Last updated on the 04^th January, 2023

THIS PRIVACY POLICY IS A LEGALLY BINDING DOCUMENT BETWEEN YOU AND YoPas TECHNOLOGIES LTD (BOTH TERMS DEFINED BELOW). THE TERMS OF THIS PRIVACY POLICY WILL BE EFFECTIVE UPON YOUR ACCEPTANCE OF THE SAME (DIRECTLY OR INDIRECTLY IN ELECTRONIC FORM, BY CLICKING ON THE I ACCEPT TAB OR BY USE OR THE WEBSITE OR BY OTHER MEANS) AND WILL GOVERN THE RELATIONSHIP BETWEEN YOU AND YoPas TECHNOLOGIES LTD FOR YOUR USE OF THE WEBSITE (DEFINED BELOW). THIS DOCUMENT IS PUBLISHED AND SHALL BE CONSTRUED IN ACCORDANCE WITH THE PROVISIONS OF THE INFORMATION TECHNOLOGY (REASONABLE SECURITY PRACTICES AND PROCEDURES AND SENSITIVE PERSONAL DATA OF INFORMATION) RULES, 2011 UNDER INFORMATION TECHNOLOGY ACT, 2000; THAT REQUIRE PUBLISHING OF THE PRIVACY POLICY FOR COLLECTION, USE, STORAGE AND TRANSFER OF SENSITIVE PERSONAL DATA OR INFORMATION.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING THE YoPas TECHNOLOGIES LTD WEBSITE, YOU INDICATE THAT YOU UNDERSTAND, AGREE AND CONSENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THIS WEBSITE. YOU HEREBY PROVIDE YOUR UNCONDITIONAL CONSENT OR AGREEMENTS TO YoPas TECHNOLOGIES LTD AS PROVIDED UNDER INFORMATION TECHNOLOGY ACT, 2000 AND RULES AND REGULATIONS MADE UNDER THERIN.

Introduction

This policy describes the information privacy practices that YoPas Technologies Ltd (YoPas, “we”, “us”, or “our”, if not explicitly referring to the company) follow when handling personal information that we collect or receive in conducting our business, including through our services, products, websites, employee(s) and user application(s).

This privacy policy demonstrates our commitment to protect the privacy of individuals with respect to personal information and is designed to assist you in understanding our policies and practices in relation to the collection, use, retention, transfer and access of personal information. 

Definition of personal information

Personal Information means any information relating to an identified or identifiable natural person (known as the data subject). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an phone number, location, an online identifier or by one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of the natural person. Personal information does not include information that is truly anonymised, i.e. where the data subject is no longer identifiable. Personal information also does not include corporate information that relates to an organization but not to an individual, such as a corporate name, corporate address or general corporate phone number.

Whom is this Privacy Policy for

In addition to our employees, consultants who are our agents, will be required to act consistently with this Privacy Policy on our behalf. Independent agent will be made aware of the Privacy Policy as it applies to our staff, potential and/or existing customers and counterparties in their dealings with them. Joint Venture companies not under our control are encouraged by YoPas Technologies Ltd to adopt similar privacy practices and standards in accordance with various in-country data protection law(s).

Contact Information

We are committed to responding to and resolving questions, requests and/or complaints about your personal information and our collection or processing of your personal information. If you believe that we are not complying with the terms of this Privacy Policy or other legal requirements you may direct your concerns via email to legal@utrax.co.ug. We will investigate and will do our best to resolve any complaints or disputes you bring to our attention regarding the use and disclosure of your personal information.

Personal information you provide to us.

We collect personal information that you provide to us through our websites, and in connection with business dealings we may have with you, and/or where we are legally obliged to as part of a contractual agreements. This includes information that you may provide to us in employment contracts, applications for employment, service agreements, Know Your Customer (KYC) and community events and engagements held at our operational sites where permitted.

The personal information you provide includes basic contact information about you, such as your name, title, address, phone number, location and email address.

To ensure we do business with reputable, honest and qualified business partners and agents, we conduct due diligence checks on companies and their directors to establish the legal status of all potential new business partners to evaluate whether they may be involved in illegal or corrupt practices.  

Website information you provide to us.

For your information, Cookies are small pieces of data that can be stored in users’ hardware for the purposes of obtaining configuration information and analyzing users’ viewing habits. They are commonly used to track users’ preferences in relation to the subject matter of the website and make users’ online experience easier and more personalized. 

Our website and any other websites and applications we offer as part of our business dealings with you will consist of various contact request forms in which you will willingly submit personal information which will be held in accordance with this Privacy Policy.

This website usage can be anonymous information. However, if it is combined with your personal information in a manner that reasonably allows it to be associated with your identity, or is otherwise considered personal information under applicable law, it will be treated as personal information in accordance with this Privacy Policy.

Information we may receive from our counterparties.

We may receive personal information about you from our counterparties who may recommend or suggest that we contact you for business purposes. This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address. It may also include information on the products or services you have shown interest in or may be interested in purchasing from us, as well as information on other companies or individuals with whom you do business with. We may also obtain personal information about you from our counterparties in connection with business transactions you initiate with us, such as through credit verification or other processes related to the transaction.

We do not knowingly collect or use any personal information from children younger than the age of fourteen  (14), or from children, who do not have the necessary ability to foresee the consequence of their personal information being processed without obtaining the appropriate consent, as required by applicable law.

Use of personal information

Business Purposes

We use your personal information to facilitate our ongoing and proposed business dealings with you. This includes:

• To process business transactions with us;
• To establish and maintain counterparty (includes customer(s)) accounts so that we may provide products or services of ours requested by you or your company;
• To communicate with you about updates, maintenance, outages or other technical matters concerning these products or services;
• To provide you with training regarding usage of these products or services;
• To notify you about changes to any of the policies and procedures for use of these products or services;
• To verify the accuracy of technical contact information we have on file for you and your company in relation to these products or services; and
• To respond to questions or inquiries that you or your company may have about our products or services.

We may use your personal information as required for us to comply with relevant laws and regulations relating to the products or services that we provide in any of the jurisdictions in which we or our affiliated operating units operate.

Marketing Purposes

With your consent or as otherwise permitted by applicable law, we may use your personal information for purposes relating to the marketing of our products and services, or those of our business partners where you may have shown interest in. This means we may from time to time:

• Send you newsletters, press releases, event announcements and other similar communications regarding the products or services that we offer;
• Market or promote our products or services to you or similar products to those which you have already signed up for, including by offering you trial or limited access to certain of our products or services;
• Solicit input from you regarding improvement of our products or services;
• Inform you of third-party offerings that we think you or your company may be interested in which relate to our products or services;
• Send you announcements or requests on behalf of other customers of ours who believe you would benefit from use of our products or services; and
• Use your personal information for other purposes that we disclose to you at the time we obtain your consent.

You may at any time opt-out to receiving marketing related communication from us, by contacting our offices directly, alternatively you may email us at help@utrax.co.ug.

Referrals

From time to time, we may receive personal information about you from counterparties who recommend or suggest that we contact you for business purposes. We may receive such personal information because you have consented towards the relevant counterparty that they might share your personal information with businesses like ours for these purposes. If we use that information to contact you, it will only be to see if you are interested in our products or services, or those of our business partners. We will not use this information for other purposes without your consent. In addition, if you inform us that you are not interested in these products or services, we will stop using the information to contact you.

Data Integrity

You are responsible for the accuracy of all personal information that you provide to us. We will use reasonable efforts to maintain the accuracy and integrity of your personal information, and to update that information as appropriate. We will take reasonable steps to ensure that the personal information we collect from you is relevant to its intended use, and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorized by you.

Recruitment

We may use your personal information you provide to us through job applications, using our online website, email or via fax solely for the purposes of processing your job application for the position you have shown interest in and in accordance with this privacy notice and applicable law. This may also include data we collect from third parties such as professional recruiting firms, your references, prior employers and educational history in order to identify and evaluate candidates for potential employment. We may conduct vetting for specific job roles, which may include criminal background checks and credit checks, as permitted by local laws. With your consent, we may retain a record of your job application and references for a period of time, in order to ensure compliance with legal requirements.

Legal Protections and Law Enforcement

We may access, use, preserve, transfer and disclose to our counterparties your personal information for the following purposes:

• To satisfy any applicable law, regulation, subpoena, or legal or regulatory process, if in our opinion such is required or permitted by law or reasonably requested by a regulatory authority;
• To protect and/or defend this Privacy Policy or YoPas product and service policies or terms of use applicable, including investigations of potential violations thereof, ensuring the protection of the safety, rights, property or security of YoPas Technologies ltd or any of our counterparties;
• To detect, prevent or otherwise address fraud, security issues or breaches, or technical issues. This may include allowing third parties, such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, to access and use your personal information in order to identify you. We may take any of these steps without notice to you to the extent permitted by law.

Your additional rights

As a data subject, you have rights regarding the processing of your personal information, including rights to, in certain circumstances:

• Withdraw any consent you have given, or are deemed to have given, in relation to our collection or use of your personal information;
• Request access to any personal information held about you by us and details of the processing of your personal information by us;
• Have inaccurate personal information amended or erased, and to have incomplete personal information completed;
• Request the erasure of your personal information;
• Object to or restrict the processing of your personal information (including profiling), including where the processing is unlawful or no longer necessary;
• Receive your personal information in a format suitable for transmission to another data controller;
• Object to processing of your personal information for direct marketing. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information.
• Prevent processing that is likely to cause unwarranted substantial damage or distress to yourself or anyone else;
• Object to any decision about you based solely on automated processing (including any profiling) that produces legal effects or otherwise significantly affects you; and
• Complain to the relevant data protection supervisory authority, if you think that we are not complying with our obligations in relation to our processing of your personal information.

You can make a request to us in relation to these rights at any time by contacting us via email at legal@utrax.co.ug/. All requests will be dealt with promptly and any information to which you are entitled will be provided within a reasonable timeframe, subject to the exemptions stipulated in applicable data privacy laws.

Data Security

We will take all reasonable security measures to protect your personal information in our possession from loss, misuse, and unauthorized access, disclosure, alteration or destruction. As necessary, we will take additional precautions regarding the security of particularly sensitive information such as categories of data deemed as sensitive under applicable data protection laws. While we strive to secure your personal information, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control.

Data retention

We will not retain personal information for longer than is necessary for the purposes for which it was collected, except where retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

Enforcement

We will conduct periodic internal compliance audits and assessments of our relevant privacy practices to verify adherence to this Privacy Policy. We encourage you to raise any questions or concerns that you may have about the way we process your personal information by contacting us at legal@utrax.co.ug/.

Policy Changes

We reserve the right to update this Privacy Policy at any time, without prior notice to you, to the extent permitted by applicable law. We will notify the changes that we make to this Privacy Policy by posting the revised Privacy Policy on our websites, and such changes will be effective immediately unless otherwise stated.