Privacy Policy

Overview

This privacy statement explains how and why Transfara collects, stores, uses, and shares personal data when you visit our websites or use our services. Reading it will help you understand your privacy rights and choices. “Personal data” in this statement means information about you, including your identity, finances, and online behavior. “Transfara” in this statement means Transfara Technologies Ltd. This privacy statement applies to the Transfara, and any other services offered by Transfara. This Privacy Policy ("Policy") explains among other things: what we do with your personal information; what we do to keep it secure; with whom we share your information; your rights in relation to the personal information we hold about you; and who you can contact for more information.  We will regularly amend or update this Policy to reflect changes in our practices with respect to the processing of personal information, or changes in applicable law. We encourage the public to read this Policy carefully, and to regularly check the company’s website to review any changes we might make to the terms of this Policy

Who we are

Transfara Technologies Ltd ("Transfara", "we", "us", "our") having its registered office at Missionaries House, Stensera Road, Kampala, Uganda is a data controller for the purpose of Privacy Laws, as defined by the Data Protection and Privacy Act of 2019.

Definitions

To help clarify our meaning, we have used certain capitalized terms in this Policy. These terms and their meaning are:
In this Policy, references to "You" and "Your" are references to a user of our website and/or of our Mobile App.
“Customer” means any individual who has registered with us or used any of our Services or inquired about any of our Services.
“Privacy Laws'' means the Uganda Data Protection and Privacy Act 2019 and other applicable legislation relating to privacy or data protection, such as the Computer Misuse Act 2011.
“Marketing” means any action or advertisement or promotion or marketing material like surveys, vouchers, research and events. This list is not exhaustive.
“Services” means Transfara’s money transfer services; and such other services or products that we may introduce from time to time.

The personal information we collect about you

We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process this data in accordance with the Privacy Laws and as set out in this Policy. The personal information we collect and use may include, amongst other things:

  • Your Full Legal name;
  • Your contact information such as Your email address, postal address and telephone number (or any telephone number used to call our customer services);
  • Your demographic information such as date of birth, age, education, gender, and interests;
  • evidence of Your identity (for example Primary Photo ID document such as passport information, passport copy);
  • any correspondence or complaint made to us;
  • unique identifiers such as Your username, account number and password;
  • Your profiles and postings on any other social media applications and services that we provide or that You make available to us;
  • Your payment details and other financial data (for example, Your bank or payment method provider’s name and Your account number and sort code); and
  • 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.
  • We will not collect sensitive information about you without your consent unless an exception in the Act applies. These exceptions include if the collection is required or authorized by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct. For example, we might collect your biometric information when confirming your identity.
We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers), where You provide us with such information. In providing this information you confirm to us that you have obtained all necessary permissions from them to the reasonable use of their information for the purposes and in the manner described in this Policy, or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.

How we collect your personal information
  • Information You give to us when You use our services. If You use our services You will need to provide certain information including Your name, address and card number, as well as the name and other details of the recipients of the money transfers that you instruct us to carry out.  This information must be complete and accurate, and if not we may have to take additional steps to complete the transaction.
  • Other information You give to us. This is information about You that You give us by filling in forms on our website (for example, the ‘contact us’ section) or when you communicate with us by phone, e-mail or otherwise. It includes, for example, information You provide when You register on the website for us to contact You, when You inquire about any of our Services, and when You report a problem with our website. The information You give us may include, among other data, Your name and email address.
  • Social Media. Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram, You might give us permission to access information from those accounts or services.
  • Other Sources. We may receive information about You from other sources, including publicly available databases and combine this data with information we already have about You. This helps us to update, expand and analyze our records and provide services that may be of interest to You.
  • Transfara App. When You download the Transfara mobile App, in addition to the information mentioned above we:
    • automatically collect information on the type of device You use, operating system version, and system and performance information. We may send You push notifications from time-to-time in order to update You about events or promotions that we may be running. If You no longer wish to receive these types of communications, You may turn them off at the device level. To ensure You receive proper notifications, we will need to collect certain information about Your device such as operating system and user identification information;
    • may collect Your location-based information for the purpose of locating a place that You may be searching for in Your area. We will only share this information with our mapping provider for the sole purpose of providing You with this service. Your geo-location data may be shared with third parties for the purpose of serving You ads for places in Your area. You may opt-out of location-based services at any time by editing the setting at the device level or by emailing us at privacy@transfara.com; and
    • may use mobile analytics software to allow us to better understand the functionality of our mobile software on Your device. This software may record information such as how often You use the Transfara App, the events that occur within it, aggregated usage, performance data, and where the Mobile App was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the Transfara app.
Information we collect about You
  • We use "cookies" to help us make our site – and the way You use it – better. Cookies mean that a website will remember You. They are small text files that websites transfer to Your computer (or phone / tablet). They improve website use and speed – for example by automatically filling Your name and address in text fields. Please see our Cookies Policy for further information.
  • Log Files. In addition, with regard to each of Your visits to our site, we will automatically collect certain information (for example, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data). We may combine this automatically- collected log information with other information we collect about You.
  • Social Media Widgets. Our website includes Social Media Widgets or Features, such as the Facebook Like button and Twitter button which are interactive mini-programs that run on our site to provide specific services from another company (e.g. displaying the news, opinions, music, etc.). Personal information, such as Your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.
Personal information from third parties. If we receive personal information about you that we do not request directly from you or from another party, we will decide whether we could have collected the information in accordance with this Policy and Privacy Laws. If so, we will keep the information and handle it in accordance with this Policy and applicable Privacy Laws. If we decide that we could not have collected the personal information in accordance with this Policy and applicable Privacy Laws, we will destroy or anonymize the information if it is reasonable and lawful to do so.
Cookies and similar technologies
When you visit our site or use a Mobile App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may use your personal information through Cookies and similar technologies, in accordance with our Cookie Policy.
How we use your personal information
Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customized experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You and Your computer or device.
We use Your information for the following specific purposes:
  • to carry out our obligations arising from any contracts entered into between You and us or from applicable law, and to provide You with the Services in accordance with our terms and conditions and with this Policy;
  • to register You for a Transfara account;
  • to fulfil Your Transaction / (Airtime Top Up) Request;
  • to send You confirmations;
  • to notify You about temporary or permanent changes to our services or other service-related messages;
  • to assist you where online applications are not completed;
  • to prevent fraud, money laundering, and any other illegal activity that may cause you, us or others harm including in relation to the Services;
  • comply with our legislative and regulatory requirements in any jurisdiction;
  • to ensure that content from our site is presented in the most effective manner for You and for Your computer;
  • to promote our business;
  • to send You Marketing communications, provided that You have given us Your contact details except you tell us not to do so.
  • to administer our site and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes;
  • as part of our efforts to keep our site, Mobile App and our services safe and secure;
  • to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
  • to make suggestions and recommendations to You and other users of our site about services that may interest You or them;
  • to train, monitor and assess the effectiveness of the manner in which we provide the Services to You;
  • to consider and investigate any concerns or complaints you may have; and
  • to display personal testimonials of satisfied customers on our website in addition to other endorsements, where You have agreed with a third-party review site that we may do so. If You wish to update or delete Your testimonial, You can contact us using the help section of our services.
Direct Marketing
We may use your personal information to contact you via email, telephone, direct mail or other communication formats to offer you products and services we believe may be of interest to you but we will not do so if you tell us not to. When we market products and services to you, we will comply with applicable Privacy Laws to obtain your consent if required.
You can ask us to stop sending you Marketing information by contacting us at any time. Details of how to unsubscribe will be included on each electronic mailing we send you. Alternatively, simply send an email to privacy@transfara.com with the subject “UNSUBSCRIBE” in the subject line and the email address that you wish to be removed within the email.
Please note that it may take up to 72 hours to process your request and update our systems. Also note that if you request that we stop sending you Marketing messages, we will not stop sending you service and administrative communications (such as transfer updates and other important or transactional information).
We partner with third parties who may use technologies such as cookies to gather information about Your activities on this site and other sites in order to provide You advertising based upon Your browsing activities and interests (see Who we may share your personal information with). If You do not want to receive any information used for the purpose of serving You interest-based ads, You may opt-out by sending an email to privacy@Transfara.com with the subject “UNSUBSCRIBE”. You may continue to receive generic advertisements.
Who we might share your personal information with
Your personal information is very important to us. However there are circumstances where it is necessary for us to share your information in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose your personal information to:
Our affiliates
We share your information with our affiliates:
  • for our internal business, operational, management and service needs;
  • for compliance, regulatory and audit activity and in connection with legal, regulatory and tax claims and investigations;
  • to understand and support our Customers who use our services, apps and sites, as well as visitors to those apps and sites; and
  • to send Marketing communications.
Third party processors which include people with whom we do business or who provides services to us. If we engage a third party processor to process your information, the Processor will be subject to binding contractual obligations to: only use the personal information in accordance with our prior written instructions; and use measures to protect the confidentiality and security of the personal information, together with any additional requirements. We may disclose data to provide our services, to respond to legal requirements, enforce our policies, liaise with judicial or regulatory authorities where required under applicable law, and protect our rights and property.  Processors may include:
  • Credit reference agencies or other service providers to verify Your identity or the identity of recipients of the money transferred through our services or for any other purpose related to providing our services;
  • Debt collectors;
  • Professional advisers, such as our auditors and lawyers;
  • Companies that capture or analyze information to help us understand how our services, sites and Mobile Apps are used and perform or to tailor our services and promotions, including for the purpose of allowing us to improve the services we provide;
  • Companies that provide us with marketing assistance, including: the management of email marketing operations, SMS and other services that deploy marketing on the internet or social media platforms (such as Facebook and Google); the running of surveys and other feedback activity; as analysis of the effectiveness of any marketing or customer engagement we do;
  • Banks, payment card processors and other service providers that process bank transfers, credit and debit card payments or otherwise provide financial infrastructure services to enable us to provide our services;
  • Our service providers, including those who provide data hosting services, fraud prevention services; technology services, and technology tools that allow us to monitor, test and improve our services, sites and Mobile Apps;
  • Companies that we have instructed to provide services to or for us for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
  • Other business entities should we plan to merge with, or be acquired by, or be invested in by that business entity, or if we undergo a corporate reorganization; and
  • Any successor in business to us.
Fraud Prevention Agencies
Where we have a good reason to suspect fraud, money laundering, counter terrorist financing or any other illegal activity, we can upon request or where legally obliged share your personal information with crime prevention agencies and other third parties for the purpose of detecting, preventing or reporting crime or for actual or suspected breach of any applicable law or regulation. These third parties may include business partners and companies that provide services to us, law enforcement bodies, regulatory and supervisory authorities, providers of fraud prevention and detection services. Please note, we may suspend activity on your account or any transaction, refuse access to your account or cancel any transaction you may want to make, if we think there is a risk of any illegal activity.
Public Agencies
We release accounts or other personal information when we consider it appropriate to comply with the law, to enforce our Terms and Conditions and any other agreement to protect the rights, property, or safety of Transfara, our employees or Customers, our business partners or others. In these circumstances, we will only provide them with the information they require to perform their function.
Research companies
We may share personal information in a secure way to allow research companies and feedback providers to contact you directly on our behalf to get your opinions on or refuse to take part in the research or surveys.
International transfer of your personal information
Due to the international nature of our business, we may need to transfer your personal information to other Transfara entities, to other third parties as stated in the “Who we might share your personal information with” section of this policy, and recipients, in connection with the purposes set out in this Policy. For this reason, we may transfer your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. When we do disclose / or store personal information overseas, we protect that information using the security measures set out below and require overseas recipients to do the same.
Where recipients are outside Uganda, we ensure that the information will be protected by: safeguards comparable to Uganda’s Privacy Laws; or by methods including using contractual clauses; or by ensuring the recipient is subject to laws of another jurisdiction that provide comparable protection to the Privacy Laws.
We also ensure that our data protection and information security controls applying to your personal information in Uganda continue to apply in the hands of our affiliates or contracted service providers located overseas.
How we keep your personal information secure
We have implemented appropriate technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized 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 we will do our best to protect Your personal information, we cannot guarantee the security of Your data transmitted to our site; and any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorized access.
Your Rights
Subject to applicable law, you may have a number of rights regarding our processing of your relevant personal information, including:
  • the right not to provide your personal information to us (however, please note that we may be unable to provide you with the full benefit of our site, our Mobile App, or our services, if you do not provide us with your personal information);
  • the right to request access to your personal information, together with information regarding the nature, Processing and disclosure of those personal information;
  • the right to request for the identity of a third party or a category of a third party who has or has had access to your personal information;
  • the right to request for the correction of any inaccuracies in your personal information;
  • the right to request for the erasure of your personal information. This is also known as the right to be forgotten. We will keep a note of your name if you ask for your personal information to be erased;
  • the right that we restrict our use of your personal information;
  • where we use your personal information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal information in reliance upon any other available legal basis); and
  • the right to lodge complaints with the National Information Technology Authority regarding the use of your personal information by us or on our behalf.
We will require proof of your identity before we can give effect to these rights. You should also be aware that some of these rights are qualified and not absolute; therefore exemptions or limitations may apply. For example, we can refuse to provide information if fulfilling your request would reveal the personal information about another person, or if you request that we delete information which we are required to retain by law, have compelling legitimate interests to keep, or need access to fulfil our legal obligations.
You can contact us at privacy@transfara.com if you want to enforce any of these rights. We will comply with our legal obligations as regards Your rights as a data subject. 
Any request for access to Your personal information must be in writing and we will endeavor to respond within a reasonable period and in any event within thirty days except in certain circumstances and in compliance with Data Protection Legislation. We reserve the right to charge a reasonable fee (reflecting the costs of providing the information) or to refuse to respond where requests are manifestly unfounded or excessive: in this case, we will explain the situation to You and we will inform You about Your rights.
How long will we keep your personal information for:
We take every reasonable step to ensure that your personal information is only retained for as long as it is required for the purposes set out in this Policy. Therefore, we will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal or regulatory obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
The period for which we will retain information about You will vary depending on the type of information and the purposes that we use it for. In general, unless applicable law requires a longer retention period, we will keep our records for up to seven years after you have terminated your relationship with us, in order to comply with our legal and regulatory obligations.
We have specific retention periods if you are a Customer. We will retain your information for as long as you remain a Customer and for a period of time after you cease to be one in the following manner:
  • Customers who have requested that we close their accounts - we keep your information for seven years after the date that your account was closed.
  • Call recordings - We delete call recordings after five years unless we need the information to investigate fraud, to respond to questions or complaints or for legal reasons.
How to make a privacy complaint?
Transfara takes all complaints seriously and will investigate your complaint accordingly.
If you believe that there has been a breach of the Act or elements of this Policy, or if you have any concerns about Transfara's handling of your personal information, please contact us using the Contact Us tab on our website or by emailing us at privacy@transfara.com. Your privacy complaint should be directed and addressed to the Privacy Officer.
Please note that we aim to respond to complaints within 30 days of receipt. If you are not satisfied with our response to your complaint, you can also refer your complaint to the National Information Technology Authority - Uganda by:
  • Writing to: Palm Courts, Plot 7A, Rotary Avenue (former Lugogo Bypass)
  • PO Box 33151, Kampala - Uganda
  • Telephone: +256-417-801038
  • Email: complaints@pdpo.go.ug
  • Alternatively, visit: pdpo.go.ug/file-complaint
Contact Details:
You are welcome to send us questions, comments and requests regarding your personal information and our Policy are through privacy@transfara.com or you can send it by post addressed to the Privacy Officer
Writing to: Transfara Technologies Ltd, Missionaries House, Plot 400 Stensera Road, Kampala, Uganda
Email: privacy@transfara.com
You may also use these contact details if You wish to make a complaint to us relating to Your privacy.