Privacy Policy

1. Who We Are

UgSend (“we”, “us”, “our”) is the data controller responsible for your personal data in connection with the UgSend platform. We act as a technology and programme support provider for UK to Uganda money transfers.

Contact for data protection matters: privacy@ugsend.co.uk

2. Data We Collect

Account information

• Name, email address, and password (hashed)
• Date of birth and nationality
• Residential address
• Phone number

Identity verification (KYC)

• Government-issued photo ID (passport, driving licence, national ID)
• Selfie / liveness check image
• Verification status and timestamp

Transfer data

• Sender and recipient details
• Transfer amounts (GBP and UGX), fees, and exchange rates
• Recipient mobile money network and phone number
• Transfer status and event timeline

Payment data

• Payment method type (debit card / bank transfer)
• Partial card or account details as required for payment processing
• Payment provider transaction references

Technical data

• IP address, browser type, device type, and operating system
• Pages visited, time spent, and referral source
• App usage logs and error reports

Communications

• Emails, support messages, and chat transcripts between you and UgSend

3. Why We Collect Your Data

4. Who We Share Your Data With

We share your data only where necessary to provide our service or comply with legal requirements:

• FCA-authorised Payment Partners: for payment processing, safeguarding, and currency conversion in the UK.
• Licensed Mobile Money Partners in Uganda: including MTN and Airtel agents, to facilitate payout to your recipient.
• Identity Verification Providers: who process your ID documents and selfie for KYC compliance.
• Sanctions & AML Screening Providers: who screen transactions and parties against watchlists.
• Cloud Infrastructure & Security Providers: who host the UgSend platform (all located in the UK or EEA with appropriate safeguards).
• Regulators and Law Enforcement: including HMRC, the FCA, the NCA, and Ugandan regulatory bodies, where required by law.

We do not sell, rent, or trade your personal data to any third party for marketing purposes.

5. International Data Transfers

Processing your transfers requires sending certain data to Uganda (recipient name, phone number, transfer amount). Uganda is not currently recognised by the UK as providing an adequate level of data protection. We ensure appropriate safeguards are in place for these transfers, including standard contractual clauses and our payout partners’ contractual obligations. By using UgSend, you acknowledge this transfer is necessary to fulfil the service you have requested.

6. How Long We Keep Your Data

• Transaction records: 5 years from the date of the transfer (as required by AML regulations)
• KYC documents: 5 years from the end of the customer relationship
• Account data: For the duration of your account plus 5 years after closure
• Marketing data: Until you withdraw consent or we no longer use it
• Support communications: 3 years from the date of contact

After the applicable retention period, data is securely deleted or anonymised.

7. Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

• Access: Request a copy of the personal data we hold about you
• Rectification: Ask us to correct inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal retention obligations)
• Restriction: Ask us to restrict how we process your data in certain circumstances
• Portability: Receive your data in a portable format
• Objection: Object to processing based on legitimate interests or for direct marketing
• Withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior processing

To exercise any right, email privacy@ugsend.co.uk. We will respond within one calendar month. Where requests are complex or numerous, we may extend this by a further two months with notice.

You have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner’s Office (ICO), at ico.org.uk, or by calling 0303 123 1113.

8. Cookies and Tracking

UgSend uses essential cookies to operate the service (session management, security). We may use analytics cookies to understand how the app is used and to improve it. We do not use advertising cookies or share data with ad networks.

You can control cookies through your browser settings. Disabling essential cookies will prevent the app from functioning correctly.

9. Security

We apply technical and organisational security measures appropriate to the risk, including:

• TLS encryption for all data in transit
• Encryption at rest for sensitive data
• Access controls limiting who can see your data
• Regular security testing and vulnerability assessments
• Incident response procedures for data breaches

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay.

10. Children’s Privacy

UgSend is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a person under 18, we will delete it promptly. Contact us at privacy@ugsend.co.uk if you believe a child has created an account.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by email or via an in-app notice. The ‘Last updated’ date at the top of this page indicates when the policy was last revised.

12. Contact Us

For privacy queries or to exercise your rights:
Email: privacy@ugsend.co.uk
General support: support@ugsend.co.uk