Introduction
Totya Platform (“we”, “us”, “our”) is committed to protecting and respecting your privacy, in compliance with Uganda’s Data Protection and Privacy Act, 2019. This privacy policy outlines how we collect, use, and protect your personal data when you interact with us via our website, email helpline, or social media. Totya Platform is a registered non-profit community-based organisation in Mpigi, Uganda, and acts as the data controller.
Personal Data that We Process
We collect personal data to provide and improve our services. The table below explains the types of data we collect and the legal basis for processing in accordance with the Uganda Data Protection and Privacy Act, 2019.
| Purpose | Data (Key Elements) | Basis |
|---|---|---|
| Enquiring about our organisation and its work | Name, email, message | Legitimate interests – Necessary for us to read and store your message to respond appropriately. |
| Subscribing to email updates about our work | Name, email | Consent – You have given active consent for email updates. |
| Making a donation | Name, email address, payment information | Legitimate interests – Necessary to fulfil your donation intent and provide a confirmation. |
| Website functionality | Website activity collected through cookies | Legitimate interests – Necessary for website functionality like remembering session details. |
Lawful Processing of Your Data
We process your personal data based on the following legal principles:
- Consent: Where you have given explicit consent, such as subscribing to newsletters or receiving marketing communications.
- Contractual necessity: Where processing is required to fulfil a contract with you (e.g., processing a donation).
- Legal obligation: When we are required by law to process your data (e.g., for taxation purposes).
- Legitimate interests: For purposes like responding to inquiries and ensuring website functionality.
How We Use Your Data
We will only use your data for purposes that align with the reason it was collected, as outlined above. Examples of data use include:
- Responding to your inquiries.
- Processing donations and providing confirmations.
- Sending you newsletters and updates if you have consented.
- Analyzing website activity for improvement.
Sharing Your Data
We will not share your data with third parties except in the following circumstances:
- You have given explicit consent.
- We are working with third-party service providers who process data on our behalf and are contractually obligated to comply with data protection laws.
- It is required by law, such as sharing information with regulators or law enforcement agencies.
When transferring data outside Uganda, we will ensure adequate safeguards are in place in compliance with the Act.
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes outlined in this policy or as required by law. Data collected based on your consent will be retained until you withdraw that consent or after three years, whichever comes first. We regularly review our data retention policies to ensure compliance with Uganda’s Data Protection Act.
Your Rights Under Uganda’s Data Protection and Privacy Act
You have the following rights under Uganda’s Data Protection and Privacy Act:
- Right to Access: You may request a copy of the personal data we hold about you.
- Right to Rectification: You can request corrections to any inaccurate or incomplete data we hold about you.
- Right to Erasure: You can request that we delete your data, provided we are not legally required to retain it.
- Right to Restriction of Processing: You may request that we limit the processing of your data.
- Right to Object: You may object to the processing of your data in certain circumstances.
- Right to Data Portability: You can request that your data be provided to you in a format that allows it to be transferred to another organisation.
To exercise any of these rights, please contact us at info@totya.org. We will respond to your request within 30 days as required by law.
Data Security
We take data security seriously and implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorised access. This includes the use of encryption and secure storage solutions.
Cookies and Website Tracking
Our website uses cookies to improve user experience. Some cookies are necessary for website functionality, while others are used for anonymous tracking of website performance (e.g., Google Analytics). The information collected through cookies does not identify you personally. You can manage cookie settings in your browser.
Modifications to This Policy
We may update this policy to reflect changes in our practices or legal obligations. Any significant changes will be communicated through our website. If changes materially affect your rights, we will notify you directly if we have your contact information.
Complaints and Contact Information
If you believe we have violated your privacy rights, you have the right to lodge a complaint with Uganda’s Personal Data Protection Office (PDPO). You can also contact us directly for assistance.
For any questions or concerns about this policy, please contact us at:
- Email: info@totya.org
- Postal Address: P.O. Box 158, Mpigi, Uganda
- Phone: +256 200 90 4996