1. Data Controller and Contact Information
The data controller responsible for your personal information is:
Empacode Africa Limited
Email: info@empacode.com
Address: Kampala, Uganda
2. Information We Collect
We collect information to provide and improve the services offered by Ubora AI, which focuses on providing AI-driven market validation and innovation guidance for African ideas.
A. Information You Provide Directly
When you register for or use the App, you voluntarily provide us with the following personal data:
- Account Registration Data:
- Full Name
- Email Address
- Phone Number (Tel)
- Password (stored securely using one-way cryptographic hashing)
- User Content Data (Idea Validation):
- Any textual or structured data you submit to the AI model for analysis, including business ideas, market concepts, validation questions, and input parameters.
B. Information Collected Automatically
When you access and use the App, we automatically collect certain technical and usage data:
- Usage Data: Information about how you use the App, such as the features you access, the time and date of your activity, and the frequency and duration of your submissions.
- Device Data: Information about the device you use to access the App, including device model, operating system version, unique device identifiers (e.g., Advertising ID), and mobile network information.
- Log Data: Server logs may include your IP address, browser type, and time zone settings.
3. How We Use Your Information
We use the collected information for the following purposes:
- Service Provision: To create and manage your user account, verify your identity, and provide you with access to the AI validation tools and features of the App.
- Idea Validation and Improvement:
- To process the ideas and data you submit through the App to generate validation reports and insights.
- To improve the accuracy, relevance, and performance of the underlying AI models (Note: Any data used for model training will be anonymized or aggregated where necessary to protect individual privacy).
- Communication: To send you technical notices, updates, security alerts, and support messages, as well as marketing or promotional communications (where you have opted in).
- Security and Fraud Prevention: To protect the App, our users, and Empacode Africa Limited from fraudulent or illegal activities.
- Analytics and Research: To monitor and analyze trends, usage, and activities in connection with the App to enhance functionality and user experience.
4. Legal Basis for Processing
(If Applicable to GDPR/International Law)
We process personal data only when we have a valid legal basis, including:
- Contractual Necessity: The processing is necessary for the performance of the contract to provide the Ubora AI services to you.
- Legitimate Interests: The processing is necessary for our legitimate interests (e.g., security, fraud prevention, improving services), provided these interests do not override your rights.
- Consent: Where required by law, we will rely on your consent, which you can withdraw at any time.
5. Disclosure of Your Information
We may share your information only in the following limited circumstances:
- Service Providers: We engage third-party companies to facilitate our services (e.g., cloud hosting, database management, email delivery). These providers only have access to the information necessary to perform their functions and are bound by contractual confidentiality obligations.
- Legal Compliance and Protection: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to comply with legal obligations, protect and defend the rights or property of Empacode Africa Limited, or protect the personal safety of users or the public.
- Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity.
- Anonymized Data: We may share aggregated or de-identified data (which cannot be linked back to you) with third parties for research, advertising, or analysis.
6. Data Security
We implement appropriate technical and organizational measures designed to protect your personal data from accidental loss and unauthorized access, use, alteration, or disclosure. These measures include:
- Data Encryption: Encrypting sensitive data both in transit (using SSL/TLS) and at rest (using industry-standard encryption).
- Access Control: Limiting access to your personal data to authorized employees and contractors who need that information to operate, develop, or improve our services.
- Password Hashing: Storing passwords using secure, non-reversible cryptographic hashing algorithms.
7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
If you delete your account, your personal data will be deleted or anonymized within a reasonable period, except where retention is required by law.
8. Your Data Protection Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data:
- Right to Access: The right to request copies of your personal data.
- Right to Rectification: The right to request that we correct any information you believe is inaccurate or incomplete.
- Right to Erasure ('Right to be Forgotten'): The right to request that we erase your personal data under certain conditions.
- Right to Restrict Processing: The right to request that we restrict the processing of your personal data, under certain conditions.
- Right to Object to Processing: The right to object to our processing of your personal data, under certain conditions.
To exercise any of these rights, please contact us using the information provided in Section 1.
9. Children's Privacy
The App is not intended for use by individuals under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from children. If you are a parent or guardian and you become aware that your child has provided us with personal information, please contact us so that we can take necessary actions to remove that information from our servers.
10. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy in the App and updating the "Effective Date" at the top of this policy. You are advised to review this Privacy Policy periodically for any changes.
11. Governing Law
This Privacy Policy is governed by the laws of Uganda.