Privacy Policy – Enwealth Uganda

Privacy Policy Statement

1. Introduction

This Privacy Policy Statement explains how Enwealth Financial Services (UG) SMC Limited (“Enwealth Uganda,” “we,” “our,” “us”) collects, uses, discloses, and protects personal data in line with the Uganda Data Protection and Privacy Act, 2019 (DPPA), its regulations, and other applicable laws in Uganda and in jurisdictions where Enwealth operates. We are also guided by relevant international data protection standards.

2. Definitions

Enwealth: Refers to Enwealth Financial Services (UG) SMC Limited and other Enwealth Group companies. This definition includes subsidiaries and branches both within and outside Uganda.
Data Subject: Refers to clients, employees, service providers, agents, visitors, beneficiaries, and any individual who interacts with our services, websites, portals, or mobile applications.
Personal Data: Any information relating to an identified or identifiable natural person, such as names, contacts, identification details, and financial information.

3. Who We Are

Enwealth Uganda is a leading provider of pensions administration, insurance brokerage, investment management, and trustee services. We deliver holistic financial solutions tailored to meet the needs of individuals, institutions, and corporate clients in Uganda.

4. Principles of Personal Data Protection

We are committed to safeguarding your personal data in line with the following principles:

Privacy: We respect your right to privacy and confidentiality.
Lawfulness: We process personal data fairly, lawfully, and transparently.
Purpose Limitation: Data is collected only for specific, legitimate purposes.
Data Minimization: Only data necessary for the intended purpose is collected.
Accuracy: We take reasonable steps to keep data accurate and up to date.
Storage Limitation: Personal data is retained only as long as necessary.
Security: Appropriate measures are in place to prevent unauthorized access.
Cross-Border Transfers: Data will not be transferred outside Uganda unless sufficient safeguards are in place or with your consent.

5. Personal Data We Collect

We may collect:

Identification Data: Name, date of birth, contact details, national ID/passport.
Financial Data: Bank account details, investment records, pension contributions, insurance policy details.
Transaction Data: Records of transactions and services accessed.
Technical/Usage Data: IP addresses, device/browser type, website activity.

6. How We Collect Data

Directly: Through forms, applications, mobile apps, and in-person engagements.
Indirectly: From visits to our websites or portals, or through agents.
Third Parties: From regulators, other Enwealth entities, credit bureaus, or public databases.

7. How We Use Data

We use personal data for:

Onboarding, due diligence, and compliance with regulations.
Provision and management of pensions, investments, and insurance services.
Processing transactions and fulfilling contractual obligations.
Customer service and support.
Marketing, surveys, and product development.
Risk management, fraud prevention, and security.
HR, staff management, and internal operations.

8. Disclosure of Personal Data

We may share data with:

Enwealth Group Companies.
Service providers and partners (such as administrators, brokers, auditors).
Regulators and authorities where required by law.
Legal and compliance purposes (to enforce legal rights or meet obligations).

9. International Transfers

Your personal data may be transferred outside Uganda only when:

Adequate safeguards are in place (e.g., GDPR-compliant jurisdictions).
Approved by the relevant Ugandan authority.
You have consented.
Necessary for contract execution, public interest, legal claims, or vital interests.

10. Data Security and Retention

Retention: Data is kept for only as long as necessary—generally 7 years, unless law or business need requires longer retention.
Security: We use physical, technical, and organizational measures to protect data but note that no electronic transmission is 100% secure.
Third-Party Processors: Bound by contracts to meet our security standards.

11. Your Rights as a Data Subject

Under Uganda’s DPPA, you have the right to:

Be informed when data is collected and for what purpose.
Access your personal data in our custody.
Request correction of inaccurate data.
Object to or restrict processing.
Request erasure of data (“right to be forgotten”).
Withdraw consent at any time.
Request data portability to another service provider.
Seek redress or compensation for breaches of your rights.
Lodge a complaint with the Personal Data Protection Office (PDPO), which regulates data protection in Uganda.

12. Complaints Handling

If you believe your data protection rights have been violated, you may:

Contact our Data Protection Officer (DPO) at compliance@enwealth.co.ug.
Submit a complaint at our offices.
Lodge a complaint directly with NITA-U.

13. Cookies and Analytics

We use cookies and tools like Google Analytics to improve website performance, personalize your experience, and ensure security. You may disable cookies in your browser, but this may affect website functionality.

14. Marketing

We may send you updates and marketing information about our services. You may opt out anytime by using the unsubscribe option in our messages or by contacting us directly.

15. Processing Data of Minors

We do not knowingly collect data from children without guardian consent. Proof of age (such as a birth certificate) may be required before processing.

16. Updates to This Policy

This Privacy Policy was last updated in August 2024. Future updates will be published on our website, and significant changes may also be communicated directly to you.

17. Contact Us

For any queries or requests regarding your personal data, please contact:

Data Protection Officer
Enwealth Financial Services (UG) SMC Ltd
Maria House, Plot 13/14 Kataza Close, Bugolobi, Kampala
Tel: +256 786 891 300 | +256 702 736 237
Email: compliance@enwealth.co.ug
Website: https://enwealth.co.ug