Welcome | SwApp

Who we are

Our website address is: https://swapp.co.ug.

This Privacy Policy is an overview of how we collect, use, and process your personal data when you use our website https://swapp.co.ug (hereinafter: “Website”) and our mobile app (hereinafter: “App”; jointly called: “Services”). If anything here only applies to one of our services, we’ll explicitly point this out to you.

Please read this Policy carefully, as it becomes legally binding when you use our Services. We take privacy and protection of your data very seriously and are committed to handling the personal information of those we engage with responsibly and in a way that meets the legal requirements of the country.

Responsible Authority

The responsible authority for the collection, processing and use of personal data is: Swapp Payments Limited (“Swapp”, “us”, “we”, “our'') a national business with main country offices on the 3rd Floor of Ham Towers, Makerere Hill Road, Opposite Makerere University Main Gate. Our registration number with the Uganda Registration Service Bureau is 80020001717475. If you have any questions about how we protect or use your data, please email us at privacy@swapp.co.ug.

Data we collect about you

Information you provide to us.

Information is provided when you sign up to use our service, e.g. when you give us personal details like your name, phone number and email address. This also includes information you provide through your continued use of our Services, use of other social media functions on our Website or App. The information you give us may include your name, email address, phone number, National ID, physical location description, and photograph.
In some cases, where we need to comply with anti-money laundering regulations, we may also need more identification information from you.
In providing the personal data of any individual (other than yourself) that receive payments from you during your use of our Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Policy.

Information we gather about you

details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;
technical information, including the Internet protocol (IP) address used to connect your computer or phone to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time) and all activities performed.

Information we receive from other sources.

the banks you use to transfer money to us will provide us with your basic personal information, such as your name and phone number, as well as your financial information such as your bank account details;
business partners may provide us with your name and address, as well as financial information;
advertising networks, analytics providers and search information providers may provide us with pseudonymised information about you;

Information from social media networks.

Through using your social media account to access our services; you provide us with access to certain information including your name, profile image and email address. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. We will use, disclose and store all of this information in accordance with this privacy policy.

Children’s data

Our products and services do not address anyone aged 16 years and below. We do not knowingly collect personally identifiable information from children under 16. If any data is collected from a child without verification of parental consent, it will be deleted. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

How we protect your personal information

We take the protection of your information very seriously, and take a number of steps to ensure it stays secure:

Communication over the Internet between you and swapp servers is encrypted using strong asymmetric encryption. This makes it unreadable to anyone who might be listening in.
We update and patch our servers in a timely manner
Our technical security team proactively monitors for malicious activity in our servers and services
When information you’ve given us is not in active use, it is encrypted at rest. This means it’s unreadable from server hard-drives without the decryption secret.

We restrict access to your personal information to Swapp employees who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from unauthorized access.

Ways we use your information

to carry out our obligations relating to your contract with us and to provide you with the information, products and services;
to comply with any applicable legal and/or regulatory requirements;
to notify you about changes to our Services;
as part of our efforts to keep our Services safe and secure;
to administer our Services and for internal operations, including troubleshooting, data
to improve our Services and to ensure that they are presented in the most effective manner;
to allow other Swapp customers to request or send money to you through our services when providing matching information for your phone number or email;
to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
to allow you to participate in interactive features of our Services, when you choose to do so;
to provide you with information about other similar goods and services we offer;
to combine information we receive from other sources with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

We may share your information with selected third parties including:

advertisers and advertising networks solely to select and serve relevant adverts to you and others with your consent
analytics and search engine providers that assist us in the improvement and optimization of our site;
affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter into with them or you.

We may disclose your personal information to third parties:

such as affiliates and business partners for the performance and execution of any contract we enter into with them or you;
in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our customer agreement and other applicable agreements; or to protect the rights, property, or safety of Swapp, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
to develop customer relationships, services and systems.

Cookies

We use small files (known as cookies) to distinguish you from other users. They also enable us to improve our services. This Service does not use these “cookies” explicitly. However, the app may use third party libraries that use “cookies” to collection information and to improve their services. With cookies we can give you a better browsing experience and improving the quality of our product. They let us make it easier to log in, and they show us where you might be having trouble with our products. Below are the cookie groups explaining how and why we use them:

Strictly necessary cookies. We need these cookies to run our website — they let us save your cookie preferences, and keep the site secure. They’re always on.
Cookies that give you a better browsing experience. These let us tailor the site to your needs, like displaying it in the same language as your web browser. We’ll sometimes refer to them as functionality cookies.
Cookies that help us improve our products. These let us use tools that show us how you interact with our products. They help us find and fix problems for our customers, and they’re also known as analytical or performance cookies.
Cookies that keep our marketing costs down. These improve our marketing — helping us to spend less on sites like Google and Facebook, and more on charging as little as we can. When our costs go down, so do our prices. We share this information in aggregate form with third parties, for the purpose of advertising.

Data Retention

Swapp is required by law to store some of your personal and transactional data beyond the closure of your account with us. We only access your data internally on a need to know basis, and we’ll only access or process it if absolutely necessary.

We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate.

Your rights

Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. If you have any questions in relation to our use of your personal information, contact us. Under certain conditions, you may have the right to require us to:

provide you with further details on the use we make of your information;
provide you with a copy of the information that you have provided to us;
update any inaccurate, incorrect, or out of date personal information we hold;
delete any personal information that is no longer necessary, or no longer subject to a legal obligation to which Swapp is subject to. Swapp has legal obligations so it may not be possible to delete your data at the time of request. Once the required time has passed then we will be able to comply with your request;
where processing is based on consent, to withdraw your consent so that we stop that particular processing;
restrict how we use your information whilst a complaint is being investigated

Third-party links

This Service may contain links to other websites. If you click on a third-party link, you will be directed to that website. Note that these external sites are not operated by us. Therefore, we recommends that you check these policies before you submit any personal data to these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to our privacy policy

To keep up with changing legislation, best practice and changes in how we process personal information, we may revise this Privacy Policy at any time without notice so you are required to check periodically the policies.

Contact

If you have any questions, comment or suggestions about our Privacy Policy, Please send to our email address: privacy@swapp.co.ug

Privacy Policy