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Privacy Policy

1. Important notice

This is the Privacy Policy for It describes who we are, how we obtain and use your personal data, why we are allowed to do so by law, who has access to your personal data and what your rights are. Please review it carefully. This website is not intended for children and we do not knowingly collect data relating to children.

You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including any related profiling). For more information about your rights and how you can exercise them, please see the section Your rights.

2. About Us

We are Nugsoft Technologies Ltd, a private limited company incorporated in (and subject to the laws of) Uganda. Our registered address is at Kyanja,Nakawa Division,Kampala. We take your privacy seriously and use your personal data as further explained in this Privacy Policy. We are the “controller” of the personal data you provide to us.

3. What personal data we collect and why

Personal data is any information which identifies you personally whether directly (for example, your name) or indirectly (for example, information about your use of our products and services). We may collect, store and transfer different kinds of personal data about you which as have grouped together as follows: We collect the following personal data from you:

We also obtain information about you from other sources:

How we use your personal data

We use your personal data for the following purposes:

Where applicable, to contact you in relation to a prize draw or competition you have entered.
We use your personal data to process your entry to a prize draw, competition or relevant promotion.

Direct marketing (including by third parties.

If you have provided your consent or we otherwise have the right to do so, we may use your contact details to send you direct marketing and keep you informed of promotional offers by email, SMS, post or telephone relating to our products and services. Our trusted business partners would also like to use your name, email address, postal address and telephone number to inform you of similar products, services and promotional offers. We will only share your personal data with our partners where you have provided us with your consent to do so. You can unsubscribe at any time by clicking the “Unsubscribe” link in any of their emails or managing your preferences via their website.

To conduct automated decision-making and profiling.

We use technology which tracks your use of our website, app, products and services to help us build a profile of your preferences. What this means for you is that you are more likely to receive direct marketing and promotional offers that are tailored to your specific preferences, based on your previous activity.

If you don’t agree with an automated decision that our technology has made in relation to you, you can let us know (see How you can contact us) and we may decide to look into it for you. You may still have the right to object to us processing your personal data for the purpose of automated decision-making or to restrict us from doing so (see Your rights).

Please note that the legal basis for us carrying out these activities is that it is in our legitimate interests to do so, having taken into account whether your interests and fundamental rights and freedoms are overridden by this type of processing. See Legal grounds for processing) for more information.

To track your usage of our website, communications, products and services.

We use cookies and similar technologies to track your activity on our website so that we can provide important features and functionality on our website, monitor its usage, and provide you with a more personalised experienced. Please see our Cookie Policy to find out more.

To conduct internal training.

We may use your personal data for internal training purposes so that our staff have the knowledge and expertise they need to ensure we provide you with the best possible user experience. For example, if you contact us by telephone, we may record the call and make notes in relation to your call for training and service improvement purposes.

To conduct market research and analytics.

We may analyse your personal data (potentially in combination with personal data relating to other customers) to better understand our user base. We may also invite certain users to be involved in market research. If you accept our invitation, we will use your feedback to improve our products and services.

To maintain our records and improve data accuracy.

Like any business, we process personal data in the course of maintaining and administering our internal records. This includes processing your personal data to ensure that the information we hold about you is kept up to date and accurate.

To respond to enquiries, complaints and disputes.

We use the personal data we hold about you to help us respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you, in the most effective manner.

To investigate, detect and prevent fraud and comply with our legal obligations.

In certain circumstances, we use your personal data only to the extent required in order to enable us to comply with our legal obligations, including for fraud detection, investigation and prevention purposes. This may require us to provide your personal data to law enforcement agencies, including Trading Standards, if they request it.

5 .Legal grounds for processing

Data protection law requires us to only process your personal data if we satisfy one or more legal grounds. These are set out in data protection law and we rely on a number of different grounds for the processing we carry out. These are as follows:


In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:

Necessary for the performance of a contract and to comply with our legal obligations.

  • Where you enter one of our prize draws, competition or promotions.
  • Communicate with you about major changes to the terms of this Privacy Policy or to any related or similar information.

In certain circumstances, we also use your personal data only to the extent required in order to enable us to comply with our legal obligations, including to detect, investigate and prevent fraud.


Necessary for the purposes of our legitimate business interests or those of a third party.

It is sometimes necessary to collect and use your personal data for the purposes of our legitimate interests as a business, which are to:

  • Better understand our user base so that we can improve our products and services and marketing activities (which could also benefit you).
  • Comply with our contractual obligations to third parties, for example to produce aggregated underwriting risk analysis reports for our commercial lenders and commercial insurers.
  • Develop and improve our website to enhance the user experience.
  • Train our staff so that we can provide you with a better user service.
  • Respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you.
  • Ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.

Please note that where we wish to rely on this legal ground for processing, we are required by data protection law to consider whether our legitimate interests are overridden by your interests or your fundamental rights and freedoms. We may continue to process your personal data on the basis of our legitimate interests only if we determine that your interests, rights and freedoms are not overridden by our legitimate interests. We have considered these matters and on balance, we consider that the benefits described above are not outweighed by your interests or your fundamental rights and freedoms.

Where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not process your personal data unless there is another legal ground for us to do so (either that we have obtained your consent to the processing or it is necessary for us to perform our contract with you or to comply with our legal obligations).

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