third party service providers for services such as payment processing, website hosting, data analysis, infrastructure provision, IT services, customer service, e-mail delivery services, and other similar services, to enable them to provide services;
  • to third parties which offer coupons for purchase of Products on the Sites;
  • to third parties’ sponsors of promotions (irrespective of whether such promotions are hosted by us), or otherwise in accordance with the rules applicable to such promotions. You should carefully review the rules, if any, of each promotion in which you choose to participate, as they may contain additional important information about our, a sponsor’s and/or other third parties’ use of your personal information;
  • to an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any insolvency and/or similar proceedings);
  • to the general public when you provide a rating or review of service received, you consent to us using that rating / review as we deem fit, including without limitation on the Sites, in newsletters or other marketing material. The name that will appear next to that review will be your first name, as you would have provided upon registration. We will not display your surname, nor any of your contact details, with a rating or a review;
  • to any person other than as described herein if we notify you and you consent to the sharing;
  • If you provide information to us with a view to it being read, copied, downloaded or used by other people, we accept no responsibility for what that third party may do with it. It is up to you to satisfy yourself about the privacy level of every person who might see your information. If it is available to all the World, you have no control whatever as to how it is used;
  • to assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money;
  • for re-marketing. This involves Facebook or some other supplier placing a tag or marker in order to be able to serve to you an advert for our Services when you visit some other website;

When we receive a complaint, we record all the information you have given to us. we use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. It is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person. When we obtain information from you specifically to enable you to buy a Product offered on our Sites by a Seller, we share your information with the Seller. Your Personal Information will also be used by us or shared with our sponsors, advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third-parties in connection with marketing, promotional, data enrichment and other offers, as well as product information, product development and development and expansion of our Services. Your Personal Information will be used by us or shared within our group of companies for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets, subsidiaries or business units. In such transactions, your Personal Information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice.  If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to our Sites and/ or Services, your Personal Information will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. In the event of insolvency, business rescue or reorganization proceedings being brought by or against us, all such Personal Information will be considered an asset of ours and as such it is possible, they will be sold or transferred to third-parties. We will ensure that all of our employees, Sellers, Delivery Agents, third party service providers, divisions, affiliates and third party business partners (including their employees and third party service providers) having access to your personal information are bound by appropriate and legally binding obligations in relation to the confidentiality and security of your Personal Information and are restricted in their processing thereof as per this Privacy Notice.

Financial information

We keep your financial information encrypted and stored on third party payment processor servers. We only store a token associated with those card details on our servers.  Access to your information is restricted to authorised staff only. If we ask you questions about your financial information, we shall show partial detail [the first four or the last four digits of the debit or credit card number, only enough to identify the card(s) to which we refer.

How long do we keep your Personal Information for

We keep information, which forms part of our business record for a minimum of six years. That is because we may need it in some way to support a claim or defence in court. That is also the period within which our tax collecting authorities may demand to know it. We may keep Personal Information for longer, but only if it is relevant and necessary.

What are your rights

You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Information and your rights. Therefore, we’re providing you with the information in this Privacy Notice. You may at all times choose to opt out of any marketing communication or newsletter. Every marketing communication sent to You will contain an “unsubscribe” link. Where You have elected to opt out of any direct marketing being sent to You by advising Us, such opt out will be recorded by Us and We will no longer send direct marketing to You. You may also always opt out of Push notifications from us by disallowing them on Your mobile phone settings. The right to lodge a complaint with a Regulatory Authority. You have the right to lodge a complaint directly with any local Regulatory Authority about how we process your Personal Information. The Sites are not directed to and/or intended for use by individuals under the age of eighteen (18), and We request that such individuals not use the Sites and not provide personal information through the Sites. Persons under the age of 18 are not allowed to register for the Service, or use the Sites in anyway.  If a user attempts to register and inputs a birthdate validating them younger than 18 years of age, their personal information is not stored and they are directed off the platform.

How We hold personal information securely

We will treat Your personal information as strictly confidential, save where we are entitled to share it as set out in this Privacy Notice. In all circumstances the information is held by us on our secure systems. We take all reasonable and appropriate technical and organisational steps to ensure that your personal information is kept secure and is protected against unauthorised or unlawful processing, misuse, unauthorised disclosure, loss, interference, destruction or damage, alteration, disclosure or access. Our security systems are in line with industry standards and We monitor developments to ensure that our security systems evolve, as required. We also test our systems regularly. Personal information is destroyed or anonymised when no longer needed or when we are no longer required by law to retain it (whichever is the later). We will promptly notify you if we become aware of any unauthorised use, disclosure or processing of your personal information. We may store your personal information with the web-hosting service provider appointed by us from time to time. The storage may be in Botswana, South Africa or in another country. Where storage is in another country, your personal information will be stored in a jurisdiction that has equivalent, or better, data protection legislation than Botswana or with a service provider which is subject to an agreement requiring it to observe data protection requirements equivalent to or better than those applicable in Botswana. Notwithstanding the above, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive information through email. If You have reason to believe that Your interaction with us is not secure (for example, if you feel that the security of any account you might have with us has been compromised), You must immediately notify Us of the problem by contacting us at

Disclaimer and Indemnity

Whilst we will do all things reasonably necessary to protect your rights of privacy, we cannot guarantee or accept any liability whatsoever for unauthorised or unlawful disclosures of your personal information, whilst in our possession, made by third parties who are not subject to our control, unless such disclosure is as a result of our gross negligence or non compliance with applicable laws. If you disclose your personal information to a third party, such as an entity which operates a website or mobile application linked to the Sites or anyone other than Kalahari Fresh, Kalahari Fresh SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE, HOWSOEVER ARISING, SUFFERED BY YOU AS A RESULT OF THE DISCLOSURE OF SUCH INFORMATION TO THE THIRD PARTY. This is because we do not regulate or control how that third party uses your personal information. You should always ensure that you read the Privacy Notice of any third party.


For more information contact us at