PRIVACY POLICY
At Specialist Uganda, a registered tour operator under the Uganda Tourism Act, 2008, we are committed to protecting your privacy and ensuring the security of your personal data in compliance with the Data Protection and Privacy Act, 2019 (DPPA) of Uganda and, where applicable, international standards such as the General Data Protection Regulation (GDPR) for clients in the European Union. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you interact with us through our website ([www.specialistuganda.com](http://www.specialistuganda.com)), mobile applications, booking platforms, or during our safari tour packages, including the Bwindi Mountain Gorilla Trek. By engaging with our services, you consent to the practices described in this policy.
If you have any questions or concerns about this Privacy Policy, please contact our Data Protection Officer at info@specialistuganda.com or sam@specialistuganda.com.
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1. Who We Are
Specialist Uganda is a licensed tour operator based in Uganda, registered with the Uganda Tourism Board (UTB), specializing in organizing and facilitating safari tour packages, including gorilla trekking, wildlife safaris, and cultural experiences. We act as a data controller under the DPPA, 2019, responsible for determining the purposes and means of processing your personal data. Our contact details are:
- Email: info@specialistuganda.com or sam@specialistuganda.com
- Phone: [your phone number]
- Address: [your physical address]
We are registered with the National Data Protection Office (NDPO) as required by the DPPA, 2019.
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2. Personal Data We Collect
We collect personal data to process bookings, secure permits, ensure safety, and deliver our tour services. The types of data we collect include:
2.1 Data You Provide Directly
- Identity Information: Full name, date of birth, gender, nationality, and passport details (number, issue/expiry date) for booking confirmation and Uganda Wildlife Authority (UWA) permit applications (e.g., gorilla trekking permits).
- Contact Information: Email address, phone number, and mailing address for communication and booking coordination.
- Health Information: Medical conditions, disabilities, dietary requirements, or fitness levels disclosed to assess your ability to participate in strenuous activities like gorilla trekking, as required by UWA regulations.
- Payment Information: Credit card details, bank account information, or mobile money details for processing payments (processed via secure third-party payment gateways).
- Travel Preferences: Tour preferences, special requests, or itinerary details provided during booking.
2.2 Data Collected Automatically
- Website Usage Data: IP address, browser type, device information, pages visited, and time spent on [www.specialistuganda.com](http://www.specialistuganda.com), collected via cookies and analytics tools (e.g., Google Analytics) to improve our services.
- Correspondence Data: Emails, chat logs, or call recordings (if applicable) when you contact us for inquiries or support.
2.3 Data from Third Parties
- Booking Platforms: Personal data (e.g., name, contact details) shared by authorized booking agents or platforms (e.g., SafariBookings, TourRadar) when you book through them.
- Travel Documentation: Visa or vaccination status (e.g., yellow fever certificate) verified through government or health authorities, as required for entry into Uganda.
2.4 Sensitive Personal Data
- We may collect sensitive data, such as health information or passport details, only when necessary for tour operations (e.g., UWA permits, safety assessments). We process such data with your explicit consent and in compliance with DPPA, 2019 Section 11.
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3. How We Use Your Personal Data
We process personal data for specific, legitimate purposes as required by DPPA, 2019 Section 8. These purposes include:
- Booking and Tour Operations: To confirm bookings, secure UWA gorilla trekking permits, arrange accommodations, transport, and guides, and coordinate your tour itinerary.
- Safety and Compliance: To verify age (minimum 15 for gorilla trekking), assess health/fitness for strenuous activities, and ensure compliance with UWA regulations and Uganda’s health requirements (e.g., yellow fever vaccination).
- Payment Processing: To process deposits, balances, and refunds via secure payment gateways.
- Communication: To send booking confirmations, tour updates, safety information, or respond to inquiries via email, phone, or other channels.
- Marketing (Optional): With your consent, to send promotional offers, newsletters, or updates about our tours. You may opt out at any time.
- Website Improvement: To analyze website usage data for enhancing user experience and optimizing [www.specialistuganda.com](http://www.specialistuganda.com).
- Legal Obligations: To comply with Ugandan laws (e.g., Uganda Wildlife Act, 2019, Tourism Act, 2008) or respond to legal requests from authorities.
We do not use your data for purposes beyond those stated without your consent, except as required by law.
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4. Legal Basis for Processing
We process personal data based on the following legal grounds under DPPA, 2019 and, where applicable, GDPR:
- Consent: When you provide explicit consent (e.g., for health data, marketing emails). You may withdraw consent at any time by contacting info@specialistuganda.com.
- Contractual Necessity: To fulfill our contract with you (e.g., processing bookings, securing permits), as outlined in our Terms of Service.
- Legal Obligation: To comply with Ugandan laws (e.g., UWA permit requirements, immigration regulations).
- Legitimate Interests: For website analytics, fraud prevention, or improving services, provided your rights are not overridden.
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5. How We Share Your Personal Data
We share personal data only when necessary to provide our services or comply with legal obligations, in compliance with DPPA, 2019 Section 21. Recipients include:
- Uganda Wildlife Authority (UWA): Passport details and age for gorilla trekking permits, as required by the Uganda Wildlife Act, 2019.
- Third-Party Service Providers: Hotels, lodges, transport companies, or local guides involved in your tour, receiving only necessary data (e.g., name, dietary needs).
- Payment Processors: Secure third-party gateways (e.g., Stripe, PayPal) to process payments, receiving limited financial data.
- Government Authorities: Immigration or health authorities to verify visas or vaccination status (e.g., yellow fever certificate).
- Booking Platforms: Authorized agents or platforms (e.g., SafariBookings) to facilitate bookings, with your consent.
We ensure third parties comply with data protection standards through contracts or agreements. Data shared with UWA or government bodies is subject to their privacy policies, over which we have no control.
For international clients, we may transfer data outside Uganda (e.g., to booking platforms or EU-based providers). Such transfers comply with DPPA, 2019 Section 21, ensuring adequate protection (e.g., GDPR-compliant agreements, client consent).
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6. Data Security
We implement appropriate technical and organizational measures to protect your personal data, as required by DPPA, 2019 Section 22, including:
- Encryption: Secure SSL encryption for data transmitted via [www.specialistuganda.com](http://www.specialistuganda.com).
- Access Controls: Restricting data access to authorized personnel trained in data protection.
- Secure Storage: Storing data on encrypted servers with regular security audits.
- Third-Party Vetting: Ensuring service providers (e.g., payment processors, lodges) meet data security standards.
Despite our efforts, no system is completely secure. In the event of a data breach, we will notify affected individuals and the NDPO within 72 hours, as required by DPPA, 2019 Section 24.
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7. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy, in compliance with DPPA, 2019 Section 9:
- Booking and Tour Data: Retained for 5 years after your tour to comply with tax laws, UWA regulations, and potential legal claims, then securely deleted.
- Health Data: Retained for the duration of your tour and up to 1 year for safety and liability purposes, then deleted unless required by law.
- Payment Data: Retained for 7 years to comply with financial regulations, then deleted (credit card details are not stored directly by us).
- Marketing Data: Retained until you unsubscribe or withdraw consent, with immediate removal from marketing lists upon request.
- Website Analytics: Anonymized data retained indefinitely; identifiable data (e.g., IP addresses) deleted after 12 months.
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8. Your Data Subject Rights
Under DPPA, 2019 Sections 15–18 and, where applicable, GDPR, you have the following rights regarding your personal data:
- Right to Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Correct inaccurate or incomplete data.
- Right to Erasure: Request deletion of your data, subject to legal retention obligations (e.g., tax records, UWA permits).
- Right to Restrict Processing: Limit how we use your data in certain circumstances.
- Right to Data Portability: Receive your data in a structured, machine-readable format for transfer to another provider.
- Right to Object: Object to processing for marketing or legitimate interests (e.g., analytics).
- Right to Withdraw Consent: Withdraw consent for data processing (e.g., marketing) at any time, without affecting prior lawful processing.
To exercise these rights, contact our Data Protection Officer at info@specialistuganda.com or sam@specialistuganda.com. We will respond within 30 days, as required by DPPA, 2019 Section 16. You may also lodge a complaint with the National Data Protection Office (NDPO) at:
- Email: [NDPO contact, pending public information]
- Address: [NDPO address, pending public information]
For EU clients, you may contact your local data protection authority under GDPR.
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9. Cookies and Tracking Technologies
We use cookies and similar technologies on [www.specialistuganda.com](http://www.specialistuganda.com) to enhance your experience, analyze usage, and deliver personalized content. Types of cookies include:
- Essential Cookies: Necessary for website functionality (e.g., booking forms).
- Analytics Cookies: Track website performance (e.g., Google Analytics) to improve user experience.
- Marketing Cookies: Deliver targeted ads or promotions, with your consent.
You can manage cookie preferences via your browser settings or our website’s cookie banner. Disabling cookies may limit website functionality. We obtain your consent for non-essential cookies, as required by DPPA, 2019 and GDPR.
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10. Third-Party Links
Our website may contain links to third-party sites (e.g., UWA, booking platforms). These sites have their own privacy policies, and we are not responsible for their practices. Review their policies before sharing personal data.
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11. Children’s Privacy
Our services, including gorilla trekking, are not intended for individuals under 15, as per UWA regulations. We do not knowingly collect personal data from children under 15 without parental consent. If we discover such data, we will delete it immediately, unless required by law. For minors aged 14 (with UWA approval for trekking), parental consent is required for data processing.
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12. International Data Transfers
For clients booking from outside Uganda or through international platforms, personal data may be transferred to countries like the EU, USA, or Kenya (e.g., for booking platforms or payment processors). We ensure such transfers comply with DPPA, 2019 Section 21 by:
- Obtaining your explicit consent.
- Using contracts with third parties that meet Uganda’s data protection standards.
- Ensuring GDPR compliance for EU clients (e.g., Standard Contractual Clauses).
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13. Updates to This Privacy Policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. Updates will be posted at [www.specialistuganda.com/privacy-policy](http://www.specialistuganda.com/privacy-policy), with the effective date revised. We will notify you of significant changes via email or website notice. Continued use of our services after updates constitutes acceptance of the revised policy.
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14. Contact Us
For questions, concerns, or to exercise your data subject rights, contact our Data Protection Officer:
- Email: info@specialistuganda.com or sam@specialistuganda.com
- Phone: [your phone number]
- Address: [your physical address]
We aim to respond within 30 days, as required by DPPA, 2019.
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Last Updated: April 28, 2025
