Privacy Policy

1. Introduction

Welcome to ShareCARD Limited (“we,” “our,” or “us”). 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. For more about us, see the Who We Are section of our website.

We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, share, and protect your personal data when you use our platform. By using our services, you consent to the practices described in this Privacy Policy.

2. Law Applicable

ShareCARD Limited is required by the Data Protection and Privacy Act, No.9 of 2019 to comply with requirements regarding the collection, use, disclosure, storage, and destruction of specified types of information obtained from our clients, employees, and any third parties with whom we have dealings.

3. Collection of personal data

When you provide information to ShareCARD, through the website or otherwise, you are warranting to the company that all of the information you provide to us about yourself and about your Beneficiary is accurate and complete.

In providing the personal data of any individual other than yourself to us during your use of our services, you promise that you have obtained consent from such individuals to disclose their personal data to us, as well as their consent to our collection, use, and disclosure of such personal data, for the purposes set out in this Privacy Policy.

The company is relying on your warranty when it provides the services to you. The information you provide includes personal data, which is defined as information that can be used, on its own or with other information, to identify you or your Beneficiary. Please also ensure that your beneficiaries are aware of this notice and that the provisions of this notice are clearly communicated to them.

4. Information We Collect

4.1. Personal Information

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. The information that may be obtained from you includes the following:

1. Contact Information: Your name, email address, phone number, and other contact details as provided.
2. Business Information: Work and nature of services details, company name, and other business-related details as provided.
3. Demographic information for users: Such as age, education, gender, nationality and interests.
4. Investment Product identifier details.
5. Evidence of identity (for example passport information, National ID Number).
6. Unique identifiers such as username, account number, and password.
7. Payment details and other financial data (for example, bank or payment method provider’s name and your account number and sort code).
8. Information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
9. Financial information which includes investment history, transaction details.
10. User account information which includes usernames, passwords.
11. Identity verification data.
12. Any other information you provide to us voluntarily.

4.2. Non-Personal Information

We may also collect non-personal information such as anonymised and aggregated data for statistical and analytical purposes.

5. How We Use Your Information

We use your information for the following purposes:

• Providing Services: To facilitate your access to the monitoring and evaluation platforms we avail and various investment products.
• Account Management: To create and manage your account, including authentication and identity verification.
• Customer Support: To provide customer support, respond to your inquiries, and address issues.
• Marketing: To send you updates, newsletters, and promotional materials if you have opted in to receive them.
• Communication: To contact you for business-related purposes, such as updates, inquiries, or customer support.
• Improvement: To improve our products and services based on your feedback and usage patterns.
• Legal Compliance: To comply with applicable laws and regulations, including anti-money laundering (AML) and know-your-customer (KYC) requirements.

6. Data Sharing

We may share your personal information with:

• Service Providers: Third-party service providers that help us operate our platform (e.g., payment processors, data hosting services).
• Forex Exchanges: To facilitate your transactions and interactions with forex exchanges.
• Legal Compliance: As required by law, regulation, or legal process.

7. Data Security

We take reasonable measures to protect your personal data from unauthorized access, disclosure, alteration, and destruction. However, no data transmission over the Internet is completely secure, so we cannot guarantee absolute security.

We take data security seriously and employ reasonable measures to protect your personal information. These measures include encryption, access controls, and regular security assessments.

8. Legal Basis

The Company only uses your personal information for a specific purpose(s), and before we do so we must have a legal basis. We may use your personal information for each of the following legal bases:

• Performance of a contract: Providing you with our products or services, notifying you of changes, enabling third parties to perform technical or logistical functions for us, and responding to complaints.
• Consent: Where you have consented to processing for a specific purpose such as marketing communications, surveys, or where otherwise required by law.
• Legitimate interests: Including fulfilling AML/CFT obligations, protecting our legal rights, promoting and conducting our business, research, product development, fraud prevention, and contacting you to progress your use of our Services — subject always to applicable law. You can object to processing based on legitimate interests.
• Compliance with legal obligations: Including AML, terrorist financing, fraud prevention, data protection legislation, court orders, and requests from NITA-U, the Financial Intelligence Authority (FIA), or other supervisory authorities.

9. Protection of Personal Data

We have implemented appropriate technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.

Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although the company uses strong methods to protect the data that you provide to us, and we regularly test our information protection practices and technology, ShareCARD cannot absolutely guarantee its security. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We will, however, notify you of any breach or other compromise that affects your data, promptly and in compliance with applicable law.

10. Your Rights

• Access: You can request access to the personal data we hold about you.
• Correction: You can request corrections to your personal information.
• Deletion: You can request the deletion of your personal data.
• Data Portability: You can request the transfer of your data to another service provider.
• Opt-out: You can opt out of marketing communications at any time.

11. Data Retention

We will retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by Ugandan data privacy and protection laws.

12. Data storage

Confidential information is stored on devices with end-to-end encryption in compliance with ShareCARD Limited standards.

13. Data leakage prevention

We shall implement appropriate controls on all our networks used to process personal information to protect your personal data. We shall be able to identify, monitor and detect any personal information leakage and block suspicious network traffic.

We may suspend or terminate your account if your devices are hacked to control and contain the damage and subsequently notify you of any available remedy.

14. Notices

In the event of any data breaches or suspected transmission of sensitive data to unauthorized persons, we will immediately communicate with affected parties and regulatory bodies.

15. Cookies and Tracking

We may use cookies and similar tracking technologies to improve our services and user experience. You can manage your cookie preferences through your browser settings.

16. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in our practices. We will notify you of any significant changes by posting a revised version on our platform.

17. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at info@sharecardapp.com.

18. Privacy Policy Changes

The Company’s privacy policy may change in the future. If that happens, the revised version will be posted on our website.