PRIVACY AND DATA PROTECTION POLICY

This privacy policy provides information on the processing of the personal data of our Users, job applicants, social media Users who interact with Yo-Uganda Limited (“Yo!”) and users of the contact form on our website, as provided in the DATA PROTECTION AND PRIVACY ACT, 2019 (“the Act”).

1.    PROCESSING OF DATA OF USERS AND PERSONS WHO CONTACT YO!!

1.1    Data Processed

1.1.1    Information supplied directly by Users:

1.1.1.1    Data: the information which is processed by equipment operating automatically in response to specific instructions, information that is recorded as part of our technical systems.

1.1.1.2    Personal Data: the information about a person from which the person can be identified such as; nationality, age, marital status, educational level, occupation and identity data

1.1.1.3    Registration Data: the information provided by Users when they create an account on the Yo! Platforms: username and e-mail.

1.1.1.4    User Profile Information: the information added by Users on the platforms in order to be able to use the Yo! services; i.e., their mobile phone number and other information. Users can view and edit the personal data on their profile whenever they wish. Users may request this and other affiliated  providers’ privacy policies at any time.

1.1.1.5    Additional information that Users wish to share: any information that a User could supply to Yo! for other purposes. Examples include a photograph of the User or the billing address in the case of Users who have asked to receive invoices from Yo!.

1.1.1.6    Information about previous communications with Yo!: Yo! will have access to the information supplied by Users for the resolution of any queries or complaints about the use of the platforms, whether through the contact form, by e-mail or by phone through the customer service.

1.1.1.7    Transcription and recording of conversations held between the USER and Yo! for the processing of incidents, queries or any other consultations that may be made.

1.1.1.8    Information on Communications between Users and Mandataries: Yo! will have access to the communications exchanged between Users and the Mandatories that collaborate with the Platforms by means of the chat system provided on the Platforms.

1.1.2    Information indirectly supplied by Users:

1.1.2.1    Data arising from the Use of the Platforms: Yo! collects the data arising from Users’ Use of the Platforms every time they interact with the Platforms.

1.1.2.2    Data on the application and the device: Yo! stores data on the device and the Application used by Users to access the services. This data is:

1.1.2.2.1    The IP address used by each User to connect to the Internet using his/her computer or mobile phone.

1.1.2.2.2    Information about his/her computer or mobile phone, such as his/her Internet connection, browser type, version and operating system, and type of device.

1.1.2.2.3    The full uniform resource locator (URL) Clickstream, including date and time.

1.1.2.2.4    Data from the User’s account: information on the instructions made by each User, as well as feedback and/or comments made about them by such User.

1.1.2.3    Data arising from the User’s origin: if a User arrives at the Yo! Platformss through an external source (such as a link from another website or a social network), Yo! collects data on the source from which the Yo! User arrived.

1.1.2.4    Data resulting from the management of incidents: if a User contacts the Yo! Platforms through the Contact Form or on Yo!’s phone number, Yo! will collect the messages received in the format used by the User and may use and store them to manage current or future incidents.

1.1.2.5    Data arising from “cookies”: Yo! uses its own and third-party cookies to facilitate browsing by its users and for statistical purposes (see the Cookie Policy).

1.1.2.6    Data resulting from external third parties: Yo! may collect personal data or information from external third parties only if the User authorises such third parties to share that information with Yo!.

1.1.3    Similarly, if a user accesses Yo! through products and services offered by Google, Google may send the User’s browsing data to Yo!, with access to the platforms through the links created by Google.

1.1.4    The information provided by the external third party may be controlled by the User in accordance with the third party’s own privacy policy.

1.1.4.1    Geolocation Data: provided that this has been authorised by Users, Yo! will collect data relating to their location, including the real-time geographic location of their computer or mobile device.

1.2    Purpose

1.2.1    To use the Yo! Platformss

Yo! uses the data collected from Users to enable them to access and communicate with the Yo! platforms and to provide the services requested by them through their account on the Yo! Platforms, in accordance with the procedure described in the “Terms of Use”.

1.2.2    To send communications
Yo! uses Users’ personal data to communicate via e-mail and/or send them SMS messages relating to the operation of the services where needed.

1.2.3    To detect and investigate fraud and possible criminal offences

1.2.3.1    Yo! also uses the information to research and analyse how to improve the services it provides to Users, as well to develop and improve the features of the service it offers. Internally, Yo! uses the information for statistical purposes in order to analyse User behaviour and trends, to understand how Users use the Yo! Platforms and to manage and improve the services offered, including the possibility of adding new, different services to the Platforms.

1.2.3.2    Yo! may monitor all actions that could result in fraud or in the commission of a criminal offence relating to the means of payment employed by users. In any event data will be processed by Yo! for the sole purpose of fulfilling its fraud prevention and monitoring functions, and it shall be stored for as long as its relationship with the user concerned remains in forcé and for such time as may be reasonable neccessary to retain the information,

1.2.3.3    Yo! reserves the right to retain the data provided and to share it with the competent authorities in order to carry out the relevant investigation. Yo! may share the data with the authorities based on the legal obligation to prosecute conducts that are contrary to the applicable law.

1.2.4    To comply with the legislation and bring and defend legal actions
Yo! informs the user that conversations with the Mandatary using the chat system may be reviewed and used by Yo! for the purpose of filing and/or defending any claims and/or legal actions that may be necessary.

1.2.5    Promotion and commercial offers

Yo! may use third-party technology integrated in its Platforms for the purpose of collecting Users’ data and preferences and using this with CRM systems and advanced technology for the benefit of Users. The following processing will thus be carried out on their data through the information collected:

1.2.5.1    Yo! may send e-mails with promotional messages and/or offers relating to the service offered by it that may be of interest to Users. Yo! may gauge and personalise such advertising in accordance with its Users’ preferences. If a Yo! User does not wish to receive this information and/or commercial communications, he/she may at any time opt to “Unsubscribe” in the e-mail, and Yo! will immediately stop sending the aforementioned information.

1.2.5.2    Yo! may also send Users messages and/or offers relating to such services through “push” notifications consisting of sending such promotional messages and/or offers to their mobile phones. If a Yo! User does not wish to receive the commercial communications described in this clause and in 3.1 above, he/she may remove them all by disabling them with a single click in the privacy preferences of his/her profile.

1.2.5.3    As a result of using the Yo! Platforms, Users may also receive commercial communications from third parties associated with the Platforms, such as Facebook and Google, all this in accordance with the privacy preferences set by each User on the said Platformss.

1.2.6    For statistical and service analysis purposes

1.2.6.1    Yo! may use the information for statistical purposes in order to analyse User behaviour and trends, to understand how Users use the Yo! Platforms and to manage and improve the services offered, including the possibility of adding new, different services to the Platforms.

1.2.6.2    Yo! also uses the information to research and analyse how to improve the services it provides to Users, as well to develop and improve the features of the service it offers.

1.3    Legal Basis of Processing
Users’ data is processed in accordance with the following legal bases:

1.3.1    To perform the contractual relationship following Users’ registration on the Platforms

1.3.2    On the basis of our own legitimate interest (such as monitoring for the prevention of fraud through the Platforms).

1.3.3     To fulfil our legal obligations (such as when competent authorities request data in connection with court investigations and/or with the filing of the necessary actions to protect Yo!’s interests.

1.4    Recipients of the Data

1.4.1    Yo! warrants that all commercial partners, technicians, suppliers or independent third parties are bound by contractually binding promises to process the information shared with them in accordance with Yo!’s indications, this Privacy Policy and the applicable data protection legislation.

1.4.2    We will not disclose your personal data to any third party who does not act under our instructions, and no communication will involve selling, renting, sharing or in any other way revealing customers’ personal information for commercial purposes in breach of the commitments made in this Privacy Policy.

1.4.3    When carrying out an order, data may be shared with:

1.4.3.1    The Mandatory who carries out the task of collecting and delivering the product.

1.4.3.2    The Customer Care Services contracted by Yo! for the purpose of warning the User of any possible incidents or asking why negative feedback has been given for the service. Yo! may use the data provided in order to manage any incidents that may occur during the provision of the services.

1.4.3.3    The payment Platforms and payment service providers so that the amount can be charged to the User’s account.

1.4.3.4    Providers rendering satisfaction survey services on Yo!’s behalf.

1.4.4    Sharing User data with third parties
In order to continue providing the services offered through the Platforms, Yo! may share certain personal data of Users with:

1.4.4.1    Service providers includingbut not limited to Financial Institutions, Mobile Network Operators, Datacenter Providers: Yo!’s third-party service providers may have access to Users’ personal information as may be necessary to carry out their functions, but they may not use it for any other purposes. They must process the said personal information as provided in this Privacy Policy and in the applicable data protection legislation.

1.4.4.2    Service providers for fraud control purposes: Yo! will share Users’ data with fraud control service providers to assess the risk of the transactions carried out.

1.4.4.3    Security companies and Law Enforcement Forces and Agencies: Yo! may disclose personal information and data on its customers’ accounts if it believes that such disclosure is necessary to comply with the law, to enforce or apply the “Terms of Use” or to protect Yo!’s, its users’ or third parties’ rights, property or safety. The above therefore includes the exchange of information with other companies and organisations as well as with Law Enforcement Forces and Agencies to protect against fraud and reduce credit risk. After being required to do so by law, Yo! may share information with bodies of executive authorities and/or third parties in relation to requests for information relating to criminal investigations and alleged illegal activities.

1.4.4.4    Call centre and incident management services: In order to provide a Customer Service and call centres, actions to measure Users’ degree of satisfaction and the provision of administrative support services, Yo! may disclose Users’ data to companies located outside the Uganda, provided it is authorised to do so and the security requirements mentioned in the preceding section have been met.

1.4.4.5    Telecommunications services: In order to be able to provide Users with telephone contact services, Yo! may contact telecommunications companies that provide secure lines and systems for the purpose of contacting Users.

1.4.4.6    Changes of ownership: If Yo!’s ownership changes or the majority of its assets are acquired by a third party, Users are informed that Yo! will transfer their data to the acquiring organisations in order to continue to provide the services subject to the processing of data. The new file controller will inform Users of its identification data. Yo! states that it will comply with its duty of information to the relevant Supervisory Authority in the event of such circumstances arising, and it shall inform Users of the change of file controller if and when this happens. This processing shall be carried out under the contract entered into with Yo!.

1.4.4.7    Insurance companies: Yo! may provide users’ data to those insurers and insurance brokers with which it has an agreement in place for the management and processing of claims and losses arising from the activity carried out by Yo! and the parties that collaborate with it.

1.4.5    Yo! Users’ data will not be disclosed to any third parties unless: (i) this is necessary in order to provide the services requested if Yo! is collaborating with third parties; (ii) if Yo! has the User’s express and unambiguous authorisation; (iii) where this has been requested by a competent authority pursuant to its functions (in order to investigate, prevent or take action in relation to illegal actions); or (iv) finally, where required by law.

1.4.6    Yo! shall within a reasonable time stop the collection and processing of personal data upon objection by a User.

1.4.7    Yo! shall not collect or process special personal data relating to the religious, philosophical beliefs, political opinión, sexual life, financial informations, health status or medical records of a User.

1.5    Processing the Data of Job Applicants who Contact Yo! Using the Forms in the Yo! Jobs Section
These provisions shall apply to those persons who contact Yo! through its website for the purpose of applying for an available position (“Applicants”).

1.5.1    Legal Basis for Processing

Before submitting their application, Applicants must consent to the processing of their data, expressly agreeing to everything set forth in this Privacy Policy. Yo! may also process their data for the purpose of considering the possibility of establishing a contractual relationship and in view of the fact that such consideration was requested by the Applicants themselves.

1.5.2    Data Protection officer; The following are details of Yo!’s data protection officer.

Name: SCHOLAH AMURON (OPERATIONS MANAGER)
Postal address: P. O. BOX 27105, KAMPALA
Contact e-mail address: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

1.6    International Data Transfers

When choosing service providers, Yo! may transfer users’ data outside the local borders. In such cases, Yo! will ensure before sending the data that such service providers are in compliance with the minimum security standards established by the National Information Technology Authority and that they always process the data in accordance with Yo!’s instructions. Yo! may have a contractual relationship with them under which the service providers agree to comply with Yo!’s instructions and to put in place the necessary security measures to protect Users’ data.

1.7    Collection and Retention

1.7.1    The User’s data will not be retained for a perid longer than is necessary to achieve the purpose for which the data is collected unless such retention is authorized by the applicable law and/or is necessary for a lawfuly purposes.

1.7.2    Users’ data will be retained during the performance and maintenance of the contractual relationship; i.e. for as long as they are Yo! Users or until they exercise their right to restrict the processing of their data.

1.7.3    Once a User has cancelled his or her registration with the Platforms, Yo! will keep his or her data for the time established in the tax, health, criminal and any other legislation that may apply, for the purpose of filing and defending any actions to which Yo! may be a party. Yo! will in any event block Users’ data so that it can only be consulted if an action has to be filed or defended in connection with it.

1.7.4    Yo! shall not collect or process personal data relating to children under the are of 18 unless such collection is required by aplicable law ori s carried out with the prior consent of the parent or guardian of the child.

1.7.5    Yo! shall ensure that the collection, holding or processing of the data does not infringe on the privacy of the User.

1.7.6    Yo! shall not disclose the User’s data unless required by law or in the course of discharge of a duty.

1.8    Correction of Data

1.8.1    A User may request Yo! to correcto or delete their personal data in the evento that such personal data is innacurate, irrelevant, excessive, outdated, incomplete, misleading or unlawfully obtained.

1.8.2    A User may request Yo to destroy or delete the data where the User resoanble believes that Yo! no longer has legal authority to retain the data.

1.8.3    Upon receipt of such request, Yo shall either; comply with the request, inform the User of the failure to coomply with the request, but shall in all cases notify the user of the action taken following the request.

2.    EXERCISE OF RIGHTS

2.1    Users may exercise their rights free of charge at any time using the form available on the Platforms. They may also exercise their rights by sending an e-mail to the following e-mail address: This e-mail address is being protected from spambots. You need JavaScript enabled to view it . The e-mail must specify which right they wish to exercise, as well as, where applicable, the identifying data registered on the Platforms. We will contact the User if we need additional data to that provided in order to verify his or her identity.

2.2    You may exercise the following rights vis-à-vis Yo!:

2.2.1    The right of access to your personal data in order to know which data is being processed and the processing operations carried out thereon;

2.2.2    The right to correct any inaccuracies in relation to your personal data;

2.2.3    The right to the erasure of your personal data, where possible;

2.2.4    The right to request the restriction of processing of your personal data when the accuracy, legality or need for processing of the data is in question, in which case we may retain the data for the purpose of filing or defending claims.

2.2.5    If you believe that Yo! is in breach of data protection law, please do not hesitate to contact us at the e-mail address This e-mail address is being protected from spambots. You need JavaScript enabled to view it telling us what you consider to be the case, so that we can resolve the problem as soon as possible. In any event, you may also report it to the Data Protection Officer.

2.2.6    Yo! Uganda shall at all times endeavor to respond to any requests within the timelines imposed by applicable law or where no time is prescribed by law, within reasonable time.

3.    SECURITY MEASURES

3.1    Yo! has taken the necessary steps recommended by NITA-U and the competent authority to maintain the required security level, according to the nature of the personal data processed and the circumstances of the processing, in order to avoid, to the extent possible and always in accordance with the state of the art, its alteration, loss or unauthorised access or processing. As mentioned above, the personal data supplied will not be disclosed to third parties without the data subject’s prior consent.

4.    NOTIFICATIONS AND MODIFICATIONS

4.1    As stated above, all Users have the right to access, update and erase their data, as well as object to its processing. You may exercise these rights, or make any enquiries in relation to Yo!’s Privacy Policy, through the Contact Form.

4.2    Due to the constant evolution of Yo!’s activities, this Privacy Policy, the Cookie Policy and the Terms of Use are also subject to change. Yo! will send Users notifications about substantial changes and modifications to such documents by e-mail or through any other method that ensures their receipt. In any case, Yo! will in no event modify its policies or practices to make them less effective in the protection of our customers’ previously stored personal data.