Vega Borehole Drilling Company Limited

January 2024

Welcome to Vega Borehole Drilling Co. Ltd ("we, " "us, " or "our"). We are committed to protecting the privacy and security of your personal data. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you engage our borehole drilling, geological survey, pump installation, or related services in Uganda.

This policy is formulated in accordance with the Uganda Data Protection and Privacy Act, 2019.

Please read this policy carefully. By using our services, you consent to the collection and use of your information as described herein.

1. The Information We Collect

To provide our services effectively and comply with regulatory requirements, we collect the following categories of personal data:

A. Information You Provide to Us

Contact Information: Name, physical address (location of the proposed drilling site), email address, and phone number(s).
Identification Data: National ID number or Passport number (required for contracting and permit applications with the Ministry of Water and Environment).
Property Information: Land ownership details, land title copies, and site accessibility info.
Financial Information: Payment details, bank account numbers, or Mobile Money numbers used for transactions.

B. Information Collected Automatically

When you visit our website, we may automatically collect certain information, including:

IP address, browser type, operating system, and geographic location (at a city/country level).

C. Information From Third Parties

We may receive information from local authorities (LC1 Chairpersons) regarding site location verification or environmental management agencies (NEMA) during the permitting process.

2. Statutory Authority for Collection

We collect and process personal data in line with the legal bases provided under Section 7 of the Uganda Data Protection and Privacy Act, 2019, including:

Consent: Where you have given clear consent for us to process your data for a specific purpose.
Contract: Processing is necessary for the performance of the drilling contract between you and us.
Legal Obligation: Processing is necessary to comply with the law (e. g., obtaining water abstraction permits from Ugandan regulatory bodies).

3. How We Use Your Information

We use the collected data for the following specific purposes:

To conduct hydrogeological surveys and assess the feasibility of drilling on your site.
To prepare, negotiate, and execute the drilling contract.
To apply for necessary permits on your behalf from the Directorate of Water Resources Management (DWRM) and local government authorities.
To manage billings, process payments, and recover debts.
To communicate with you regarding project updates, logistical arrangements, and post-installation support.
To comply with tax obligations (URA reporting).

4. Disclosure of Your Information

We do not sell your personal data. We only share your information with the following parties for strictly defined purposes:

Government Regulators: To the Ministry of Water and Environment (DWRM) and NEMA for statutory permitting and reporting as required by Ugandan law.
Third-Party Service Providers: We may share data with subcontractors (e.g. , specialized geophysical surveyors, pump suppliers, or transporters) purely to execute the project.
Financial Institutions: Banks and Mobile Money operators to process your payments.
Professional Advisors: Auditors, lawyers, and insurers as necessary.
Law Enforcement: When required to do so by court order or applicable Ugandan law.

5. Data Security

We implement appropriate technical and organizational security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include:

Physical security of hard-copy project files and contracts.
Password-protected digital databases and secured servers for financial data.
Restricting access to your data only to employees and authorized partners who need it to perform their jobs.

6. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

The duration of the drilling project and warranty period.
A period thereafter to comply with Ugandan accounting and legal retention requirements (usually seven [7] years for financial records).
Geological and technical data regarding the final borehole specification may be retained indefinitely for regional groundwater record-keeping.

7. Your Rights as a Data Subject

Under Uganda's Data Protection and Privacy Act, 2019, you have the following rights regarding your personal data:

Right to Access: You have the right to request a copy of the personal data we hold about you.
Right to Rectification: You can request that we correct incomplete or inaccurate data.
Right to Erasure (Right to be Forgotten): You may request that we delete your data where there is no legal reason for us to continue processing it (subject to statutory retention limits).
Right to Object: You can object to the processing of your data, particularly for direct marketing.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, please contact our Data Protection Officer using the details below. We will respond within seven (7) working days, as required by Ugandan regulations.

8. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or the law. We will notify you of any significant changes by posting the new policy on our website or contacting you directly (if we have your email).

9. Contact Us and Complaints

If you have questions about this policy, wish to exercise your rights, or have a complaint about how we handle your data, please contact us:

Vega Borehole Drilling Co. Ltd

Nsambya, Kampala, Uganda

Email: admin@vegadrilling.ug

Phone: 0700 000 000

If you are dissatisfied with our response to a complaint, you have the right to lodge a complaint with the national regulator:

The Personal Data Protection Office (PDPO) c/o National Information Technology Authority Uganda (NITA-U) Web: https://www.pdpo.go.ug/