Version no: 1 | Last updated: March 2022
Authorised by: Timothy Musoke, CEO, Laboremus Uganda Ltd.
1.1. Laboremus understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website. We do not collect personal data about you unless you contact us. Any personal data we do collect will only be used as permitted by law.
1.4. The use of our website is possible without any indication of personal data, although data processing may occur once a user goes forward to use specific services offered on the website thus disclosing certain data. If data processing is necessary, we generally obtain consent from the data subject. This shall be in compliance with the DataProtection and Privacy Act, 2019.
1.5. Although we have taken every prudent step to ensure that data is processed fairly and transparently, there are may be data that is transferred to us through alternative means such as by telephone calls and the user takes personal responsibility to ensure transferred data safety.
2.1. Processor for the purposes of the Data Protection and Privacy Act, 2019 is Laboremus Uganda Limited of Phone number: +256 751 069 277 and email of the Data Protection Officer: firstname.lastname@example.org or email@example.com
4.1. Laboremus website collects a series of general data and information when a data subject or automated system calls up the website.
4.2. This general data and information are stored in the server log files.
4.3. The processed data includes:
4.3.1. the person’s name;
4.3.4. identity document number;
4.3.5. personal code (if it is issued);
4.3.6. number (i.e., national identification number) (if it is issued);
4.3.7. birth date;
4.3.8. identity document expiry date;
4.3.9. identity document issued date ((if it is issued);
4.3.10. identity document photograph(s);
4.3.11. face photograph(s);
4.3.13. client id;
4.3.14. identification date and method;
4.3.15. IP address;
4.3.16. device fingerprint (“user agent”).
4.4. Processed information is needed to;
4.4.1. deliver the content of our website correctly;
4.4.2. optimize the content of our website as well as its advertisement;
4.4.3. ensure the long-term viability of our information technology systems and website technology, and
4.4.4. provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack;
4.4.5. provide products and services for our clients and fulfill the agreement conditions between the Parties.
5.1. In furtherance to the processing of data in clause 4 above, we use your data for the necessary performance of a contract with you and because you have consented to the use of your personal data or because it is in our legitimate business interests to use it. Your personal data may also be used for the following purposes;
5.1.1. Providing and managing your account;
5.1.2. Providing and managing access to our site;
5.1.3. Personalizing and tailoring your experience on our site;
5.1.4. Supplying our services to you. Your personal details are required in order for us to enter into a contact with you;
5.1.5. We may also use your personal data for marketing purposes, which may include contacting you one mail, telephone, text message, or any other means, with information, news, and offers on services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection and Privacy Act, 2019, and you will always have the opportunity to opt out.
6.1. Identify you;
6.2. Locate you;
6.3. Improve the service such as saving common destinations;
6.4. Connect services like"send" and "share" with your contacts;
6.5. For product research and development;
6.6. To provide measurement and analytics;
6.7. Communicate with you (share marketing communications on our products);
6.8. Generally, improve your user experience
7.1. Laboremus stores data until retention only in Uganda.
7.2. In some extra cases data can be sent outside Uganda to countries with equivalent data protection safeguards as Uganda.
8.1. The data subject has the possibility to register on the website of the controller with an indication of personal data. Personal data is transmitted to the controller by the respective input mask used for the registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller, and for their own purposes. The controller may request transfer to one or more processors that also uses personal data for an internal purpose which is attributable to the controller.
8.2. By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses.
8.3. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal investigations.
8.4. The registration of the data subject with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
8.5. Laboremus acts as a Data Processor when dealing with website visitors’ collected data. Laboremus as a Data processor will cooperate with Data Controller to ensure that the data controller at any time could provide information upon request to each data subject as to what personal data are stored about the data subject.
9.1. The website of Laboremus contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general e-mail address. If Laboremus as a Data processor receives a request from the Data Subject, the obligation of Laboremus is to transfer such a request to be considered.
10.1. We may disclose or share your Personal Information with third parties which include our affiliates, employees, officers, service providers, agents, suppliers, subcontractors as may be reasonably necessary for the purposes set out in this policy.
10.2. We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process or enforceable governmental request, enforce applicable Terms of Service, including investigation of potential violations thereof, detect, prevent, or otherwise address fraud, security or technical issues, or protect against imminent harm to the rights, property or safety of Laboremus, its users or the public as required or permitted by law.
11.1. The data processor shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as is permitted under the Data Protection and Privacy Act, 2019.
11.2. If the storage purpose is not applicable, or if a storage period prescribed by the Data Protection andPrivacy Act, 2019 or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
12.1. Be accountable to the data subject for data controlled, processed, held or used;
12.2. Collection and processing of data fairly and lawfully;
12.3. Collection, processing use or holding data adequately relevant and not excessive or unnecessary personal data;
12.4. Retain personal data for the period authorized by law for which data is required;
12.5. Ensure quality of information collected, processed or held;
12.6. Ensure transparency of the personal data collected, processed, used or held;
12.7. To observe security safeguards in respect of that data.
13.1. Right of confirmation. Each data subject shall have the right granted under the Data Protection and Privacy Act, 2019 to obtain from Laboremus as the controller the confirmation as to whether or not personal data concerning them is processed. If a data subject wishes to avail themselves of this right of confirmation, they may at any time contact Laboremus at the address provided in this policy.
13.2. Right of access. Each data subject shall have the right granted by Ugandan law to obtain from the controller free information about their personal data stored at any time and a copy of this information. Furthermore, the Data Protection and Privacy Act, 2019 provides that a data subject may have access to the following information:
13.2.1. confirmation of whether Laboremus holds personal data about the data subject;
13.2.2. a brief description of personal data held by data controller;
13.2.3. provide the identity of at hird party or category of a third party who has had access to the information;
13.2.4. Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer;
13.2.5. If a data subject wishes to avail themselves of this right of access, they may, at any time, contact theData Protection Officer and Laboremus as Data Processor will act accordingly with all known information.
13.3. Right to rectification. Each data subject shall have the right under the Data Protection and PrivacyAct, 2019, to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them.
13.4. Right to erasure (Right to be forgotten). Each data subject shall have the right granted under the Data Protection andPrivacy Act, 2019 to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller shall have the obligation to erase personal data without undue delay where the personal data is no longer necessary in relation to the purposes for which it is collected or otherwise processed.
13.4.1. The right to erasure also arises where the data subject withdraws consent to which the processing is based according to the Data Protection and Privacy Act, 2019.
13.4.2. A data subject who wishes to request the erasure of personal data stored by Laboremus as explained in this clause may at any time contact the Personal Data Protection Officer to ensure that the erasure request is complied with within a reasonable time.
13.5. Right of restriction of processing. Each data subject shall have the right granted under the Data Protection and Privacy Act, 2019 to obtain from the controller restriction of processing where one of the following applies:
13.5.1. The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
13.5.2. The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead of the restriction of their use instead;
13.5.3. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
13.5.4. If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Laboremus, they may at any time contact the Data Protection Officer to arrange the restriction of the processing.
13.6. Right to object– Each data subject shall have the right to object, on grounds relating to their particular situation, at any time, to processing of personal data concerning them.
13.6.1. Laboremus shall no longer process the personal data in the event of the objection, unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.
14.1. Should Laboremus process personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Laboremus processing for direct marketing purposes, Laboremus shall no longer process the personal data for these purposes.
14.2. Automated individual decision-making, including profiling – Each data subject may have the right granted by the Data Protection and Privacy Act, 2019 to, upon a notice in writing in data controller for any decision taken by and on behalf of the data controller which significantly affects the data subject is not based solely on the processing by automatic means of personal data in respect of that data subject.
14.3. Right to withdraw data protection consent – Each data subject shall have the right granted by the Data Protection and Privacy Act, 2019 to withdraw their consent to the processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw their consent, they may at anytime, contact the Data Protection officer at Laboremus Uganda.
15.1. The Data Protection and Privacy Act, 2019 serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the activities as communicated by Laboremus to the data subject, then the processing is based on the Data Protection and Privacy Act, 2019.
15.2. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services.
16.1. The criteria used to determine the period of storage of personal data is the respective statutory retention period for the respective personal data collected. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
16.2. The Data Protection Officer is the existing Legal Officer at Laboremus Uganda.