Privacy Policy
Effective Date: 1 April 2025 · Version 2.1 · Trucabin Connect Uganda Limited
1. Introduction and Scope
This Privacy Policy describes our practices regarding the collection, use, and disclosure of information that identifies you or can be used to identify you ("Personal Data"). This applies to all interactions across our website, www.trucabin.net, our consulting engagements, and the implementation of the Itiner Digital platform.
We adhere to the following principles:
- Lawfulness, Fairness, and Transparency — Processing data only on valid legal grounds.
- Purpose Limitation — Collecting data for specified, explicit, and legitimate purposes.
- Data Minimisation — Collecting only what is strictly necessary.
- Integrity and Confidentiality — Ensuring technical and organisational security.
2. Who We Are — Data Controller & Processor
The entity responsible for your data (the "Data Controller") is:
Trucabin Connect Uganda Limited
North Park Plaza, Bypass Link, Bweyogerere Industrial Park, Kampala, Uganda
Privacy Office
privacy@trucabin.net
Processor Roles
When providing our Itiner Digital services to business clients, Trucabin Connect acts as a Data Processor. In these instances, our clients are the Data Controllers. Processing is governed by a formal Data Processing Agreement (DPA) in accordance with Section 29 of the DPPA 2019.
3. Data We Collect
3.1 Direct Information
We collect identifiers (Name, Email, Phone), Professional details (Organisation, Job Title), and any specifics provided in your consultation requests.
3.2 Automated Data
Log data including IP addresses, browser configuration, and interaction metrics to help us optimize our service delivery and maintain system security.
7. International Transfers
Trucabin Connect is the exclusive partner for Itiner Digital, developed by **Care All Ltd. in Hungary (EU)**. Some personal data may be transferred to and processed in the European Economic Area (EEA).
Safeguards:
Such transfers are protected by standard contractual clauses (SCCs) and the mutual adequacy of Hungarian data laws under the GDPR, ensuring your data enjoys the same level of protection as it does in Uganda.
9. Your Rights
Under both DPPA and GDPR, you have comprehensive rights as a Data Subject:
- Access: See what data we hold.
- Rectification: Correct inaccuracies.
- Erasure: Request "Right to be Forgotten".
- Restriction: Limit how we use data.
- Portability: Receive data in structured format.
- Objection: Challenge legitimate interests.
Exercise Your Rights
Contact our Data Protection Officer at privacy@trucabin.net. We respond to all valid requests within **30 days**.
Note: We may require identity verification to prevent unauthorised data disclosure.
11. Security & Breach Notification
We employ industry-leading technical measures including AES-256 encryption and multi-factor authentication. We maintain a formal Incident Response Plan aligned with **ISO/IEC 27001**.
Breach Notification Policy
In the highly unlikely event of a data breach, we will notify the **Personal Data Protection Office (PDPO)** within **72 hours** of becoming aware, and notify affected individuals directly where required by law.
15. Contact & Complaints
Privacy Queries
privacy@trucabin.net
Regulatory Authority
PDPO at NITA-U, Kampala