This Privacy Policy (Policy) governs the collection, use, storage, process and disclosure of your personal data, including sensitive personal data by Furaha Finserve Uganda Limited (“Furaha”, “we”, “us” or “our”) and any of its members, successors, assigns and/or authorized representatives. This Policy will help you as an individual (“you” or “your”) understand what personal data we collect, why we collect it, how we use it, including if and how we share the information with third parties, and the choices you have in relation to your information.

Personal data is information relating to an identifiable or identified individual (natural person). We are the Data Controller Registration number PDPO-202401-2856 in relation to the personal data collected from you via the Furaha Platform (this includes Furaha Mobile App and Furaha Financial website). Furaha solely determines the purpose and means of processing your personal data.

By using our Furaha Platform, you confirm that you have read and understood this Policy and expressly consent to our use and disclosure of your personal data and any sensitive personal data in accordance with this policy. This Policy must be read together with the Terms and Conditions available on the Furaha Platform.

We respect the privacy of your personal data and will treat it confidentially and securely.

 

Your Personal Data

Personal data comprises all the personal details we collect and/or hold about you, directly or indirectly including your personal identification data, your transactions data, financial information, interactions and dealings with us, including information received from third parties, the public domain or collected through use of our Furaha Platform and cookies.

You authorise Furaha to collect, process and store your personal data including: 

1. information you provide to us through the Furaha Platform including your national identification number, your name, your mobile phone number, your email address, gender, date of birth, personal property details;
2. technical information automatically collected from you and/or any of your electronic devices through the Furaha Platform. Technical information includes: the type of device you use, unique device identifiers i.e., IP or serial number, the operating system, time zone setting; and location information to determine your current location;
3. details of your use of any of our platform or your visits to any of our service sites; and
4. information received from third parties including government agencies, credit reference agencies and mobile network providers.

We collect certain information automatically and store it in log files. This information may include your internet protocol (IP) address, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. From time to time, we may combine this automatically collected data to other information we collect about you for reasons such as analysis, security, content generation or marketing.

If you do not provide us with the personal data required to meet our legal and regulatory obligations or to enter into an agreement with you, we may not be able to provide you with our products or services.

 

Purposes for which we may process your Personal Data

Furaha recognizes your right to privacy as a data subject. We ensure that your personal data is processed in a lawful, fair and transparent manner and only for the legitimate purpose for which it was collected.

Any of your personal data collected and/or stored by Furaha through means specified in this Policy may be used for any of the following purposes: 

1. effecting payments, transactions and completing instructions or requests;
2. assessing suitability of products and services; 
3. regulatory compliance including all purposes required under written law;
4. conducting background checks and assessing your fitness for our products and services (including credit bureau checks, credit scoring and sanction screening);
5. updating Furaha’s records about you;
6. verification of school and beneficiary (student) information details and balances for credit assessment and payment purposes; 
7. statistical purposes;
8. establishment, continuation and management of the relationship and for loan accounts held with financial institutions licensed and regulated by the Bank of Uganda;
9. improving our product and service offering including the way we serve you;
10. contacting and informing you of our other products and services which may be of interest to you; and
11. plan, conduct and monitor the Furaha business.

The information collected from you by Furaha will be valuable in improving the design and marketing of our range of services and related products. 

Furaha may have a legal or regulatory purpose in processing your personal data. These purposes include:

1. prevention, detection, investigation and prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
2. identity verification, sanctions screening and due diligence checks;
3. compliance with local or foreign law, regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body.
4. We may also process your personal data to effect agreements between Furaha and any authority, regulator, or enforcement agency; to comply with policies and good practice standards where it is in our legitimate interest to do so.
5. We may process your personal data in line with any voluntary codes; to effect agreements between us and any authority, regulator, or enforcement agency where it is in our legitimate interest to do so.
6. We may also process your personal data where it is in our legitimate interests to seek professional advice, including, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights.

Persons to whom we may disclose Personal Data

Other than to those individuals and entities listed below your personal data will not be shared or disclosed by Furaha to any external person or body, unless Furaha has your express consent, or is under either a legal obligation or any other duty to do so.

For the purposes detailed above, your information may be disclosed:

1. to any member of Furaha anywhere in the world, including any officer, employee, agent or director and/or their advisors;
2. to any local or international law enforcement or competent regulatory or governmental authority for any legal purpose;
3. to any of Furaha’s service providers, dealers, agents or any other company that may be or become Furaha’s subsidiary or holding company for reasonable commercial purposes relating to our products and services;
4. to Furaha’s professional advisors including but not limited to lawyers, auditors or other professional advisors;
5. any court, tribunal, regulator, enforcement agency, exchange body, tax authority, or any other authority (including any authority investigating an offence) or their agents;
6. any debt collection agency, credit bureau or credit reference agency, rating agency correspondents, insurer or insurance broker, direct or indirect provider of credit protection and fraud prevention agencies;
7. any financial institution to conduct credit checks, anti-money laundering related checks, for fraud prevention and detection of crime purposes; 
8. upon your death or mental incapacity, your legal representative and their legal advisers, and a member of your immediate family for the purpose of allowing him/her to make payment on your account;
9. to our business alliance partners who may provide their product or service to you including but not limited to licensed and regulated financial institutions, credit reference bureaus, mobile telecommunication providers, school aggregators; 
10. to any actual or potential participant or sub participant in relation to any of our obligations under the terms and conditions between us governing the services offered through the Furaha Platform or assignee, novatee or transferee (or any officer, employee, agent or adviser of any of them);
11. for legitimate business purposes connected to your use of our services, such as marketing and research related activities;
12. in business practices including but not limited to quality control, training and ensuring effective systems operation;
13. any security provider or any person authorised to operate your account and to act on your behalf in giving instructions, to perform any other acts under our services offered to you or use any product;
14. anyone we consider necessary to facilitate your requests for Services; and
15. anyone we consider necessary to provide you with services in connection with the Furaha Platform.

The above disclosures may require the transfer of your information to parties located in countries outside Uganda. We will ensure that parties to whom your details are transferred treat your information securely and confidentially. We also pledge our commitment to fully meet any internationally recognised standards of personal data protection and to comply with applicable data protection and privacy laws including but not limited to Uganda’s Data Protection & Privacy Act and Regulations as amended from time to time. 

We may transfer your information if it is necessary to perform our contract with you and by providing details to us via the Furaha Platform you are deemed to have consented to any lawful transfer of your personal data.

 

Security

The security of your personal data is our key priority. We have technical and organisational security measures in place to safeguard your personal data. When using external service providers, we require that they adhere to security standards mandated by us. We may do this through contractual provisions, including any required by a privacy regulator, and oversight of the service provider. Regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that your data is kept securely.

You should be aware that electronic communication is not entirely a secure form of communication and sending us any personal data electronically carries with it risks including the risk of access and interference by unauthorised third parties. Information passing over the Internet may be transmitted internationally (even when sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than in your country of residence.

 

Retention

Information held about you is retained as long as the purpose for which the information was collected continues or as required under regulatory requirements. The information is then destroyed unless its retention is required to satisfy legal, regulatory, or accounting requirements or to protect Furaha’s interests. In the majority of cases the information will be retained for ten years from the end of your relationship with us.

It is your responsibility to maintain the secrecy and confidentiality of any user login password you hold for the Furaha Platform.

 

Monitoring

To the extent permitted by law, we may record and monitor your electronic communications with us to ensure compliance with our legal and regulatory obligations and internal policies for the purposes outlined above.

 

Marketing and Push Notifications 

We may use your personal data:

1. to conduct market research and surveys with the aim of improving our products and services;
2. for marketing purposes, and promotional events. 

We may also occasionally use push notifications through the Furaha Platform to send you marketing messages and other service or transaction-related notifications that may be of importance to you. We process your personal data for these purposes because it is in the interest of our business to do so with the intention of improving our products and services and generating business. 

By consenting to the Furaha Terms and Conditions and this Policy, you expressly provide your consent to receive marketing and promotional content from Furaha. If you change your mind and ask us not to send you marketing material or other promotional or research material you have subscribed to receive, we may need to retain a record that you have asked us not to do so to ensure that you do not receive anything further.

You have the right, at any time, to opt-out from receiving these types of communications by turning them off at the device level through your settings or through the Furaha Platform settings. You may also contact us through our care centre available on the Furaha Platform  or send any concerns or inquiries to [email protected] 

Automated decisions and profiling

We may use profiling, including behavioural analysis, to assist us to provide you with better services, to make decisions and to prevent money laundering, terrorism, fraud and other financial crime. If any profiling will result in an automated decision relating to you, we will let you know and you will have the right to discuss the decision with us.

Your Rights

As a data subject, you have the following rights under the applicable regulatory framework:

1. Access

You have the right to access any of your personal data under Furaha’s custody any time. You may request for a copy of your personal data held by us where necessary and this may be subject to a fee chargeable to you. 

2. Correction of personal data

If you suspect that your personal data as held by Furaha is false or misleading, it is your right to request that we correct such false or misleading data through the Furaha Platform.

3. Erasure of personal data

Where Furaha no longer has a legitimate business or lawful purpose to store your data or in the event the data we hold in relation to you is false or misleading, you have the right to request for deletion of your personal data. 

4. Object to the processing of personal data

It is within your rights to object the processing of all or part of your personal data held by Furaha. However, please note that you must consent to the processing of your personal data to access our products and services. Raising an objection to processing your personal data, unless a lawful basis exists, may interfere with how we provide our products and services to you.

Restriction

It is your right to require that personal data collected and stored by Furaha is processed for explicit, specified and legitimate purposes and that your personal data is not processed in a manner incompatible with those purposes. We have detailed the purposes for collection and processing of your personal data in this Policy.

Be informed

You have the right to be informed of the use to which your personal data is put by Furaha.

Portability

You have a right to request a copy of the personal data you have given to us in a machine readable format.

All requests inquiries, questions and/or concerns in relation of your rights as data subject should be addressed to the Data Protection Officer via [email protected] or by calling Furaha’s contacts as contained in the Furaha Platform under the Contact us section.

 

Cookies

To improve our service to you, we will occasionally use a ‘cookie’ and/or other similar files or programs which may place certain information on your devices’ hard drive when you visit the Furaha Platform. A cookie is a small amount of data that our web server sends to your application when you visit certain parts of the Furaha Platform. We may use cookies to:

1. allow us to recognise the device you are using when you return to the Furaha Platform so that we can understand your interest in the Furaha Platform and tailor its content and advertisements to match your interests (This type of cookie may be stored permanently on your device but does not contain any information that can identify you personally.);
2. identify you after you have logged in by storing a temporary reference number in the cookie so that our web server can conduct a dialogue with you while simultaneously dealing with other customers. (Your browser keeps this type of cookie until you log off or close your browser when these types of cookie are normally deleted. No other information is stored in this type of cookie.);
3. allow you to carry information across pages of the Furaha Platform and avoid having to re-enter that information;
4. enable us to produce statistical information (anonymous) which helps us to improve the structure and content of the Furaha Platform;
5. enable us to evaluate the effectiveness of our advertising and promotions.

Cookies do not enable us to gather personal data about you unless you give the information to our server. Most Internet browser software allows the blocking of all cookies or enables you to receive a warning before a cookie is stored.

 

Terms and Conditions

There are specific Terms and Conditions for the Services offered under the Furaha Platform that govern the collection, use and disclosure of your personal data. The Terms and Conditions shall be read together with this Privacy Policy.

 

How to Contact Us

If you wish to access and exercise any rights you have regarding your personal data or if you have any questions concerning our Privacy Policy please contact Furaha’s Data Protection Officer through [email protected] or calling the phone numbers on the Furaha Platform.
 

Complaints

In the event you are unhappy with the way we collect, handle or process your personal data, send your complaints to the Data Protection Officer via [email protected]. We will promptly and fairly address all your complaints and concerns and provide feedback to you within the legally permitted timelines. We will also keep you updated on the steps we take to resolve your complaints throughout the internal review process. 

You have the right to complain to Personal Data Protection Office where we do not provide satisfactory feedback and/or do not resolve your complaints within required timelines without providing information to you regarding delays we face with the review process.

 

Changes to this Privacy Policy

This Privacy Policy may be updated from time to time without advance notice to you. The most updated version will be uploaded onto the Furaha Platform to replace the existing version. Any amendments to the Privacy Policy will take effect on the date of publication and you are advised to check the Privacy Policy on the Furaha Platform regularly for any updates.

 

Linked Websites

Our Privacy Policy does not apply to third-party websites where our online advertisements are displayed or to linked third-party websites which we do not operate or control.

This Privacy Policy is not intended to, nor does it, create any contractual rights whatsoever or any other legal rights, nor does it create any obligations on Furaha in respect of any other party or on behalf of any other party.