Privacy Policy
Local Sustainable Communities Organisation (LOSCO) (“us”, “we”, or “our”) operates the https://www.loscoug.org website and Advocacy Strategies (hereinafter referred to as the “Service”).
This Document informs you of our policies regarding the collection, use and disclosure of personal data when execute our mandate and the choices you have associated with that data.
We use your data to provide and improve the Services. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings.
LOSCO adopts the necessary measures to protect the privacy of the data of her stakeholders, employees and business partners, having prepared this Privacy and Personal Data Protection Policy (“Privacy Policy”) with the purpose of demonstrating its commitment and respect for the rules of protection of personal data, thus complying with the principles of lawfulness, loyalty, transparency, purpose limitation, conservation, accuracy, and integrity confidentiality.
The Privacy Policy was prepared to inform the practical rules of protection of the personal data made available, seeking to clearly explain the requested personal identification information (“Personal Data”), as well as its use, management and disclosure.
We also intend to provide information about the exercise of the rights of access, rectification, cancellation and opposition to the treatment of your personal data, in accordance with the Data Protection and Privacy Act 2019.
Definitions
Service
Service means the https://www.loscoug.org website and Advocacy Strategies executed by LOSCO
Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small files stored on your device (computer or mobile device).
Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
PURPOSE OF THE INFORMATION COLLECTED AND ITS USE
The provision of personal data by clients, employees, and business partners (hereinafter referred to as “Holders”) implies the knowledge and acceptance of the conditions contained in this Privacy Policy. Thus, by making the personal data available, the holder is authorizing its collection, use and disclosure in accordance with the rules defined in the applicable data collection instruments and in this document.
The collection of personal data is done in writing, and may be in person or by e-mail and will include the name, contact details (address, telephone number, email address), legal data (tax number) and other contained in the independent formal statement subscribed by the holder.
By legislation, an organisation must provide all information requested by the competent authorities, in accordance with Ugandan laws. In each individual case, LOSCO will inform the holders of the mandatory nature of the provision of the personal data in question.
In certain cases, there is a need to assign personal data to third parties for them to provide services on our behalf. We will only share the information strictly necessary for the service provided with these entities, and they are prohibited from using it for any other purpose. These third parties will be obliged to comply with the rights and duties laid down in Data Protection and Privacy act 2019.
This information is covered through an agreement signed between LOSCO and these third parties or simply through a statement of responsibility.
Under no circumstances will the data collected be used for any purpose other than that for which the express consent of the holders was given.
LOSCO uses the collected data for various purposes:
- To provide and maintain our data base
- To notify you about changes to our Mandate
- To allow you to participate in interactive conversations when you choose to do so
- To provide Advocacy support and send out messages
- To gather analysis or valuable information so that we can execute our mandate.
- To monitor the Human Rights Situation and also Service Delivery
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other interventions, services and events which we offer that are similar to those that you have already enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), LOSCO legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
LOSCO may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- To comply with the law
DISCLOSURE OF PERSONAL DATA
Personal data, as described in this Privacy Policy, and authorized by the Holder in an independent formal statement, are disclosed (as applicable):
To third-party service providers;
To other entities to which it is necessary to provide the data to fulfill the purpose of the personal data processing.
Disclosure for Law Enforcement
Under certain circumstances, LOSCO may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
LOSCO may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of LOSCO
- To prevent or investigate possible wrongdoing in connection with LOSCO
- To protect the personal safety of beneficiaries of the organisation or the public
- To protect against legal liability
RETENTION OF PERSONAL DATA
In case, for legal reasons, it is necessary to retain the data for a certain period, the information should be kept and stored according to the purpose for which the information is processed.
LOSCO will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
LOSCO will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Organisation, or we are legally obligated to retain this data for longer periods.
We’ll keep this data in your LOSCO file until you decide to remove it or choose to have it removed.
We keep some data until you terminate your relationship with LOSCO, such as information about how often you work with LOSCO.
And some data we retain for longer periods of time when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping.
RESPONSIBILITY FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA
The entity responsible for the collection and processing of personal data is LOSCO.
Department managers should ensure that data collection processes are in line with the Privacy and Personal Data Protection Policy.
LOSCO employees have an obligation to ensure the confidentiality of personal data as an integral part of their professional duties and ensure compliance with the guidelines set out in the Privacy and Personal Data Protection Policy.
ACCESS, CORRECTION, DELETION OF PERSONAL DATA
According to applicable law, the holders have the right of access, correction and deletion of their personal data, as well as the right to limitation of processing, the portability of the data, the withdrawal of consent or opposition to the processing thereof, unless there are contractual, legal or regulatory provisions otherwise.
We recommend that you confirm and update your personal data whenever you deem it necessary.
In any of the mentioned situations the holder of personal data may send the request to the following address:
SECURITY MEASURES FOR THE PROTECTION OF PERSONAL DATA
LOSCO is committed to ensuring the protection and security of the personal data it was given access to, having designed for this purpose a technical and organizational Personal Data Protection Management System, in order to protect these same personal data against its loss, misuse, and unauthorized treatment or access, as well as against any other form of unlawful processing.
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Your Data Protection Rights under the Personal Data Protection Office (PDPO)
If you are a resident of the East African Community (EAC) you have certain data protection rights. LOSCO aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our records, please let us know for removal of any doubt.
INFORMATION LOSCO COLLECTS
LOSCO wants you to understand the types of information they collect as you work with them.
TYPES OF DATA COLLECTED
Personal Data
While executing our mandate, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, news briefs, advocacy campaigns and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
Usage Data
We may also collect information that your browser sends whenever you visit our Service or website/ social media or when you access the Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
Examples of cookies we use:
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
LOSCO collects information to provide better advocacy services to all beneficiaries and stakeholders — from figuring out basic stuff like which language you speak, to more complex things like which strategies you’ll find most useful, the people who matter most to you.
LOSCO also collects information that is store with your connection, which we treat as personal information.
LOSCO collects information about the services, which helps us provide suitable interventions and gender aspect of programming.
The information we collect includes names, phone numbers, location, business names, services, email addresses, Account numbers, TIN numbers, NSSF Numbers, Education Background, Service Numbers, Vehicle Numbers, NIN, Driving Permit Information among others as deemed necessary.
YOUR ACTIVITY
We collect information about your activity in our services. The activity information we collect may include:
If you use our services to make and receive calls or send and receive messages, we may collect call and message log information like your phone number, calling-party number, receiving-party number, forwarding numbers, sender and recipient email address, time and date of calls and messages, duration of calls, routing information, and types and volumes of calls and messages.
We collect information about your location when you use our services, which help us offer appropriate interventions on your general location.
In some circumstances, LOSCO also collects information about you from publicly accessible sources. For example, if your name appears in your local newspaper, LOSCO’s Search engine may index that article and display it to other people if they search for your name. We may also collect information about you from trusted partners, such as directory services who provide us with business information to be used for LOSCO services, partners who provide us with information about potential funders of our advocacy strategies, and security partners who provide us with information to protect against abuse. We also receive information from advertising partners to provide advertising and research services on their behalf.
WHY LOSCO COLLECTS DATA
- We use data to build better databases
We use the information we collect from all our services for the following purposes:
Develop new Strategies
We use the information we collect in existing strategies to help us develop new ones. For example, understanding how people organise advocacy campaigns.
We use the information we collect to make gender based interventions for you, including providing recommendations, personalized content, and direction.
Measure performance
We use data for analytics and measurement to understand how our services are used. For example, we analyze data about your visits to our sites to do things like improve our posts. And we also use data about the content you interact with to help stakeholders understand the performance of their support..
Communicate with you
We use information we collect, like your email address, to interact with you directly. We may let you know about upcoming changes or improvements to our Strategies. And if you contact LOSCO, we’ll keep a record of your request in order to help solve any issues you might be facing.
SHARING YOUR INFORMATION
Many of our services enable us share information with other people, and you have control over how we share. Remember, when we share information publicly, your data may become accessible through search engines.
When LOSCO shares your information
We do not share your personal information with companies, organizations, or individuals outside of LOSCO except in the following cases:
With your consent
We’ll share personal information outside of LOSCO when we have your consent. For example, if you use LOSCO for Advocacy purposes we’ll get your permission before sharing your name or phone number with the stakeholders. We’ll ask for your explicit consent to share any sensitive personal information.
For external processing
We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For example, we use service providers to help operate our meeting centers, deliver our materials and services, improve our internal business processes. We also use service providers to help review our online content for public safety and analyze to help improve LOSCO’s programming.
For legal reasons
We will share personal information outside of LOSCO if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:
Meet any applicable law, regulation, legal process, or enforceable governmental request. We share information about the number and type of requests we receive from governments in our Transparency Report.
Enforce applicable Terms of Service, including investigation of potential data breaches.
Detect, prevent, or otherwise address fraud, security, or technical issues.
Protect against harm to the rights, property or safety of LOSCO, our beneficiaries, staff, Board, or the public as required or permitted by law.
We may share non-personally identifiable information publicly and with our partners — like publishers, Funders, Partners, or rights holders. For example, we share information publicly to show trends about the general impact of our interventions. We also allow specific partners to collect information from our browser or device for Monitoring, References and measurement purposes.
If LOSCO is involved in a merger, acquisition, or sale of assets, we’ll continue to ensure the confidentiality of your personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.
KEEPING YOUR INFORMATION SECURE
We build security into our services to protect your information
All LOSCO online services are built with strong security features that continuously protect your information. And if we do detect something risky that we think you should know about, we’ll notify you and help guide you through steps to stay better protected.
We work hard to protect you and LOSCO from unauthorized access, alteration, disclosure, or destruction of information we hold, including:
We use encryption to keep your data private while in transit
We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems
We restrict access to personal information to LOSCO employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
EXPORTING & DELETING YOUR INFORMATION
You can export a copy of content in your LOSCO Account if you want to back it up or use it with a service outside of LOSCO.
To delete your information, you can:
Delete your content from specific LOSCO services and databases by asking the person in charge through a written request.
COMPLIANCE & COOPERATION WITH REGULATORS
We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.
DATA TRANSFERS
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. We maintain servers and your information may be processed on servers located outside of the country where LOSCO has it office. Data protection laws vary among countries, with some providing more protection than others provide. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks relating to the transfer of data.
If you are located outside Uganda and choose to provide information to us, please note that we transfer the data, including Personal Data, to Uganda and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
LOSCO will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
ABOUT THIS POLICY
When this policy applies
This Privacy Policy applies to all of the programs and services offered by LOSCO and its affiliates, including partners and funders. This Privacy Policy doesn’t apply to services that have separate privacy policies that do not incorporate this Privacy Policy.
This Privacy Policy doesn’t apply to:
The information practices of other companies and organizations that use our services
Services offered by other companies or individuals, including products or sites they offer that may include LOSCO services to which the policy applies, or products or sites displayed to you in search results, or linked from our services
Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
Links to Other Organisations/ Networks
Our Mandate may contain links to other networks that are not operated by us.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children’s Privacy
Our Mandate addresses anyone under the age of 18 (“Children”). LOSCO has a separate Child Protection Policy for the Beneficiaries under that age.
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our records unless it’s critical that we retain that information for Advocacy and Human Rights purposes.
IN CERTAIN CIRCUMSTANCES, YOU HAVE THE FOLLOWING DATA PROTECTION RIGHTS:
The right to access, update or delete the information we have on you.
Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification.
You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object.
You have the right to object to our processing of your Personal Data.
The right of restriction.
You have the right to request that we restrict the processing of your personal information.
The right to data portability.
You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
The right to withdraw consent.
You also have the right to withdraw your consent at any time where LOSCO relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
The holder of the personal data has the right to file a complaint with the National Data Protection Commission, the supervisory authority in Uganda (www.pdpo.org).
CHANGES TO THIS POLICY
We change this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We always indicate the date the last changes were published and we offer access to archived versions for your review. If changes are significant, we’ll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).