Two Nations Consulting Serices C.C has developed this Privacy Policy to explain how we may collect, retain, process, share and transfer your Personal Data when you visit our Sites or use our Services. This Privacy Policy applies to your Personal Data when you visit Sites or use Services, and does not apply to online websites or services that we do not own or control.

This Privacy Policy is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Sites and Services.

We have defined some terms that we use throughout the Privacy Policy. You can find the meaning of a capitalised term in the Definitions section.

Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Policy.

What Personal Data Do We Collect?

We do not seek to collect or otherwise Process your Sensitive Personal Information. Where we need to Process your Sensitive Personal Information for a legitimate purpose, we do so in accordance with applicable law. The Services are not intended for use by children.

We collect Personal Data about you when you visit our Sites or use our Services, including the following:

  • Registration and use information - When you register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfil the Services you request. Depending on the Services you choose, we may require you to provide us with your name and email address to establish an Account. We may require you to provide us with additional Personal Data as you use our Services.

  • Payment Information - When you sighup for a subscription, that information is directed to our third-party payment processors. We do not store your financial account information on our systems; however, we have access to, and may retain, subscriber information through our third-party payment processor.

  • Usage of our Services - When you use our Services, we may collect information about your engagement with and utilization of our Services, such as IP addresses, domain names, hostnames, processor and memory usage, storage capacity, navigation of our Services, and system-level metrics. We use this data to operate the Services, maintain and improve the performance and utilization of the Services, develop new features, protect the security and safety of our Services and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.

  • User Content - Our "Mailing list" feature allows you to publicly post content on our Services. By using our mailing lists, you agree that your profile information and the content you post may be viewed and used by other users and third parties we do not control.

  • Personal data that you choose to provide us to obtain additional Services or specific online Services - If you request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection, if the use of that Personal Data differs from the uses disclosed in this Privacy Policy.

  • Personal Data about you if you transact as a guest - Certain limited Services are available without being required to log in to or establish an Account, also referred to as Guest Transactions. We will collect Device Information and Technical Usage Data as necessary to provide the requested Guest Transactions.

  • Personal Data about you from third-party sources - We obtain information from third-party sources such as payment processors, merchants and data providers, where permitted by law.

  • Other information we collect related to your use of our Sites or Services - We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

Why Do We Retain Personal Data?

We retain Personal Data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal data in accordance with this Privacy Policy.

How Do We Process Personal Data?

We may Process your Personal Data for a variety of reasons that are justified under data protection laws in the European Economic Area (EEA) and Switzerland.

  • To operate the Sites and provide the Services, including to:

    • authenticate your access to an Account
    • provide, operate, and maintain our Services;
    • process your messaging transactions;
    • communicate with you about your Account, the Sites, the Services
    • create an account connection between your Account and a third-party account or platform
    • develop new products, services, features, and functionality;
  • To manage our business needs, such as monitoring, analysing, and improving the Services and the Sites performance and functionality.

  • To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.

  • To manage risk and protect the Sites, the Services, and helping to detect and prevent abuse of the Sites or Services.

  • For our legitimate interests, including to:

    • enforce the terms of our Sites and Services
    • manage our everyday business needs, such as monitoring and analysing
    • To respond to your requests, for example to contact you about a question you submitted to our customer support service.

Do We Share Personal Data?

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy. We may share your Personal Data or other information for the following reasons:

  • With other members of the Two Nations Consulting Serices C.C corporate family: We may share your Personal Data with members of the Two Nations Consulting Serices C.C family of entities to, among other things, provide the Services you have requested or authorised; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of Two Nations Consulting Serices C.C products, Services, and communications.

  • With the other parties to transactions when you use the Services, such as payment processors, merchants, and their service providers: We may share information with the other participants to your transactions, including payment processors, and merchants or their service providers when you purchase subscriptions or use the Services. The information includes:

    • Personal Data necessary to facilitate the transaction;
    • Personal Data to help other participant(s) resolve disputes and detect and prevent fraud; and
    • Anonymous data and performance analytics to help merchants better understand the uses of our Services
  • With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for Two Nations Consulting Services C.C's business purposes or as permitted or required by law, including:

    • if we need to do so to comply with a law, legal process or regulations;
    • to provide, operate, and maintain our Services
    • to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to Two Nations Consulting Services C.C or Two Nations Consulting Services C.C's corporate family;
    • to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
    • if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
    • to protect the vital interests of a person;
    • to protect our property, Services and legal rights;
    • to facilitate a purchase or sale of all or part of Two Nations Consulting Services C.C's business;
    • to companies that we plan to merge with or be acquired by;
    • to support our audit, compliance, and corporate governance functions.

How Do We Work with Other Services and Platforms?

A significant benefit and innovation of Two Nations Consulting Services C.C's Services is that you can connect your Account with a third-party account or platform. For the purposes of this Privacy Policy, an "account connection" with such a third-party is a connection you authorise or enable between your Account and a non-Two Nations Consulting Services C.C's account, payment instrument, or platform that you lawfully control or own. When you authorise such a connection, Two Nations Consulting Services C.C and the third-party will exchange your Personal Data and other information directly. Examples of account connections include:

  • using your third-part account to make payments to us.
  • linking your Account to a social media account or social messaging service;
  • connecting your Account to a third-party data aggregation or financial services company, if you provide such company with your Account log-in credentials;

Information that we receive or share with a third-party based on an account connection will be used and disclosed in accordance with the third-party's privacy practices. Before authorising an account connection, you should review the privacy notice of any third-party that you authorised to have an account connection that will provide or gain access to your Personal Data as part of the account connection.

International transfers

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers.

The parties mentioned above may be established in jurisdictions other than your own and outside the European Economic Area and Switzerland. These countries do not always afford an equivalent level of privacy protection. We have taken specific steps, in accordance with EEA data protection law, to protect your Personal Data. In particular, for transfers of your Personal Data within Two Nations Consulting Services C.C related companies. Other transfers may be based on contractual protections. Please contact us for more information about this.

If you make transactions with parties outside the EEA or Switzerland or connect our Service with platforms, such as social media, outside the EEA or Switzerland, we are required to transfer your Personal Data with those parties in order to provide the requested Service to you.

How Do We Use Cookies and Tracking Technologies?

When you visit our Sites, use our Services, or visit a third-party website for which we provide online services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, "Cookies") to recognise you as a User and to customise your online experiences, the Services you use, and other online content; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.

What Privacy Choices Are Available To You?

You have choices when it comes to the privacy practices and communications described in this Privacy Policy. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services.

  • Choices Relating to Account Connections

    • If you authorise an account connection to a third-party account or platform, such as a payment processor, you may be able to manage your connection preferences from the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices you may have.
  • Choices Relating to Your Registration and Account Information

    • If you have an Account, you generally may review and edit Personal Data by contacting us. Contact us if you do not have an Account or if you have questions about your Account information or other Personal Data.
  • Choices Relating to the Personal Data We Collect

    • You may decline to provide Personal Data when it is requested by us, but certain Services or all of the Services may be unavailable to you.
  • Choices Relating to Cookies

    • You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options, but doing so may prevent you from using many of the core features and functions available on a Service or Site.
    • You may have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of a Site. For example, you may be asked if you want the Service or Site to "remember" certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.
  • Notices, Alerts and Updates from Us:

    • Marketing: We may send you marketing content about our Sites, Services, products, products we jointly offer with partners, as well as the products and services of unaffiliated third parties through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications we send by following the instructions in the communications you receive. If you have an Account with us, you may also adjust your communication preferences in your Account settings. For messages sent via push notifications, you may manage your preferences in your device.
    • Informational and Other: We will send communications to you that are required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.

What Are Your Rights?

Subject to limitations set out in EEA data protection laws, you have certain rights in respect of your Personal Data. In particular, you have a right of access, rectification, restriction, opposition, erasure and data portability. Please contact us if you wish to exercise these rights. If you wish to complete an access request to all personal data that Two Nations Consulting Services C.C holds on you, please note that photo identity will be required to prove your identity.

If you have an Account with any of our Services, you generally can review and edit Personal Data in the Account by logging in and updating the information directly or by contacting us.

If you are a resident of the EEA, you have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

How Do We Protect Your Personal Data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorisation controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorised.

Can Children Use Our Services?

The Sites and Services are not directed to children under the age of majority. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of majority, we will promptly delete it, unless we are legally obligated to retain such data.

What Else Should You Know?

Changes to this Privacy Policy.

We may revise this Privacy Policy from time to time to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Policy will be effective as of the published effective date.

If the revised version includes a substantial change, we will notify Users of the change using email or other means.

Contact Us

You may contact us if you have general questions or concerns about this Privacy Policy and supplemental notices or the way in which we handle your Personal Data.

Our Data Protection Officer can be contacted at Two Nations Consulting Services C.C P.O Box 1037 Strubens Valley Gauteng 1735 South Africa dpo@tncs.io.

The data controller of your personal information is Two Nations Consulting Services C.C.


  • Account means a Baruwa Enterprise Edition or Baruwa Hosted Edition subscription account.

  • Device Information means data that can be automatically collected from any device used to access the Site or Services. Such information may include, but is not limited to, your device type; your device's network connections; your device's name; your device IP address; information about you're your device's web browser and internet connection you use to access the Site or Services.

  • Guest Transaction means a person's Use of the Services without logging into and/or establishing an Account.

  • Baruwa means Two Nations Consulting Services C.C. and subsidiaries or affiliates. In this Privacy Policy, Baruwa is sometimes referred to as "we", "us", or "our", depending on the context.

  • Personal Data means information that can be associated with an identified or directly or indirectly identifiable natural person. "Personal Data" can include, but is not limited to, name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver's license number, national ID, passport number).

  • Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

  • Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by Baruwa with an Account or Guest Transaction.

  • Sites means the websites, mobile apps, official social media platforms, or other online properties through which Baruwa offers the Services and which has posted or linked to this Privacy Policy.

  • Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Sites or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies. This may include IP address, email address, hostnames for email processed by our services and products.

  • User means an individual who uses the Services or accesses the Sites and has established a relationship with Baruwa (for example, by purchasing a service, subscription or product) or otherwise uses the Services as a sender or reciepient of messaging processed by our services or products or other type of participant to a transaction, including a Guest Transaction.