Purly

Privacy Policy

This is a placeholder, not a privacy policy. It sets out the sections a Uganda DPPA-compliant policy needs to cover. No section has been drafted yet, and nothing on this page states how Purly actually handles data. The policy will be professionally drafted and reviewed before Purly handles any real user data. Do not rely on this page.

1. Data controller

To be drafted. Identify the entity responsible for the data, its registration details, and how it can be contacted — including whether it is registered with the Personal Data Protection Office.

2. What personal data is collected

To be drafted. Enumerate each category collected, separating what a user provides directly from what is generated by use of the service. Identity documents and property ownership documents are a distinct, higher-sensitivity category and must be described as such rather than folded into a general list.

3. Purpose and lawful basis for processing

To be drafted. State the specific purpose of each category of processing and the lawful basis relied on for it. Consent, where it is the basis, must be described in the terms in which it is actually obtained in the app.

4. How data is stored and protected

To be drafted. Describe storage location, access controls, encryption in transit and at rest, and who within the organisation can access sensitive documents.

5. Sharing and disclosure

To be drafted. Identify any third parties that receive personal data, what they receive, why, and any cross-border transfer involved — DPPA places specific conditions on transfers outside Uganda.

6. Retention

To be drafted. State how long each category is kept and what triggers deletion. Retention periods for verification documents differ from those for ordinary account data and should be stated separately.

7. Your rights

To be drafted. Set out the data subject rights the DPPA confers — including access, correction, erasure, objection, and withdrawal of consent — and the actual mechanism for exercising each.

8. Children

To be drafted. State the minimum age for using the service and how that is handled.

9. Changes to this policy

To be drafted. Explain how changes are notified and from when they take effect.

10. Contact and complaints

To be drafted. Give the contact route for privacy enquiries and the route for lodging a complaint with the supervisory authority. Interim contact: purlyhomes@gmail.com.

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