1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4    In this policy, “we”, “us” and “our” refer to The Real Uganda.

  1. Credit

This document was created using a template from SEQ Legal (https://seqlegal.com).

  1. How we use your personal data

3.1    In this Section 3 we have set out:

(a)    the general categories of personal data that we may process;

(b)    the purposes for which we may process personal data; and

(c)    the legal bases of the processing.

3.2    We may process data about your use of our website (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3    We may process your account data (i.e. inquiries about our volunteer programs) (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4    We may process your information included in your personal profile (i.e. application to volunteer) (“profile data“). The profile data may include your name, email address, interests and hobbies, education, and employment background. The profile data may be processed for the purposes of enabling your use of our services. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.5    We may process information that you post for publication on our website (i.e. testimonials or blog comments) (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website. The legal basis for this processing is consent.

3.6    We may process information contained in any enquiry you submit to us regarding our services (i.e. contact form use) (“inquiry data“). The inquiry data may be processed for the purposes of providing information about and offering our services to you. The legal basis for this processing is consent.

3.7    We may process information relating to our customer relationships, including customer contact information (email inquiry) (“customer relationship data“). The customer relationship data may include your name, your contact details, and information contained in communications between us. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with volunteers, communicating with volunteers, keeping records of those communications and promoting our volunteer programs. The legal basis for this processing is consent.

3.8    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications of our volunteer programs. The legal basis for this processing is consent.

3.9    We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.10  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our organization against risks.

  1. Providing your personal data to others

4.1    Financial transactions relating to our website and services are handled by our payment services providers, PayPal and PesaPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of invoicing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. We do not store your payment information.

4.2    Your inquiry data and notification data are stored with a third party email management company, namely Mail Chimp. Their privacy policy can be found here.

  1. International transfers of your personal data

We have offices and facilities in Uganda.  The hosting facilities for our website are situated in United States of America.The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers to Uganda will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

  1. Retaining and deleting personal data

6.1    We will retain your usage data for a maximum period of 14 months following your website visit.

6.2   In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. The period of retention of account, profile, publication, inquiry, customer relationship, and notification data will be determined based on our ongoing online communications.

  1. Amendments

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We will notify you of significant changes to this policy by email.

  1. Your rights

8.1    In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

  1. About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

  1. Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website. We use Google Analytics and Facebook Pixels to analyse the use of our website. Most browsers allow you to refuse to accept cookies and to delete cookies. If you block cookies, you will not be able to use all the features on our website.

  1. Our details

11.1  This website is owned and operated by The Real Uganda. We are registered in the Republic of Uganda under registration number S.5914/6232, and our registered office is at Plot 130, Jinja Road, Mukono, Uganda. Our principal place of business is at Ssemanda Road, Green Gate, Mukono, Uganda.

11.2  You can contact us by post, P.O. Box 637, Mukono, Uganda, using our website contact form, and by email, using [email protected]

  1. Data protection officer

Our data protection officer’s contact details are: Leslie Weighill, [email protected]

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