Privacy Policy

LABOREMUS PRIVACY STATEMENT

 FEBRUARY 2024

 Your privacy and trust are very important to us. This document explains how Laboremus Uganda Limited  (“We”) processes personal information about you. Processing covers any operation which is performed upon collected data by automated means or otherwise including collecting, storing sharing transferring, handling, and protecting the data. With this document information about your rights as a data subject and how you can contact us if you have questions about how we handle your information. Based on the specific Laboremus service you are using; we may furnish additional or distinct privacy statements or notifications to address the specific interactions you have with us. This is intended to emphasize how we handle your personal information in relation to those services. In such cases, clarity will be maintained regarding which statements are applicable to those interactions and services.

 SCOPE OF DOCUMENT

This document applies to data subjects and individuals who access, use and/or interact with our products, services, websites, digital properties, platforms, software, and applications including mobile applications, and those who attend our events. This document does not pertain to situations where we are serving as a processor or service provider managing personal information on behalf of a third party such that, in these instances, our processing of personal information is carried out according to their direction and instructions, and their privacy statement shall be the governing factor. Through our products and services might be third party websites and applications. However, we are not responsible for the content or privacy compliance of third-party websites or applications.

 PERSONAL DATA THAT WE PROCESS AND HOW WE USE IT

We process personal data about you as a data subject in the operation of business through our interactions with you, and through our products that include Streamline, or through other services we offer. You provide some of this data directly, while we might also process such personal data through collecting data about your interactions, use and experiences with our products through our customer support channels made known to you, or otherwise, for example through Cookies. See our Cookie Policy for more information.

 We might also process data that we have obtained through our systems and by use of our services; for example, through our servers, logs and any other technologies that automatically collect certain information from or about you and your systems for example User Identification or an Internet Protocol Address that help us administer, protect, and improve our products and services.

We might process personal information about you from third parties such as those arranging for you to access our Services, through partners and service providers who work with us or even through public domain sources that are available to the public and typically over the internet. However, where we obtain your personal data through a third party, such as those mentioned, such persons shall also be responsible for their own satisfaction of applicable data protection and privacy laws. We might collect personal data through cookies and other similar technologies included on our services. More information relating to cookies and how to control their use can be found in our Cookie Policy.

Otherwise, as a credit infrastructure entity providing Know-Your-Customer infrastructure we might also be using your information to help prevent and detect unlawful acts under local and applicable international laws such as money laundering, counterterrorism financing, fraud, or any other criminal activity. This would be in provision of services that we are contractually obliged by a third party and in their legitimate interests.

Especially regarding marketing events, where you give consent for example by signing up to receive promotional material or regular communications from us, we shall also use your personal data in order to provide you with such material.

Other scenarios we might use your personal data is to:

·   Communicate with you to provide important notices and updates, product changes and other necessary notices

·   To market our other services to you

·   Facilitate reporting and analyze performance of our products or features

·   Provide webinars or public presentations

·   To provide you with support by responding to your requests from information, help identify, and troubleshoot any issues with your use of our product or services

·   Resolve support requests

·   Provide you with reports about usage

 As a data subject you have the right to decline when we ask for personal data. However, in order to provide you with a service many of our products require some personal data. In the event that you choose not to provide data required to furnish you with a service, you cannot use that product or feature. Furthermore, where we need to collect personal data by law or to enter into or carry out a contract with you and you choose not to provide the data, we will not be able to enter into the contract; or if this related to an existing product you are using, we may have to cancel or suspend it. In he event of the latter, we shall notify you if this is the case at the time.

 TYPES OF DATA WE COLLECT FROM YOU

The type of data we collect usually depends on why we would need it. That is determined by how you are interacting with us, which products you are using and/or which services you are purchasing or using. Such information may include:

·   Name and contact data including names, email address, phone number and other similar data

·   Account credentials such as for the purpose of security and authentication

·   User content such as communications and files provided by you in your use of services

·   Usage information and browsing history such as information about how you navigate within our services, your browsing history, and which elements of our services you use the most.

·   Payment information in order to make any required payments

·   Identifiers such as unique identification numbers, cookie identifiers, national identifiers among others

·   Images and or photographs if you visit or work from our offices or attend an event that we sponsor or organize

 If you directly interact with our staff or authorized representatives, such as our sales, user research or user operation groups, or if you participate in research conducted by us, we may process the following information voluntarily provided by you:

·   Your requests, questions, and responses to us via forms or email

·   Social media information

·   Your date of birth

·   Geographic information such as region and country

·   Information to verify your identify

HOW WE MAY DISCLOSE YOUR INFORMATION

We may need to disclose the information we collect about you to make our products and services run smoothly and to operate our business under the following circumstances.

The entities that provide access to our services may have access to your personal information for the purpose of facilitating the use of our services. We also collaborate with business partners to deliver co-branded service, engage in product or service co-selling activities, and provide content or host events, conferences, and seminars.

Service providers and sub processors may use your information on our behalf to assist in providing our services, website, and features. Such third parties provide services that may include sales, marketing, analytics, research, data storage, security, among others.

Should our ownership of all or substantially all of our business changes, or all or some of our assets are sold as part of bankruptcy or other proceeding, we may transfer your information to the new owner so services can continue to operate. Nonetheless your information would remain subject to the promises and commitments contained in this statement until updated by the acquiring party.

Lastly, to comply in good faith with any lawful process expect that you shall be notified as in the method that may be applicable of that request from law enforcement unless we are prohibited from doing so by la or court order.

 STORAGE,TRANSFER, PROTECTION AND RETENTION OF YOUR INFORMATION

We take the prerequisite technical and organization al measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. While no method of internet transmission  or electronic/physical storage is absolutely secure and we cannot ensure or warrant the security of that information, we have in place mitigation measures that include constantly updating and improving our safeguards.

When you use our products and services information about you shall be stored in Uganda.

 We shall retain your information for the period necessary to fulfil the purposes outlined to you in this document, to make our products and services available to you unless a longer retention period is required or permitted by law.

 PERSONAL DATA RELATING TO CHILDREN

We do not intentionally collect the personal data from or about individuals categorized legally as children, that is individuals under the age of eighteen (18) as our services are not made or aimed at children. However, in the unlikely event it is discovered we have collected personal information inconsistent with this document, we shall ensure that the processing of that information is in accordance with the law and for a legitimate purpose.

 LEGAL BASIS FOR USE OF YOUR INFORMATION

Our legal basis for collecting and processing your information, as already stated, depend on the particular type of information and the particular context in which it is collected. However, some of the legal reasons for collecting your information include where use of your data is necessary to perform our obligations under a contract with you, where use of your information is necessary for our legitimate interest or that of others for example to provide security, operate our products and services or other similar purposes; and where use of your information is necessary to comply with a legal obligation.

More specifically we may use personal information to:

·   Account set up and administration including the management of you account, access credentialing, providing technical and customer support, and delivering training. We may also use it to verify identity, perform authentication activities, process transactions and offers suggestions and recommendations related to our services.

·   Relationship administration where we administer our relationship with you, our business and third party providers. This usually involves activities such as sending invoices and maintaining communication to ensure smooth interactions.

·   Understanding customer patterns in order to enhance and improve our services

·   Handling inquiries and complaints where personal information is used to address and resolve inquiries and complaints

·   Event management where we may contact you in participation in and management or events, webinars, seminars, meetings, and related activities

·   Screening and investigation where we may use your information in the conducting of screening, investigation, and enforcement activities

·   Content delivery and personalization where we my deliver tailored content, analyze your usage patterns to make service suggestions and personalize your experience within our services

·   Marketing and surveys including polls and research activities

·   User generated content such as the information you post, share or upload in various platforms that is processed for collaboration, peer connection and information exchange

·   Legal and regulatory compliance where we process your information to meet internal and external audit requirements, regulatory reporting, enforcement of terms and conditions and to comply with applicable laws and regulations

·   Security and Protection where your information is utilized to protect our rights, privacy, safety, networks, systems, and property including through identity verification and monitoring for safety and security purposes.

·   Business Operations where we use your information for onboarding and managing relationships, negotiation and finalization of business transactions, appointment, and periodic review

·   Crime Prevention and Investigation where data is processed for the prevention, detection or investigation of crime, loss prevention or fraud

·   Legal Compliance and Defense where we may be required to comply with request from courts, law enforcement, regulatory agencies and other authorities and exercise our rights while defending against claims and adhering to relevant laws and regulations.

 MARKETING

We communicate marketing and event information to you through various s channels, such as email, telephone, text messaging, direct mails, and online platforms. Incompliance with the law, we shall request explicit opt-in consent for receiving marketing communication. If you receive a marketing message from us, it shall include instructions on how to opt out of future communications.

Respecting your preference is an important thing for us, and you have the right to opt out of direct marketing and targeted online advertising. We employ tools and technologies including cookies and related methods to deliver targeted marketing content. Additionally, we may use email tracking technology to assess engagement and the effectiveness of our communications. While we may engage in marketing on third party platforms such activities are governed by the privacy statements and terms and conditions of those platforms.

 To opt out of marketing activities, including email, post and telephone marketing, individuals can utilize the “Contact Us”  feature, specific opt out mechanisms provided in connection with marketing communications, discuss with a Laboremus contact or any other means available.

 YOUR RIGHTS

Upon request that can be delivered to our Data Protection Officer , and subject to applicable legal expectations, we will:

·   Provide access to and/or a copy of certain information we hold about you

·   Provide you with information about categories of information we collect or disclose about you, the categories of sources of such information, the business or commercial purpose for collecting your information, and the categories of third parties to which we disclose your information

·   Prevent the procession of your information for promotional purposes (including any direct marketing processing)

·   Update information which is out of data or incorrect

·   Delete certain information which we have about you

·   Restrict the way that we process and disclose some of your information

·   Transfer your information to a third party provider of services

·   Revoke your consent for the processing of your information

We may take further steps to make sure that the request for information does indeed concern you, or that you are authorized to make the request. Please note  though, that certain information may be exempt from such requests in special circumstances, for example, if we need to comply with a legal obligation. As explained in our Cookie Policy we provide information on how our sites use Cookies and how to optout of them.

 CHANGES TO THIS DOCUMENT

We shall be relevantly updating this document form time to time to make sure that it accurately reflects our data protection and privacy standards. When that happens, any such changes shall be duly communicated.

 FORANY FURTHER INFORMATION

^{We are located at Plot 57B Luthuli Avenue Bugolobi, Kampala Uganda. If you wish to contact us or if you have any questions about or complaints in relation to this notice, please contact us at hello@laboremus.ug . To contact our Data protection Officer, please email isabel@laboremus.ug}

‍

‍

‍