Privacy Policy

Updated on August 12, 2023

1. Introduction

This privacy policy ("Privacy Policy") covers how TerraGo Real Estate Limited ("TerraGo") handles personal information on the TerraGo app, website, software, and related services (collectively known as the "Websites"). This policy is linked to or referred to across our Websites.

Your personal privacy and the privacy of your data is paramount to us at TerraGo.

This Privacy Policy is designed to explain how we ensure your privacy and data protection.

2. Privacy Bill of Rights

We are uncompromising about trust, respect and integrity.

  1. You own your personal information and content. It is explicitly not ours.
  2. We do not sell your personal information.
  3. Your facial identity is your business; we do not use facial recognition technology.
  4. We do not use cookies or other tracking technologies on our Websites.
  5. You will not receive targeted advertisements or targeted third-party content.
  6. Permissions and privacy are your rights; you control them.
  7. You have the right to delete your account.
  8. We have certification from the Personal Data Protection Office of Uganda. Contact us for a copy of the certificate.

3. What Information We Collect

We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. Here are the details:

A. INFORMATION YOU PROVIDE

i. Profile Information. We collect information that you provide when you register for any of our services, such as your date of birth, full name(s), government-issued identity number (such as National Identity [NID], passport number, driving license number, etc.) mobile numbers, address, and login pin. We also collect additional information in the form of photographs submitted by you of your self (selfie), and the front and rear of your government-issued identity document.

ii. Your Contacts. We collect information about your next-of-kin or nominee. If we cannot reach you regarding the Land Sale Agreement, we use this information to contact your chosen next-of-kin.

iii. Information When You Contact Us. When you contact us, we collect the information you send us, such as proof of identity, alternate contact number(s), email address(es), social media IDs/handles, feedback or inquiries about the Websites or information about possible violations of our Terms of Service (our “Terms”), Land Sale Agreement on an Equated Instalment Payment Plan (our “Land Sale Agreement”), or other policies.

B. AUTOMATICALLY COLLECTED INFORMATION

i. Technical Information. We may collect your browser version when you access the Websites.

ii. Location Information. We do NOT collect location information.

iii. Cookies. We do NOT use cookies or similar tracking technologies.

C. INFORMATION FROM OTHER SOURCES

i. Third Party Websites and Partners. We receive logistical support from third-party Websites for hosting, authentication, data storage, marketing, and usage monitoring. Our partners have strict measures in place to protect your privacy. We ensure that our service providers limit Personal Identifiable Information (PII).

ii. Payment Integrators and Telecommunication Service Providers. We may receive information from our payment integration partners and telecom providers in order to verify your mobile money wallet registration information, identity and related data.

iii. Others. We may receive information about you from other sources, such as when you are mentioned in a complaint, appeal, request, or feedback, or when a user, law enforcement, or third party provides your contact information to us.

4. How We Use Your Information

We use your data to run, improve, and expand our Websites. Here's how we use it:

  • We help you apply for a plot of land, finalize a land sale agreement, and make payments for the plot(s).
  • You can use our websites or mobile apps (please see the "Terms & Conditions").
  • We process any requests related to our products and services.
  • We make sure our Terms & Conditions, Land Sale Agreement, Privacy Policy, and other policies are followed.
  • We work on making our Websites safer, more secure, and stable by identifying and fixing technical or security issues (like technical glitches, spam accounts, and detecting abuse, fraud, and illegal activity).
  • We promote the Websites through marketing communications.
  • We meet our legal obligations, perform tasks in the public interest, or protect the vital interests of our users and other people.

5. Sharing Your Information

A. WITH SERVICE PROVIDERS

We work with service providers that help us provide, support, and develop the Websites and understand how it is used. They provide services such as cloud hosting, content delivery, customer and technical support, identity verification, marketing, analytics, text messaging services, online payment, and mobile money services. We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as needed so they can provide their services.

B. WITH PARTNERS

i. Third-Party Websites and Partners. We share limited information, which may include Information You Provide, Technical Information, and Usage Information with third-party Websites and partners whose Websites or services are integrated with the Websites. We do this to give you a seamless experience, access your account anywhere with internet, and enable us to authenticate users.

ii. Marketing. Some partners use aggregated and non-personalized information to deliver our marketing campaigns to the right set of potential users.

iii. Measurement and Data Partners. We also share Technical Information and Usage Information with third party measurement providers. They help us measure advertising served on the Websites and help our advertisers determine how effective their ads have been.

C. WITH OUR HEAD OFFICE

The Websites are supported by certain entities (“employees”, “agents”, “partners”) within or in cooperation with our corporate office. These entities process Information You Provide, Automatically Collected Information, and Information From Other Sources for us as necessary to provide essential functions, such as verification, account approval, consent to the Land Sale Agreement, collections, storage, content delivery, security, research and development, analytics, payments, customer and technical support, and related activities.

D. WITH OTHERS

We share your information in other limited scenarios as follows:

i. Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control, or acquisition of all or a portion of our business.

ii. Legal Obligations and Rights. We may access, preserve, and share the information described in "What Information We Collect" with law enforcement agencies, public authorities, or other third parties if we believe in good faith that it is necessary to:

  • comply with applicable law, legal process or government requests,
  • protect the rights, property, and safety of our users, shareholders, and others, including protecting life or preventing imminent bodily harm. For example, we may provide information (such as your contact information) to law enforcement in an emergency situation where someone’s life or safety is at risk,
  • investigate potential violations of and enforce our Terms, Land Sale Agreement, Privacy Policy or any other applicable terms, policies, or standards, or
  • detect, investigate, prevent, or address misleading activity, fraud, or other illegal activity.

6. Our Legal Bases and How We Process Your Information

We only use your information when we have a “legal basis” or lawful reason to do so. We use different legal bases depending on why we use your information (in other words, the “purpose” of our processing). These legal bases are contractual necessity, legitimate interests (ours, yours or those of another party), consent, compliance with a legal obligation, performing a task in public interest, and protection of vital interests.

In the subsequent points, we explain the legal bases we rely on when we process your information. We also explain why and how we use your data, what categories of data are involved, and what rights you have (which always includes the right to access your data). For more details on how to exercise any of your rights, please look at the “Your Rights and Choices” section.

7. CONTRACTUAL NECESSITY

We use Information You Provide, Automatically Collected Information, and Information From Other Sources where it is necessary to perform the contract you enter into (our Terms) when you register for, access, or use the Websites. This means we use your information to:

  • Provide you with the Websites. We use your information to allow you to access and use the Websites, including allowing you to contact our support services, and provide you with products and services you wish to access. We also use your information to enter into a digital contract with you (refer the “Land Sale Agreement”).
  • Enforce our Terms, Land Sale Agreement, or policies. We use your information to enforce our Terms, Land Sale Agreement, and policies. This may include removing uploaded information (including through automated means) or suspending or banning your account if we determine that you are violating our Terms or Land Sale Agreement.
  • Administer the Websites. We also use the information we have to administer the Websites, such as to communicate with you about service-related matters and respond to your queries (including when you tell us about a problem or ask for a copy of your information).

Your Rights: Whenever we use your information because it is necessary for the contract or agreement we have with you, you have the right to update the information you have provided to us.

8. LEGITIMATE INTERESTS

We use your information where this is necessary to achieve legitimate interests - whether belonging to us, you, or a third party - provided these interests are not outweighed by your interests or fundamental rights. We use the information we collect to:

A. ENSURE THE SAFETY OF OUR SERVICES AND PRODUCTS (REFER “LAND SALE AGREEMENT”).

  • We use your information to ensure the safety our real estate product by reviewing for breaches of our Terms, Land Sale Agreement, and other policies. Sometimes, we may ask you to provide additional information to confirm your identity.
  • Legitimate Interest relied upon: To keep our community safe, review compliance with our Terms, Land Sale Agreement, and other policies, and identify misuse of the Websites.
  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

B. ENSURE THE SECURITY AND STABILITY OF THE WEBSITES.

  • We use your information to ensure the stability and security of the Websites. This includes identifying and dealing with technical or security issues (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).
  • Legitimate Interest relied upon: To ensure the ongoing stability and security of the Websites and to ensure it is continuously available and functioning.
  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

C. EVALUATE, ENHANCE, PROMOTE AND DEVELOP THE WEBSITES.

  • We use the information we have to understand how people are using the Websites and to develop and improve the Websites. This includes training, developing, and improving our technology such as our machine learning models and algorithms. We also use this information to better understand and promote the Websites, popular features, and emerging trends.
  • Legitimate Interest relied upon: To improve, promote, and develop the Websites in an informed way.
  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

D. SHARE YOUR INFORMATION WITH THIRD PARTIES.

  • We share your information with third parties whose Websites or services are integrated with the Websites.
  • Legitimate Interest relied upon: : To provide you with login authentication, secure access to your content, enable payments, and optimise user experience.
  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Your Rights: Whenever we use your information on the basis that it is necessary for legitimate interests, you can request clarification on such usage.

9. Your Consent

We ask for your consent to access or use your information for specific purposes. If we do, you’ll always be able to revoke your consent through your device browser permissions or in-app settings. It is important to understand that when you revoke certain permissions, we may not be able to provide you access to our products and/or services, as the case may be.

A. COMPLIANCE WITH A LEGAL OBLIGATION

We may use your information including your Profile Information or User Content where it is necessary to comply with a legal obligation. This includes situations where we have obligations to take measures to comply with terms of the licensing authority in the country or comply with a valid legal request such as an order from law enforcement agencies or courts. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.

B. TO PERFORM A TASK IN THE PUBLIC INTEREST

We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding our financial accounts, and promoting public safety, security, and integrity as laid down by applicable law. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.

C. TO PROTECT SOMEONE'S VITAL INTERESTS

We may use your information where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. We generally provide Information You Provide and Automatically Collected Information, although it depends on the specific situation.

10. Your Rights and Choices

a. You have rights and choices when it comes to your information. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations. TerraGo will be responsible for responding to your request within the confines of the law.

b. Accessing your information. You can ask us to confirm what information we process about you, to provide certain information about the processing, and for a copy of your information.

c. Deleting your information. You can delete or ask us to delete some or all of your information. This request might not be fulfilled if your information is needed to meet our administrative, legal or regulatory obligations.

d. Rectifying your information. You can modify your information or ask us to do so if it is not accurate. You can make many of these changes through the in-app controls and settings.

e. Objecting to information processing. You also have the right to object to the processing of your information in certain circumstances. This right applies when we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. In submitting an objection request, please provide all relevant information, including the processing activity you are objecting to, why you want to object and how the processing activity affects you, and any additional information that you think will help us review your request. We will stop the particular processing if we don't have compelling legitimate grounds to continue that processing or don’t need it for legal claims.

f. Restricting information processing. You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.

g. Exercising your rights. To exercise any of the above rights, please contact us. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details or provide additional information so that we can understand your request.

We encourage you to “Contact us” if you are not satisfied with how we have responded to any of your rights requests. You also have the right to complain to the PERSONAL DATA PROTECTION OFFICE | PDPO OF UGANDA, which is TerraGo’s data protection supervisory authority in Uganda.

11. How We Keep Your Information Safe and For How Long

We believe that your information is valuable and needs to be protected. To ensure this, we use various safety measures including technology and procedures that are designed to safeguard your information from unauthorized access, theft, exposure, changes, or loss. We always keep an eye on new technology and methods that can help us improve our security measures.

We retain information for as long as necessary to provide the Websites and for the other purposes set out in this Privacy Policy. We also retain information to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Websites, and enhancing its safety, security and stability), and for the exercise or defence of legal claims.

The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Websites, we keep this information for as long as you have an account. This information includes your Profile Information, Identity Information, and Transactional Information. If you violate our Land Sale Agreement, Terms, or policies, we may remove your Profile Information and/or User Content from third-party view immediately but keep your information as is necessary to process the violation.

12. Our Operations and Data Transfers

We store the information described in "What Information We Collect" in secure servers operated by Amazon Web Services (AWS).

Certain entities (“Employees”, “Agents”, “Partners”), located in or outside your country of residence, are given limited remote access to this information so they can provide certain functions, as described in the Our Head Office section in "How We Share Your Information". This access is limited, secure and only granted where necessary under strict security controls and authorization approval protocols.

We share "What Information We Collect" with service providers, partners and other third party entities, as described in "How We Share Your Information". These third parties may or may not be located outside your country of residence. These entities commit to processing information in compliance with applicable privacy laws and to implementing appropriate security measures to protect your information.

13. Security

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of your personal user data and other information transmitted to us. For instance, we encrypt your personally identifiable information (PII), and most, if not all requests from you to the server are made over a secure connection (HTTPS).

However, no data transmission over the Internet or other network can be guaranteed to be 100% (one hundred percent) secure.

14. Younger Users

You must be at least 18 (eighteen) years old to use the Websites. If you believe that there is a User who is below this minimum age, please contact us using the details set out in the “Contact Us” section below.

15. Changes to This Privacy Policy

We may amend or update this Privacy Policy from time to time. We will notify you of any material changes to this policy by a notice provided through the Websites or by other means. The “Last Updated” date at the top of this policy reflects the effective date of such policy changes.

16. Contact Us

If you have questions about this Privacy Policy, you can reach us by:

  • Calling our support team at: +256-747-350-077
  • Sending a text to our support team via WhatsApp at: +256-747-350-077
  • Emailing our support team at: [email protected]