Privacy Policy

01 Who We Are

The data controller responsible for your personal information is:

Dr Precious Serero, as the Medical Director and Founder, is the responsible person for data protection matters at Phemo Aesthetics. Any questions or requests relating to your personal data should be directed to the contact details above.

02 What Information We Collect

We collect personal information in the following categories:

Contact and identity information

• Full name
• Phone number
• Email address
• Physical address (where relevant)

Booking and appointment information

• Appointment dates, times and treatment type
• Booking history and appointment notes
• Cancellation and rescheduling records

Medical and health information

• Relevant medical history and current medications
• Known allergies and contraindications
• Skin type, skin concerns and aesthetic goals
• Treatment records, clinical notes and outcomes
• Before and after photographs (where consent is given)

Financial information

• Payment records and transaction history
• Deposit and refund records

Website and communication information

• Enquiries submitted through our website contact form
• Email and WhatsApp communications
• Basic website usage data (pages visited, browser type)

03 How We Collect Your Information

We collect your personal information through the following channels:

• In-clinic consultations — when you complete intake forms or speak with our clinical team
• Our website — when you submit an enquiry or booking request via phemo.co.bw
• Fresha booking platform — when you book an appointment online via our Fresha profile
• Telephone and WhatsApp — when you contact us directly
• Email correspondence — when you communicate with us via email
• Referrals — when another professional or client refers you to our clinic

We will always be transparent about why we are collecting your information at the point of collection.

04 Why We Use Your Information

We use your personal information for the following lawful purposes:

To provide medical aesthetic care

• Conducting pre-treatment consultations and skin assessments
• Administering treatments safely and effectively
• Maintaining accurate clinical records
• Following up on treatment outcomes and aftercare

To manage your bookings and appointments

• Confirming, rescheduling or cancelling appointments
• Sending appointment reminders
• Processing deposits and payments

To communicate with you

• Responding to enquiries submitted through our website or other channels
• Sending information about treatments relevant to your care
• Notifying you of clinic updates, changes to hours or policies

To comply with legal and regulatory obligations

• Maintaining medical records as required by applicable health regulations
• Complying with the Botswana Data Protection Act
• Responding to lawful requests from regulatory or government authorities

To improve our services

• Analysing appointment patterns and client feedback to improve clinic operations
• Understanding which treatments are most in demand

05 Legal Basis for Processing

Under the Botswana Data Protection Act, we process your personal data on the following lawful bases:

• Consent — where you have given us explicit consent to process your data, including special category health information for the purpose of treatment
• Contract — where processing is necessary to fulfil the agreement between you and Phemo Aesthetics for the provision of services
• Legal obligation — where we are required to process your data to comply with applicable law or regulation
• Legitimate interests — where we have a legitimate business reason to process your data that does not override your rights and interests, such as responding to your enquiries or improving our services
• Vital interests — in rare circumstances where processing is necessary to protect your health or safety

06 How We Store and Protect Your Information

The security of your personal information is a priority for Phemo Aesthetics. We take the following measures to protect your data:

• Client records and clinical notes are stored securely and accessible only to authorised clinical staff
• Digital records are protected by password access controls
• Paper records, where used, are stored in locked physical storage
• All staff are trained on data confidentiality and their obligations under the Data Protection Act
• Our website uses HTTPS encryption to protect information submitted online
• Third-party platforms we use (such as Fresha) maintain their own security standards and privacy protections

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant authorities and, where required, inform affected individuals without undue delay.

07 How Long We Keep Your Information

We retain your personal information for as long as is necessary for the purposes for which it was collected, and in line with our legal obligations:

• Medical and clinical records — retained for a minimum of 6 years from the date of last treatment, or longer where required by applicable health regulations
• Booking and appointment records — retained for 3 years for administrative and financial record-keeping purposes
• Enquiry and communication records — retained for 12 months from the date of last contact where no appointment was made
• Financial records — retained for 5 years in line with applicable financial record-keeping requirements

Once your data is no longer required, it will be securely deleted or anonymised.

08 Sharing Your Information

Phemo Aesthetics does not sell, rent or trade your personal information. We may share your data only in the following limited circumstances:

• Referring professionals — with your explicit consent, where a referral to or from another medical professional is in your clinical interest
• Service providers — with trusted third-party platforms that assist us in operating our clinic, such as Fresha (booking management). These providers are contractually bound to handle your data securely and only for the purposes we specify
• Legal and regulatory requirements — where we are legally required to disclose information to government authorities, law enforcement or regulatory bodies
• Emergency situations — where disclosure is necessary to protect your vital interests or the safety of others

Any third parties with whom we share your data are required to maintain appropriate data protection standards consistent with the Botswana Data Protection Act.

09 Photography and Before & After Images

Phemo Aesthetics may take clinical photographs before and after treatment for the purposes of assessing treatment outcomes and maintaining accurate clinical records.

• Clinical photographs will only be taken with your explicit written consent
• You may decline photography without it affecting the quality of treatment you receive
• Where you consent to images being used for marketing or educational purposes (such as on our website or social media), this consent will be obtained separately and specifically
• You may withdraw consent for marketing use of your images at any time by contacting us at phemoaesthetics@gmail.com

10 Your Rights Under the Data Protection Act

The Botswana Data Protection Act gives you the following rights in relation to your personal information:

To exercise any of these rights, please contact us at phemoaesthetics@gmail.com or call +267 71 291 641. We will respond to all requests within 30 days.

If you are dissatisfied with how we handle your request or believe your data protection rights have been violated, you have the right to lodge a complaint with the relevant supervisory authority in Botswana.

11 Cookies and Website Data

Our website at phemo.co.bw may collect basic usage information such as which pages are visited and what browser is used. This information is used solely to improve the performance and user experience of the website and is not linked to individual identities.

We do not currently use tracking cookies or third-party advertising cookies. If this changes, this policy will be updated and you will be informed.

Third-party platforms linked from our website — such as Fresha and Google Maps — operate under their own privacy policies. We encourage you to review those policies separately.

12 Children's Privacy

Phemo Aesthetics does not knowingly collect personal information from individuals under the age of 18 without the consent of a parent or legal guardian. Where treatment is provided to a minor with parental or guardian consent, the personal data of the minor and the consenting adult will be handled with the highest degree of care and confidentiality.

13 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements or the services we offer. The most current version will always be available on our website at phemo.co.bw/privacy.html.

We will notify existing clients of any material changes to this policy via email or a prominent notice on our website. The date at the top of this page indicates when the policy was last reviewed.