Data Protection & Privacy Policy

Purpose

1. 1.1

   This policy explains how we can collect, use, hold and disclose your personal information, as well as ensuring the quality, integrity and security of your personal information under applicable Privacy Laws.

2. 1.2

   As the data collector, processor and controller, Infigent Consulting Limited (“we”, “us”, “our”) recognises the importance of privacy and security and is committed to protecting and respecting your privacy and personal information.

3. 1.3

   This policy outlines how personal data we collect from you, or that you provide to us, will be handled by us.

4. 1.4

   Please read the following carefully to understand how your personal data will be treated.

5. 1.5

   The collection and processing of your personal data is in accordance with the Data Protection and Privacy Act 2019 (the “Act”) of Uganda, and any other laws or regulations passed pursuant to the said Act.

Technical definitions

The company adopts the definitions as they are contained in the Act.

What is personal information?

1. 3.1

   The Company has a general duty of confidentiality towards you, except in the following circumstances:

   1. 3.1.1

      where disclosure is compelled by a relevant regulation or law;

   2. 3.1.2

      where disclosure is made with your express or implied consent.

2. 3.2

   Personal information includes any information about an identified individual or an individual who can be reasonably identified from that information.

3. 3.3

   The information will still be personal information whether it is true or not and regardless of whether we have kept a record of it.

   1. 3.3.1

      Some examples of personal information may include your:

      • iName
      • iiMailing or residential address details
      • iiiContact details such as telephone numbers, email address and social media platform user name
      • ivGovernment issued identifiers such as National ID, Alien Card, Passport or Taxpayer Identification Number
      • vBank account and Mobile Money account details
      • viCredit history, credit capacity, ability to be provided with credit or credit worthiness
      • viiPhotograph, video or audio recording
      • viiiSensitive information such as information relating to your health and biometric data
      • ixYour location

Technical and other information

1. 4.1

   We may also collect technical information to help us improve our services from time to time while maintaining your anonymity. This is part of our core ambition to ensure we constantly provide top tier services to all our clients, detect security threats and for fraud analysis and prevention. Such technical information may include information about your device or computer such as operating system version, how your device or computer connects to our services, and your web browser settings.

2. 4.2

   This information may also be used or stored in combination with your personal information for these purposes, including to enable us to contact you if we detect any issues.

Use and disclosure

1. 5.1

   We may use your information to comply with legislative or regulatory requirements in any jurisdiction, prevent fraud, crime or other activity that may cause harm in relation to our products or services and help us run our business.

2. 5.2

   Based on your express or implied consent we may also disclose your personal information to anyone we engage to do something on our behalf, and other organisations that assist us with our business.

3. 5.3

   As a provider of consultancy services, we have legal obligations to disclose some personal information to government agencies and regulators or agencies authorised within applicable laws and regulations.

What kinds of personal information do we collect and hold?

1. 6.1

   The personal information that we collect about you will depend on the products or services that you apply for, or enquire about.

2. 6.2

   If you do not allow us to collect all of the personal information we reasonably request, we may not be able to deliver those products or services to you.

3. 6.3

   Throughout the life of your product or service, we may also collect and hold additional personal information about you.

   1. 6.3.1

      This could include transaction information or making a record of queries or complaints you make and, if you make an insurance claim, collecting additional information to assess the claim.

4. 6.4

   Our collection of ‘sensitive information’, being personal information under the Data Protection and Privacy Act 2019 of Uganda, is further restricted to circumstances where we have obtained your express consent and to certain other permitted situations.

5. 6.5

   Generally, we will only collect this information if it is reasonably necessary to provide you with a specific product or service and you expressly consent to our collection.

6. 6.6

   When we collect information we will disclose the specific purpose for which we use, request and store your personal information.

7. 6.7

   We will also keep a record of that personal information and the purpose for which we collected it.

8. 6.8

   We will not use your personal information for any other purpose, other than which we disclosed to you, unless you provide your express consent or unless we are permitted to do so by law.

9. 6.9

   We may collect information using cookies when you use our websites or social media pages. Cookies are small pieces of information stored on your hard drive or in memory.

   1. 6.9.1

      One of the reasons for using cookies is to offer you increased security.

   2. 6.9.2

      They can also record information about your visit to our website, allowing us to remember you the next time you visit and provide a more meaningful experience.

10. 6.10

    We may also collect information from third party websites, applications or platforms containing our interactive content or that interface with our own websites and applications.

How do we collect personal information?

1. 7.1

   We collect most personal information directly from you, whether in person, on the phone or electronically, in our online course environments and when using the AI licences we manage; for example, when you call us via phone or visit our social media pages or sites.

For what purposes do we collect, hold, use and disclose personal information?

1. 8.1

   The main reason we collect, use, hold and disclose personal information is to provide you with products and services (including, where applicable, third party products and services) and to help us run our business. This includes:

   • a)checking whether you are eligible for the product or service;
   • b)assisting you with customer care and support;
   • c)providing the product or service;
   • d)helping manage the product or service;
   • e)helping us develop insights and conduct data analysis to improve the delivery of products and services, enhance our customer relationships and effectively manage risks; and
   • f)understanding your interests and preferences so we can tailor digital content.
2. 8.2

   We may also make anonymous the personal information which we have collected for the purposes described in this Privacy Policy.

3. 8.3

   As a result, this Privacy Policy will generally not apply to our use of anonymous information. However, we will continue to safeguard this anonymous information.

4. 8.4

   Where we use anonymous information together with other information (including personal information) and in doing so we are able to identify you, that information will be treated as personal information in accordance with this Privacy Policy and applicable Privacy Laws.

5. 8.5

   We may use or disclose your information to comply with our legislative or regulatory requirements in any jurisdiction and to prevent fraud, criminal or other activity that may cause you, us or others harm, including in relation to products or services.

How do we hold and protect your personal information?

1. 9.1

   Much of the information we hold about you will be stored electronically in secure databases.

2. 9.2

   We store some of your information in secure data centres and with our contracted service providers (including cloud storage providers), and some of these data centres may be located outside Uganda.

3. 9.3

   We use a range of physical, electronic and other security measures to protect the security, confidentiality and integrity of the personal information we hold, such as end to end encryption and passwords.

4. 9.4

   If you have reason to believe that your interaction with us is no longer secure, for example if you feel that the security of any account you have with us has been compromised, please contact us immediately.

Who do we disclose your personal data to, and why?

1. 10.1

   We may share your personal data with our partners and third parties, including outsourced data processing undertaken on our behalf (some of which are located outside of Uganda), that we engage to provide products and services to you.

2. 10.2

   When information is shared, we require our service providers to keep such information under strict privacy regulations and prohibit them from disclosing such information to anyone for any other purpose.

3. 10.3

   We do not share or disclose any non-public personal information about you to any other companies except as permitted by or required by law or for the purpose of marketing their products to you.

4. 10.4

   By accepting these terms and conditions you are providing your explicit consent to share your information with these third party partners, some of which may be outside your local jurisdiction, if necessary for legitimate business purposes as defined in this policy.

Breach notification

1. 11.1

   In the event of a data security breach being identified, we will notify the relevant Regulatory Authority within seventy two (72) hours of becoming aware of the breach, and the data subject in writing within a reasonably practical period.

2. 11.2

   The company may from time to time issue disclaimer notices and statements at its premises to augment this policy and notification procedures.

Your data

12.1 Data retention

12.2 Rights to access and control your personal data

You can access your personal data from our services when you follow our procedures on data subject requests.

Data protection reporting

For any data protection issues you can contact our services team.