Privacy Policy
EMEHub moves money, gifts and parcels between people, so we handle personal data every day - including that of people who have never signed up, like the recipient of a parcel. This policy explains what we collect, why, who sees it, how we protect it, how long we keep it, and the rights everyone has under Uganda's Data Protection and Privacy Act, 2019.
The short version
- Only what's neededEach service collects only what it needs - and never your location unless you tap for it.
- Never soldShared only with those doing the job: stores, payment providers, our print partner, regulators when the law requires.
- Protected and accountableEncrypted, access-limited, logged, and governed by Uganda's Data Protection and Privacy Act 2019.
- Your rightsAccess, correct, delete, object, withdraw consent - and complain to the Personal Data Protection Office.
This summary helps you find your way; the full text below is what applies.
On this page
- 1Who we are and how to reach us
- 2What this policy covers
- 3The personal data we collect
- 4Why we use it, and our lawful basis
- 5If you're a parcel recipient, gift recipient or finder
- 6Who we share it with
- 7How EMEHub stores must handle your data
- 8Data stored or processed outside Uganda
- 9How long we keep it
- 10Your rights, and how to use them
- 11How we protect your data
- 12Children
- 13Marketing and messages
- 14Cookies and similar technologies
- 15Changes to this policy
01Who we are and how to reach us
In short: EMEHub is responsible for your data, is registered with Uganda's data protection regulator, and has a data protection officer you can write to.
EMEHub is operated by [EMEHub legal entity name], a company registered in Uganda ([URSB registration number]) with its registered office at [Registered office address], Kampala, Uganda ("EMEHub", "we", "us").
For the personal data described in this policy, EMEHub is the data controller under the Data Protection and Privacy Act, 2019 (the "Act") and the Data Protection and Privacy Regulations, 2021 (the "Regulations"). We are registered with the Personal Data Protection Office ("PDPO") under registration number [PDPO registration number].
Our data protection officer can be reached at dpo@emehub.ug or by post at the address above, marked "Data Protection Officer".
02What this policy covers
In short: Everyone whose data EMEHub handles - including parcel recipients and finders who never signed up.
This policy applies to the EMEHub website, web and mobile apps, and every service in them:
- the EMEHub Wallet - deposits, withdrawals and transfers;
- Gifts - money sent or split to a phone number;
- Returnly - QR-tagged items, ordered and made through our print partner, that help lost items find their owners;
- the delivery network - booking, moving, tracking and handing over parcels through EMEHub stores and pickup points;
- store accounts - for people who apply to run, or work at, an EMEHub store.
It covers our customers, and also people whose data reaches us through someone else: a parcel recipient named by a sender, a gift recipient, and a finder who reports a Returnly item. Where we receive your data from someone else, this policy is how we tell you about it.
It doesn't cover other organisations' services that we link to, which have their own policies. How EMEHub stores handle data is governed by our agreements with them, described in section 7.
03The personal data we collect
In short: Account and identity details, records of your money and parcels, what finders and senders tell us, and basic technical logs.
| Who | What we collect | Where it comes from |
|---|---|---|
| Account holders | Name, email address, phone number, password (held only as a one-way hash by our sign-in service), sign-in history and failed sign-in attempts, profile picture and preferences. | You |
| Identity checks (KYC) | Date of birth, national ID or passport details and images, and the result of the check - when the law or a transaction limit requires it. | You |
| Wallet and gifts | Balances; each deposit, withdrawal, transfer and gift: amounts, currencies and rates, dates, the mobile money number used, counterparties, and status. | You, payment providers |
| Gift recipients | The phone number (and name, if given) the gift is sent to, and whether and when it was claimed. | The sender |
| Parcel senders | Name, phone number, the parcel's type, weight, size, declared value, insurance choice, price paid and how it was paid. | You, at the store |
| Parcel recipients | Name and phone number, the pickup point, collection and redirect history, how you proved who you are at hand-over (for example a one-time code or ID number seen), and a signature where one is taken. | The sender, you |
| Returnly owners | Items you register and their status, orders, delivery address, and the recovery reports about your items. | You |
| Returnly finders | Only what you choose to leave: name, phone and/or email, and your message. | You |
| Store owners and staff | Business names, registration number and TIN, store location, district and sub-county, inspection documents, store wallet and earnings records, team members and their roles, and the actions each person takes in the store console (who booked, bagged, handed over what, and when). | You, your store's owner |
| Support | What you tell us in a support ticket, and our replies. | You |
| Technical | IP address, device and browser type, pages and actions requested, timestamps and error logs. | Your device |
Location. A store's location is part of the network and is shown to customers. We read your device's location only when you press "Use my location", and only to fill in that form; we don't track your location in the background.
Sensitive data. We don't ask for data about health, religion, politics, ethnicity or similar. Identity documents are treated as confidential and access to them is restricted. Please don't put sensitive data in messages, parcel descriptions or support tickets.
04Why we use it, and our lawful basis
In short: To provide what you asked for, to meet the law, to keep EMEHub safe, and to keep you informed - marketing only with your consent.
The Act allows us to process personal data only for a lawful purpose. Ours are:
| Purpose | Examples | Lawful basis |
|---|---|---|
| Providing the service | Running your wallet, sending gifts, booking and moving parcels, telling a recipient where to collect, reuniting a lost item, running a store and paying its earnings. | Performance of our contract with you |
| Meeting legal duties | Identity checks, keeping financial records, reporting suspicious transactions, tax records, responding to lawful orders. | Compliance with the law |
| Keeping EMEHub secure | Detecting fraud and misuse, locking accounts after repeated failed sign-ins, investigating lost parcels and disputes, auditing staff actions. | Our and your legitimate interests; compliance with the law |
| Service messages | A parcel is ready or is being sent back; a gift was claimed; a payment succeeded or failed; a security alert. | Performance of our contract |
| Improving EMEHub | Understanding which features are used and where things break, using aggregated or de-identified data where possible. | Legitimate interests |
| Marketing | News and offers from EMEHub. | Your consent - which you can withdraw at any time |
Where we rely on consent, you can withdraw it at any time without affecting what we did before. Where we rely on legitimate interests, we have weighed them against your rights, and you can object (section 10).
Automated decisions. A few safety checks are automatic - for example, an account is locked after several failed sign-ins, and a payment over your available balance is refused. None of them makes a decision with legal or similarly significant effect on you without a person being able to review it; contact us if you want one reviewed.
05If you're a parcel recipient, gift recipient or finder
In short: Someone else gave us your details; we use them only to get the parcel, gift or message to you, and you have the same rights as any customer.
Parcel recipients: the sender gave us your name and phone number so you can be told where and when to collect your parcel. We use them for that, for the hand-over check, and to keep a record of delivery. If the phone number belongs to an EMEHub account, you'll also see the parcel in the app.
Gift recipients: the sender gave us your phone number so you can claim the gift. If it isn't claimed in time, it goes back to the sender and we keep only the transaction record the law requires.
Finders: what you leave when you report a found Returnly item is passed to the item's owner so they can get in touch. We don't use it for anything else, and remove it once the report is closed (section 9).
Senders and owners must only give us details they're entitled to share.
07How EMEHub stores must handle your data
In short: Stores may use your details only to handle your parcel, must keep them confidential, and every action they take is logged.
EMEHub stores are independent businesses. When they handle a parcel, they act on our instructions: under our agreement with them, they may use customers' details only to handle that parcel, must keep them confidential and secure, may not copy them for other purposes, and must report any loss or misuse to us at once. Store accounts only show what each role needs, and every action - who booked, bagged, released, received or handed over a parcel - is recorded against the person who did it.
08Data stored or processed outside Uganda
In short: If data leaves Uganda, it stays protected to the standard Ugandan law requires.
Some providers - such as our print partner and certain hosting services - may process data outside Uganda. We only transfer personal data abroad where the Act allows it: where the destination provides adequate protection, or where the provider is bound by contract to protect it to the standard of the Act, or with your consent. You can ask us for details of the safeguards for a particular transfer.
09How long we keep it
In short: As long as the service or the law needs it - then it's deleted or anonymised.
We keep personal data only as long as necessary for the purpose it was collected for, or as long as the law requires:
| Data | How long |
|---|---|
| Account details | While your account is open, then as long as needed to close it out and meet the duties below. |
| Identity (KYC) records and financial transaction records | For the period required by the Anti-Money Laundering Act and financial-services law - at least ten years after the transaction or the end of the relationship. |
| Parcel records (bookings, routes, hand-over evidence) | As long as needed to settle payments, handle claims and meet record-keeping duties, then deleted or anonymised. |
| Store applications that were rejected or withdrawn | Long enough to answer questions and resubmissions, then deleted, except records the law requires us to keep. |
| Returnly finder details | Until the item is recovered or the report is closed, then deleted. |
| Support tickets | As long as needed to resolve the issue and learn from it, then deleted or anonymised. |
| Technical and security logs | A limited period for security and troubleshooting; longer only when needed to investigate an incident. |
When data reaches the end of its retention period, we delete it or anonymise it so it can no longer identify you.
10Your rights, and how to use them
In short: You can see, correct, delete or restrict your data, object, and withdraw consent - free of charge, within the time the law sets.
Under the Act you have the right to:
- be told what personal data we hold about you and how we use it, and get a copy;
- correct data that is inaccurate, out of date or incomplete;
- have data deleted that we no longer have a lawful reason to keep (records the law makes us keep remain until that period ends);
- object to processing based on our legitimate interests, and to direct marketing at any time;
- withdraw consent you have given;
- ask for a person to review an automated decision;
- complain to the Personal Data Protection Office.
How: email dpo@emehub.ug or write to the Data Protection Officer at our registered office. We'll confirm we have your request, may ask you to prove your identity (so we never hand your data to someone else), and respond within the time limits set by the Act and the Regulations. Requests are free, unless they are clearly unfounded or excessive, as the law allows.
If you're unhappy with our answer, you can complain to the Personal Data Protection Office, National Information Technology Authority - Uganda (NITA-U), Kampala.
11How we protect your data
In short: Layered technical and organisational safeguards - and we'll tell you and the regulator if a breach puts your data at risk.
We protect personal data with measures appropriate to the risk, including:
- encryption of data in transit (HTTPS/TLS) and protection of stored data and backups;
- passwords stored only as salted one-way hashes; accounts locked after repeated failed sign-ins; staff accounts forced to change temporary passwords;
- role-based access - people see only what their role needs - with access to identity documents restricted further;
- a double-entry money ledger whose entries can't be edited after the fact, with every money movement traceable to who made it;
- an audit trail of sensitive actions by staff and store teams;
- contracts requiring our providers and stores to protect data and report incidents;
- regular review of access, dependencies and configuration.
If something goes wrong: if a breach of security compromises your personal data, we will notify the Personal Data Protection Office and, where it may affect you, tell you directly - promptly and within the time limits set by the Act and the Regulations - with what happened and what you can do.
Your part: keep your password private, sign out on shared devices, and remember EMEHub will never ask for your password, PIN or one-time code by phone, SMS, email or social media. Report anything suspicious to security@emehub.ug.
Found a vulnerability? Please report it privately to security@emehub.ug before disclosing it. We'll acknowledge it, keep you informed, and won't pursue good-faith research that respects users' privacy and doesn't disrupt the service.
12Children
In short: EMEHub accounts are for adults (18+).
EMEHub accounts are only for people aged 18 and over, and we don't knowingly collect personal data from children. A child may appear in our records only as the named recipient of a parcel or gift sent by an adult. If you believe a child has created an account or given us data, contact us and we'll delete it.
13Marketing and messages
In short: Service messages are part of the service; marketing only if you opt in, and you can opt out any time.
We send service messages - about your parcels, gifts, payments and account security - because they're part of the service; you can't opt out of these while you use it. We send marketing only if you've agreed, and every marketing message tells you how to stop them. Turning marketing off never affects service messages.
15Changes to this policy
In short: We'll tell you before anything important changes.
We review this policy regularly. If we make a material change, we'll tell you in the app or by email before it takes effect, and the date at the top will change. Earlier versions are available on request.
Questions about this?
Write to privacy@emehub.ug, or our data protection officer at dpo@emehub.ug.
[EMEHub legal entity name] · [Registered office address], Kampala, Uganda