Official Data Privacy Standard

Privacy Policy

Effective Date: 1 April 2025  ·  Version 2.1  ·  Trucabin Connect Uganda Limited

Commitment to Privacy: Trucabin Connect Uganda Limited ("Trucabin Connect", "we", "us") values the trust you place in us. This policy outlines our rigorous standards for personal data protection in compliance with the **Uganda Data Protection and Privacy Act 2019** and the **EU General Data Protection Regulation (GDPR)**.

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

© 2025 Trucabin Connect Uganda Limited. This document is provided for informational and compliance purposes. Version 2.1.