Privacy Policy

Introduction

Tuende (hereinafter referred to as “we,” “our,” or “Tuende”) is a technology platform under Startboom Digital that connects individuals, businesses, and institutions with various service providers, including waste collection companies, through our mobile application. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the Tuende mobile application, website, and related services (collectively, the “Services”).

Tuende acts as the data controller, determining the purposes and means of processing your personal information. We take your privacy seriously and are committed to complying with the Uganda Data Protection and Privacy Act, 2019, and the Data Protection and Privacy Regulations, 2021. In this Privacy Policy, “personal information” means any information that can identify you as an individual, including but not limited to your name, contact details, and identification numbers.

By using Tuende, you consent to the collection and use of your personal information in accordance with this Privacy Policy.

1. Information We Collect

1.1 Information You Provide Directly

When you use our Services, we may collect the following information that you provide directly:

Account Information: Name, phone number, email address, addresses and other locations like pick up and drop locations.

Identity Verification Information: To verify your identity, we may collect your national ID number or other government-issued identification details.

Payment Information: When you pay for services through the app, we collect necessary payment details (e.g., payment method, transaction amount, and date). We do not store your full bank card details.

Service Request Information: When you request a ride, delivery or waste collection or other services in the future, we collect the type (e.g., solid, recyclable, e-waste, package type etc), service address, preferred time, and any additional notes.

Communications: Information you provide when you contact our customer support team or communicate with other users through the app.

1.2 Information Collected Automatically

When you use our Services, we may automatically collect the following:

Location Data: We collect your real-time and historical location information to match you with nearby riders, vehicles and waste collection companies or service providers and to optimise service routes. You can control location permissions through your device settings.

Usage Data: We collect data on your interactions with the app, such as access times, frequency, pages viewed, and features used.

Cookies and Similar Technologies: We use cookies and similar tracking technologies to enhance your experience and analyse service usage.

1.3 Information from Third Parties

We may collect information about you from the following third-party sources:

Other services or platforms that you authorise to connect with us.

Publicly available sources.

When another user (e.g., a third party paying for your service) uses our Services in relation to you, we may collect necessary information about you.

1.4 Special Personal Data

Under the Uganda Data Protection and Privacy Act, 2019, special personal data includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data, health or medical records, sex life, and financial information. We generally do not actively collect special personal data unless:

You give explicit consent and provide such information;

It is required or authorised by law;

It is necessary for the exercise of rights or obligations conferred by law.

2. How We Use Your Information

We use your personal information for the following purposes:

2.1 To Provide and Improve Services

Matching your service requests with suitable vehicles requests waste collection companies or service providers;

Processing and confirming service requests, scheduling, and route planning;

Sending you service confirmations and reminders;

Improving our service quality, features, and user experience;

Conducting data analysis to identify usage patterns and trends.

2.2 Communication and Support

Responding to your inquiries, complaints, and feedback;

Sending you important notices (e.g., service changes, policy updates);

Sending you marketing and promotional information, subject to your consent.

2.3 Security and Compliance

Verifying your identity to prevent fraud and unauthorised access;

Detecting, investigating, and preventing fraud, misuse, or other illegal activities;

Complying with legal obligations and regulatory requirements;

Enforcing our Terms of Service and other policies.

2.4 Data Analytics and Reporting

Generating anonymised statistics and reports for cities, municipalities, and waste collection companies to assist with service planning and improvement;

Analysing rides / packages request patterns, service coverage, and operational efficiency.

Analysing waste generation patterns, service coverage, and operational efficiency.

To enable service matching and delivery, we may share your information with:

Vehicle owners: when you request a service through Tuende, we provide your name, contact detials, add

Waste Collection Companies and Service Providers: When you request a service through Tuende, we provide your name, contact details, service address, and service requirements to the relevant provider to complete the service.

Payment Service Providers: We share necessary payment information with third-party payment processors to handle transactions.

We may share anonymised aggregate data and statistical reports with cities and municipalities for waste management planning, service monitoring, and public policy development. These reports do not identify you personally.

3.3 Legal Disclosures

We may disclose your personal information in the following circumstances:

Required by law or regulatory authorities;

Necessary to protect the rights, property, or safety of Tuende, our users, or the public;

Necessary for the prevention, detection, investigation, or prosecution of crimes or unlawful activities.

3.4 Business Transfers

If Tuende or Startboom Digital is involved in a merger, acquisition, or asset sale, your personal information may be transferred as part of that transaction. We will notify you in advance and inform you of your options.

3.5 No Sale of Information

We do not sell, rent, or make available your personal information to unauthorised third parties.

4. Data Security

Tuende implements industry-standard technical, administrative, and physical security measures to protect your personal information from unauthorised access, use, alteration, or destruction. These measures include:

Encryption of data transmission (SSL/TLS protocols);

Secure server infrastructure and access controls;

Regular security assessments and vulnerability scans;

Employee data protection training and confidentiality obligations.

While we take reasonable precautions, please note that no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

5. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

The retention period depends on the type and purpose of the information:

Account Information: Retained while your account is active and for a reasonable period after closure;

Transaction Records: Retained for 5 to 7 years as required by law (e.g., anti-money laundering and tax regulations);

Location and Usage Data: Retained for as long as necessary to provide the Service, and then deleted upon your request or in accordance with our data purging policy;

Customer Support Records: Retained for six months after resolution of the issue.

After the retention period expires, we will securely delete or anonymise your personal information.

6. Your Rights

Under the Uganda Data Protection and Privacy Act, 2019, you, as a data subject, have the following rights:

6.1 Right of Access

You have the right to request confirmation of whether we hold your personal information and to obtain a copy of that information.

6.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information we hold about you.

6.3 Right to Erasure

You have the right to request deletion of your personal information, subject to legal limitations.

6.4 Right to Restriction of Processing

You have the right to request restriction of the processing of your personal information.

6.5 Right to Object

You have the right to object to the processing of your personal information, particularly in certain circumstances such as direct marketing.

6.6 Right to Data Portability

Where applicable, you have the right to receive your personal data in a commonly used format.

You have the right to withdraw your consent to our processing of your personal information at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

How to Exercise Your Rights

To exercise any of the above rights, please contact us using the details below:

Email: info@tuendeapp.com

Phone: +256763080035

Mail: Plot 4 Wampewo Avenue Kololo Kampala Uganda

We will respond to your request within the timeframe required by law (usually within 30 days).

7. Children’s Privacy

Tuende does not direct its Services to children under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child without parental or guardian consent, we will take steps to delete that information promptly.

8. International Data Transfers

Tuende primarily stores data within Uganda. If we need to transfer your personal information outside Uganda, we will ensure that adequate safeguards, equivalent to the level of protection under the Data Protection and Privacy Act, 2019, are implemented, and we will obtain your explicit consent.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make significant changes, we will notify you through:

A notice within the application;

An email to your registered address;

Providing a reasonable review period before the changes take effect.

We encourage you to review this Privacy Policy periodically for the latest information.

10. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy, or wish to exercise your data protection rights, please contact us:

Tuende Data Protection Office

(a division of Startboom Digital)