Privacy Policy

1. Identity of the Data Controller

The data controller responsible for your personal information is:

Rodvers Company Limited is incorporated under the laws of Uganda. Where we operate as a processor on behalf of a client, the applicable client is the data controller and we act strictly on their documented instructions.

2. Scope & International Applicability

This Policy applies globally to all visitors and clients, regardless of location. We comply with:

• The Uganda Data Protection and Privacy Act, 2019 (UDPPA)
• The EU General Data Protection Regulation (GDPR — Regulation 2016/679)
• The UK General Data Protection Regulation (UK GDPR)
• The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• Other applicable national and regional privacy laws where we deliver services

Where local laws grant additional rights, those rights apply to you in your jurisdiction.

3. Information We Collect

a) Information You Provide Directly

• Contact details: name, email, phone number, company name, and job title
• Messages and enquiries via contact forms
• Career application data: CV, cover letter, professional history, and references
• Any other information you voluntarily share

b) Information Collected Automatically

• Technical data: IP address, browser type and version, OS, device identifiers
• Usage data: pages visited, time spent, referring URLs, click paths, interactions
• Cookies and similar tracking technologies (see Section 6)

c) Information from Third Parties

• Analytics providers (e.g., Google Analytics) — aggregated behavioural data
• Publicly available business directories and LinkedIn for B2B prospecting
• Referrals from existing clients or partners

We do not knowingly collect sensitive personal data (special category data under GDPR) unless explicitly provided in a specific engagement.

4. Legal Basis for Processing (GDPR)

For individuals in the EEA, UK, or other jurisdictions requiring a legal basis (Article 6 GDPR):

5. How We Use Your Information

• To respond to enquiries, proposals, and service requests
• To deliver contracted services and manage client relationships
• To process and evaluate job applications
• To improve website functionality, performance, and user experience
• To send service-related communications (invoices, project updates, support)
• To send marketing communications where you have given consent
• To comply with applicable laws and lawful regulatory requests
• To detect, prevent, and address technical issues, fraud, and security threats
• To exercise or defend our legal rights

6. Cookies & Tracking Technologies

Our website uses cookies and similar technologies to operate and understand visitor behaviour. We use strictly necessary, analytics, preference, and (currently unused) marketing cookies. See our Cookie Policy for full details and opt-out instructions.

7. Sharing & Disclosure of Data

We do not sell your personal data. We may share it in limited circumstances:

• Service Providers: Trusted vendors under strict data processing agreements.
• Legal Obligations: Where required by Ugandan law, court order, or lawful regulatory request.
• Business Transfers: In the event of a merger or acquisition, subject to the same privacy protections.
• Professional Advisors: Lawyers, auditors, and insurers under confidentiality obligations.
• With Your Consent: To any other party where you have expressly authorised disclosure.

8. International Data Transfers

As a Ugandan company delivering services globally, your data may be transferred to, stored in, or processed in countries outside your country of residence. We safeguard transfers through:

• EU Standard Contractual Clauses (SCCs) for transfers from the EEA or UK
• Adequacy decisions where applicable
• Contractual data protection obligations with all processors

9. Data Retention

10. Your Rights

• Right of Access: Obtain a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion where there is no compelling reason for continued processing.
• Right to Restriction: Ask us to restrict processing in certain circumstances.
• Right to Data Portability: Receive your data in a structured, machine-readable format (GDPR).
• Right to Object: Object to processing based on legitimate interests or for direct marketing.
• Right to Withdraw Consent: Withdraw consent at any time without affecting prior processing.
• CCPA Rights: Right to know, delete, opt-out of sale (we do not sell data), and non-discrimination.

Contact us at privacy@rodvers.com. We respond within 30 days.

11. Children's Privacy

Our services are directed at businesses and professionals. We do not knowingly collect personal data from children under 16. If you believe we have, please contact privacy@rodvers.com and we will delete it promptly.

12. Security Measures

• TLS/SSL encryption for all data in transit
• Encrypted storage of sensitive data at rest
• Access controls and role-based permissions for staff
• Regular security assessments and software patching
• Data Processing Agreements with all third-party providers

In the event of a personal data breach, we will notify the relevant supervisory authority within 72 hours and affected individuals without undue delay.

13. Changes to This Privacy Policy

We may update this Policy from time to time. Material changes will be communicated by updating the "Last Updated" date and, where appropriate, by direct notice. Continued use of our website after changes constitutes acceptance.

14. Contact & Data Subject Requests