ShareCARD Data Privacy Policy

Last Updated: Feb 3rd, 2024

Privacy Notice.

Introduction and Purpose

ShareCARD is a data intelligence company, focused on building software for simplified data management and impact tracing. Our technology comprises of a data management dashboard, a field Agent app, and beneficiary profiling cards. ShareCARD collects, verifies, aggregates, and analyzes program activity data up to the final beneficiary in real-time both on and offline. Our focus as African Innovators is to enable organizations to defragment their databases for easy data sharing, streamline partner deliverables, verify resource distributions, and reduce duplication of efforts on shared projects. With this, they can map their impact with clean data and expand their reach faster.

ShareCARD is licensed for use under the PDPO and URSB licenses available here. This data privacy policy is in full compliance with the Data Protection and Privacy Act of 2019, governing our practices related to user data and privacy. It pertains to the hosted instance accessible through and our website 

As a user of ShareCARD; you are subject to the following terms of use (“Site Terms”). By visiting the ShareCARD Site, you accept the Site Terms. Please read them carefully. In addition, when you use any current or future ShareCARD Limited services, content, or other materials, you also will be subject to the ShareCARD Customer Agreement or other agreement governing your use of our services (the “Agreement”).


Please review our Privacy Policy, which also governs your visit to the ShareCARD Site, to understand our practices.

ShareCARD Overview

ShareCARD is a digital monitoring, evaluation, and learning platform that enables organizations to gather, aggregate, and analyze program implementation data in a standard and timely manner. This Privacy Policy applies to the ShareCARD platform and software products. ShareCARD is a limited liability IT service company registered and licensed according to the laws of Uganda.

Personal Data Collected by ShareCARD

ShareCARD is committed to ensuring that we adequately protect the Personal Data of individuals whose Personal Data we Process as outlined in this Privacy Notice (“users” or “you”). 

What is Personal Information?: “Personal Data” is information that identifies or may be used to identify you as an individual. “Process or Processing” means any operation, or set of operations, automated or not, which is performed on Personal Data, including but not limited to the collection, storage, adaptation, use, transfer, disclosure, dissemination, or deletion of Personal Data.

This Privacy Notice provides information regarding the Processing of your Personal Data by ShareCARD in the course of providing you with our services or otherwise engaging with you.

This Processing is consistent with the policies, standards, procedures, and guidelines of ShareCARD. It is also consistent with, or is reasonably necessary to enable ShareCARD to carry out its mission, mandate, functions, and purpose as a data intelligence innovation established by its founder.  In certain cases, Processing Personal Data is necessary for the performance of a contract or compliance with a binding obligation or undertaking by ShareCARD.


ShareCARD respects your privacy and seeks to protect your Personal Data. The following information describes how we gather and use Personal Data.  The amount of information we hold on you and how it is used depends on your relationship with us and on what service you use or are beneficiary of, so some of the sections below may not be relevant to you. Please note:

  • We keep to a minimum the amount of information we hold about you.
  • We use your Personal Data to respond to your enquiries about our services, to send you other useful information, and to provide our services to you.
  • We apply appropriate security mechanisms to protect your Personal Data.

We are happy to answer any questions you have about this Privacy Notice. Contact us via email at

 What Personal Data do we collect and why?

Our services

When You Use Our Services

We collect and update information about users of our services.  We may obtain this information via direct contact with you, from third parties or automatically via your use of our services.

This information may include your contact details, identification details, registration and payment details, support problems, details around participation in events, and certain relevant details of your preferences.

We also collect and use your information to administer, support, improve, and obtain feedback on our services and to detect and prevent fraud, avoid faults and breaches, including breaches of our network security, applicable law or our contract terms. We may contact you to obtain feedback on that service and any improvements we could make to it.

Our legitimate basis for Processing your Personal Data when you use our services is that it is necessary for the performance of a contract or compliance with a binding obligation or undertaking by ShareCARD.

Other engagements

Our legitimate basis for Processing your Personal Data in the following cases is that it is consistent with, or reasonably necessary to enable ShareCARD to carry out its mission, mandate, functions or purpose as a data intelligence company established by its founders pursuant to the Charter:

When You Participate in a ShareCARD Supported Event or Seminar

We collect and update information about persons who take part in our events or seminars.  We may obtain this information via direct contact with you, from third parties such as other users and automatically via your use of our booking and/or Subscription facilities.  We may collect your name and contact details and, on some occasions, dietary requirements, banking information. If any of this Personal Data is sensitive data (i.e. special category data as defined under ShareCARD’s data privacy framework), we will seek consent before Processing.

When You Contact Us

We collect your contact information and use it to respond to your questions and requests.  We keep this information on our database and may use it to periodically inform you of additional useful information. We may also inform you of other related product updates, events, publications or services unless you have requested that we do not do so.

When You Sign Up for a Newsletter or Marketing

We will collect your contact details including your name, email address, and any other social media identity you provide.

When You Apply for a Vacant Position

We will collect your name, address, contact details and any other data you supply to us via your cover letter, curriculum vitae, email or through an online platform. We may also subsequently collect proof of identification, references and right to work/visa documentation.

When You are a Beneficiary of or Participant in a ShareCARD Subscriber Project

In certain circumstances, we may collect your contact details and any other Personal Data relevant to the specific project.

When we conduct research and provide or publish statistics

We may Process Personal Data for statistical and financial analysis for the formulation and validation of ShareCARD’s policies and projects and the publication of ShareCARD’s reports and research.

Reasons for processing personal data

ShareCARD may Process Personal Data for any of the following purposes:

  • administering, coordinating and managing ShareCARD’s relationships with ShareCARD’s partners, users and potential partners in the context of ShareCARD’s advisory, investment, and project activities;
  • analyzing and monitoring the use of ShareCARD’s products and services for the purposes of developing and improving ShareCARD’s products and services;
  • conducting advisory, investment and project activities, including relevant due diligence and monitoring in compliance with ShareCARD’s policies, procedures and guidelines;
  • conducting credit and other risk assessment and control activities;
  • pursuant to ShareCARD’s Strategic Framework for Integrity Compliance and Accountability, including for the prevention, detection and investigation of corruption, fraud and other prohibited practices as defined under the Strategic Framework and the sanctioning of wrongdoers;
  • investigating and responding to complaints, and establishing, complying with, exercising and defending ShareCARD’s legal rights and obligations, which may arise from ShareCARD’s projects, products and services;
  • maintaining appropriate accounting and other records;
  • managing ShareCARD’s information technology and ensuring the security and resiliency of ShareCARD’s systems; or
  • understanding and monitoring the impact of ShareCARD’s projects and services on development.

How do we Process your Personal Data?

Access to your data

We apply role-based access to our core business systems.  This means we work on a ‘need to know’ principle and only enable access for those within our organisation and those who subscribe to our products and services who have a legitimate business reason to access your data.

Protecting your identity

In some cases, it may be appropriate to protect your data using pseudonymisation or anonymisation techniques.  If this is something you require please contact us in advance of sharing your data.

Whom do we share your data with?

We work with various partners and associates in the provision of our services.  We may disclose Personal Data about you to the individual or legal entity (if any) with which you are associated, intermediaries, partners or other organisations involved in the ordinary course of conducting our data intelligence, advisory, investment, investigative and project activities or monitoring the impact of such activities on development.  We may also disclose your Personal Data to our legal and other advisors and service providers, subject to appropriate conditions of confidentiality and security.

Without prejudice to ShareCARD’s privileges and immunities, ShareCARD may disclose relevant Personal Data about you to relevant legal, regulatory, administrative or other authorities, as we believe to be appropriate in the following circumstances: (i) to enforce the terms of relevant documents; (ii) to protect and defend our rights and property; (iii) to protect the interests of ShareCARD or others; and (iv) to permit us to pursue available remedies or limit the damages that we may sustain.

Your Rights

You have certain rights regarding ShareCARD’s processing of your Personal Data.

Right of Access – You may request access to the personal data that we process.

Right to Rectification – You have the right to request that inaccurate Personal Data processed by ShareCARD be corrected.

Right to Erasure – You have the right to have your Personal Data erased from our systems in certain circumstances.

Right to Withdraw Consent – Where ShareCARD uses Consent as our legitimate basis to process your data you may withdraw that consent.

Please note that these rights are not absolute and in some instances, we may need to contact you to explain why we cannot comply with a request.

How long do we store your data?

We keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice and in order to comply or demonstrate compliance with our legal obligations and applicable records retention and disposal schedules.

Where we can, and it is appropriate, we will minimise Personal Data or anonymise data to use for statistical, analytical or reporting purposes.  The length of time we retain your personal information for will differ depending on the nature of the personal information and what we do with it.

Further details as to the length of time we keep Personal Data regarding a specific Processing activity can be obtained on request.


Where ShareCARD has used your consent to Process your Personal Data you can withdraw that consent at any time. This will not impact any previous Processing activities that took place prior to the withdrawal.


ShareCARD has standards governing information technology and security of Personal Data. ShareCARD uses reasonable endeavours to implement and maintain security measures to protect against the loss, misuse or alteration of information that we have collected from you on our website.

What if this privacy notice changes?

ShareCARD may update this Privacy Notice at any time. Changes to this Privacy Notice will be dated and will be effective from the date specified forward so that users are always aware of what Personal Data ShareCARD collects, how ShareCARD uses it, and under what circumstances ShareCARD discloses it.  You are advised to check ShareCARD’s Privacy Notice regularly for updates.

Privileges and Immunities

Nothing contained in this Privacy Notice shall operate or be regarded as a waiver, renunciation or modification of any right, privilege or immunity of ShareCARD under the regulations Establishing ShareCARD or any other applicable laws.

Requests, Complaints and Questions

Should you wish to access your Personal Data or submit a request to invoke any of your other rights, you can do so by contacting us at or by writing to us at the address below:

ShareCARD Limited
Serumage Road, Bukoto
P.o Box. 133240, Kampala, Uganda

Should you feel that you need to complain about how ShareCARD is handling your Personal Data or should you have any other questions related to ShareCARD’s data privacy framework or the use of data in a particular service, kindly send an email to