Pop Up Privacy Policy Notice 

At Prudential Assurance Uganda Limited (PAUL), we take your privacy seriously and will only process your information for the purpose of delivering optimum services to you. Therefore, in line with the Data Privacy and Protection Act, 2019 Laws of Uganda and the EU General Data Protection Regulation (GDPR) and other applicable laws and regulations, where you decide to continue using this website, you have granted consent to the processing of your personal information by PAUL and other third parties as stated in our Privacy Policy.

In Prudential Assurance Uganda Limited (“PAUL”), your personal information is treated as private and confidential at every of your interaction with us to protect your privacy and provide you with the highest level of security. This Privacy Policy describes what information we collect, what we do with it and how we protect it.

Privacy Policy

Information We Collect and Use

Collection

Personal Information: We collect your information from a variety of sources including from you, and where lawful and reasonable, we may collect personal information about you from third parties and publicly available sources (such as government agencies, payment gateways, other financial institutions) and other written or electronic communication reflecting information such as your name, address, identification numbers, telephone number, occupation, assets, income and any other information we deem necessary. PAUL website also collects standard internet log information including your IP address, browser type and language, access times and referring website addresses.

Non-Personal Information: We may collect your non-personal information during your visits to some parts of our website or conduct research on your activities on our website in the bid to improve our services. However, we do not disclose your information to any person outside our organization except as described in this Privacy Policy.

Standards for the Use of Your Information

1. PAUL is committed to processing your information in a fair, lawful and transparent manner whilst using same for specific and lawful purpose(s) only. PAUL will request from you only information that is relevant and necessary for the purpose of your transactions with us. Further, PAUL is committed to the safe keeping of your information from unauthorized processing, accidental loss, damage, destruction and any other events that may be in breach of your rights.

2. PAUL will retain your information for as long as is necessary for the purpose(s) that it was collected in accordance with your rights. Storage of your data is also determined by legal, regulatory, administrative or operational requirements. We only retain information that allows us to comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise.

3. Data which is not retained is securely destroyed when it is identified that is no longer needed for the purposes for which it was collected.

4. PAUL processes your information with your consent only or where any of the following events occurs:

   1. where processing of personal data is required for compliance with legal and/or regulatory requirements.

   2. where processing of personal data is required for the fulfilment of a contractual obligation. 

   3. where processing is required to protect your vital interest or that of any other natural person.

   4. where processing is required for legitimate interests of PAUL, or a third party provided always that this does not conflict with the requirements for the protection of your personal data.

   5. where processing is required for an activity to be carried out in significant public interest.   

   6. where PAUL is permitted by law to do so.

Use of Your Personal Information

Your personal information is used to:

• Establish your identity and assess your applications for our products and services.
• Inform you about and administer PAUL’s services and products available that we think may be of interest to you whilst ensuring that our business suits your needs and complies with applicable regulations.
• Execute your instructions and manage our relationship with you.
• Identify and investigate any illegal activity such as fraud, preventing money laundering or terrorism financing activities and manage our risks. Conduct and improve our businesses and improve your experience with us.
• Comply with our legal obligations and assisting government and law enforcement agencies or regulators/supervisors.

Information We Share

We many share your information with PAUL’s staff; branches, strategic partners/service providers, regulators, external auditors and other relevant third parties.

Automated Processing

For the purposes of PAUL’s compliance to relevant laws and regulations, PAUL makes use of automated systems and software’s to help carry out due diligence checks including fraud and money laundering checks and/or to process your information.  

How We Protect Your Information

PAUL has a Data Protection Policy in place which all staff is expected to comply with to prevent loss, unauthorized access, misuse, modification or disclosure of any information under our control. Further, PAUL has a standard data protection clause in place, binding on all parties in every agreement entered into with third parties. 

Storage and Security of Your Information

All personal information is stored securely as required by Law. PAUL stores all data electronically on our secure servers and cloud infrastructure and/or physically in our offices. We also have in place reasonable commercial standards of technology and operational security to protect all information provided by visitors via this website from unauthorized disclosure, alteration, destruction or access to your personal information from unauthorized third parties.  

Disclosure of Information to Third Parties 

PAUL may provide your personal information to third party entities in the bid to provide you with optimum services, conduct market or other research, respond to your requests or inquiries and these third parties handle information on PAUL’s behalf as part of a corporate transaction such as a reorganization, merger or acquisition, divestiture, or sale.

Where you provide your information using this Website, you consent to the disclosures described above and PAUL reserves the right, where necessary, to transfer your personal information to other countries or regions which may not have the same level of protection. If necessary, we will ask the third party to whom we transfer your personal information to agree to our privacy principles, associated policies and practices.

We will not disclose your personal information to external organizations that are not our service providers, unless you gave us your consent, or unless we may do so by law, or if it is necessary for the conclusion or performance of our agreement with you.

Your Rights

At PAUL, we are aware of your rights under the applicable privacy and data protection laws and that you are entitled to the following rights as a data subject:

(i) Right of access

You have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right, and if you want to request more than one copy, we may charge a fee.

(ii) Right to rectification

You may have the right to rectify inaccurate or incomplete personal data concerning you.  

(iii) Right to erasure (right to be forgotten)

You may have the right to ask us to erase personal data concerning you where it is inaccurate. However, PAUL reserves the right to continue processing or retain your data on valid legal, regulatory, and operational grounds.

(iv) Right to restriction of processing

In limited circumstances, you may have the right to request that we restrict processing of your personal data, however where we process Employee Data and Sensitive Employee Data for the Processing Purposes, we think that we have a legitimate interest in processing that day which may override a request that you make.

(v) Right to data portability

You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and you may have the right to transmit that data to another entity.

(vi) Right to object and rights relating to automated decision-making

Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision.

(vii) Right to prevent processing of personal data for direct marketing

Please note a one-time password will be shared with you once at point of signup for our client portal/App if you choose to have access to your policy details. We advise that you always protect your information.

Children’s privacy protection 

We understand the importance of protecting children’s privacy in the interactive online world. This website is not designed for or intentionally targeted at children 18 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 18 nor do we allow children under 18 to purchase our products.

Electronic Marketing 

If you give us permission, we may use your personal information to tell you about products, services and special offers from us. We may do this through email, text message (SMS), social media platforms or notify you on your mobile applications. Where you are not interested in such notifications, kindly inform us through our customer service channels to discontinue this service.

Analysis of your Bank Statements

PAUL shall in compliance with the relevant laws carry out due diligence checks and analysis on your bank statement, where the need arises for credit, fraud, compliance and other risk-related purposes. 

Social Media

Whereas PAUL informs, helps and engages with our customers through designated channels, pages and accounts primarily to improve our services to you, we do not give investment, tax or other professional advice on our social media sites neither will PAUL ask you to share personal, account or security information on social media sites.

PAUL is only responsible for information posted by our designated officials. We regularly update and monitor our social media accounts and welcome feedback from you through these channels. 

PAUL also acknowledges that social media sites are not suitable forums to discuss products or financial arrangements specifically as your personal information may be processed by the site owner which is not within our control and may be in a region with different privacy principles.

Right to Change this Privacy Statement

We may change this privacy statement on an ad-hoc basis and at our discretion to reflect the legal, regulatory and operating environment and such revised versions will automatically become applicable to you. We will publish all changes to our privacy policy on our website and such revised policy becomes effective as at the time it is posted. 

The latest version of our privacy statement will replace all earlier versions, unless it says differently. We encourage you to periodically review this Privacy Statement to be informed about how we are protecting your information.