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Privacy Policy

SHA Privacy and Usage Statement

SHA is committed to protecting your privacy when you use our website. This privacy statement explains how we collect, use and store any personal information we collect about you when you use this website:

SHA is a limited liability Social enterprise registered in Uganda. This Privacy Statement applies to the general public, our members and supporters, Directors and Trustees, employees, consultants, volunteers, contractors, and to information that is obtained by SHA, and for which SHA is the Data Controller.

To enable SHA to fulfill its objectives, we collect and use personal information. It is of the utmost importance to us that we are open and honest about the information that we collect and the way in which we use it, and that we do so in a manner that is lawful and respectful of people’s privacy.

This statement is compliant with GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations.

Holding and Processing Personal Information

SHA stores and processes personal information for a number of reasons:

  •  To record donations made to SHA by supporters
    • To process donations made through SHA’s website or over the telephone
    • To record any activities by our supporters in aid of SHA, and provide support if requested
    • To communicate with supporters
    • To send marketing communications to those supporters who have indicated that they wish to receive them
    • To process claims for Gift Aid, where we are able to claim this on donations received
    • To comply with legal obligations, for example keeping financial records for at least seven years, or holding bank details for staff payroll administration purposes
    • To make sure that we do not send information or communications to people who have requested not to be contacted by SHA

Types of Personal Information SHA Collects
We will only collect personal information that is relevant to your interaction with SHA. If you make a donation to SHA, sign up to receive our newsletters, enroll in an event, contact SHA by post, telephone, e-mail, or if you engage with SHA through social media, then we may collect personal information such as:
• Your name
• Your e-mail addresses
• Your postal address
• Your telephone numbers
• Your bank account details or credit card details to process donations
• If you take part in an event, then we may, with your permission, take photographs of you
• We will only collect sensitive personal information, such as health information, where there is a clear and specific reason for doing so, for example, if you are participating in an activity or event or need to access our offices. This information will only be used to ensure that we provide the support and facilities needed

All personal information is stored on a secure database, to which only a limited number of our team have access. Personal information is deleted when it is no longer needed, and anyone can request to see the information that we hold on them at any time.

Collecting Personal Information
There are several ways in which SHA collects your personal information:
•Directly – this is where you have given us your personal information directly, for example when you made a donation, when you signed up to receive newsletters on our website when you registered to download data from SHA’s dashboard, When you submit an affordable Housing form, or when you took part in an event organized by SHA.
• Indirectly – you may give us your personal information indirectly when you support SHA by signing up to take part in events not organized by SHA, for example when you contribute to SHA through fundraising websites such as New Horizon Foundation or. These independent third parties will pass your personal information to SHA where you have indicated that you want to support SHA and have given your consent, or if it is necessary in order to complete a contract with you.
• When you use SHA’s social media, such as Facebook, Twitter, or LinkedIn. The information that we receive will be dependent on your settings in your accounts with social media services, and on the social media service’s privacy policies. If you wish to change your settings on any of these services, then please refer to their privacy policies, which should tell you how to do this.
• When we use cookies – when you visit SHA’s website we will collect data from your computer, or other devices such as a tablet or smartphone, by using cookies. Cookies are created by your web browser when you visit SHA’s website and are a useful way for us to understand how people use our website. Whenever you return to SHA’s website, your browser will send the cookie file back to our website’s server. This allows us to measure your use of our website, and to ensure that any preference settings are remembered and enables us to continually improve our website and ensure that you are presented with the most relevant information.

Legal Bases under Data Protection Legislation
There are a number of different bases set out under data protection legislation for organizations to use to collect and process your personal data. SHA uses the following bases under data protection legislation:
• Legitimate interest – there may be situations where we need to process data in order to carry out a task, such as enrolling you to take part in or run an event or plan a fundraising campaign
• Consent – wherever possible we will ask for your consent to send you information, and give you a clear choice as to the channels you want us to use, for example, e-mail, post, telephone
• Legal compliance – there are circumstances under which the law requires us to collect and process your personal data

Sending Marketing Information
SHA will only contact you for marketing purposes, to keep you up to date with SHA’s work and how you can support it, where we have your consent, or we are otherwise allowed to do so.
• We will have a simple way for you to tell us if you would like to receive marketing information from SHA, and the channels through which you would like to receive it, such as e-mail, post, text messages. We will also have a simple way for you to withdraw consent, or to change the way in which we communicate with you, at any time.
• Where you have given your consent for SHA to send you marketing communications, we will deem that consent to last until such time as you withdraw it.

How SHA will Use Personal Information
SHA will predominantly use your personal information for administrative reasons, and this includes:
• Keeping a record of your relationship with SHA
• Administering and acknowledging any donations that you make to SHA
• Your tax status with regard to claiming Gift Aid on donations that you make
• Sending you newsletters if you have signed up to receive these on our website
• Responding to any communication that we receive, whether this is a letter, e-mail, telephone call, text message, social media contact, or other means
• Providing information to anyone who is taking part in an event in aid of SHA
• To keep your information up to date, we may contact you from time-to-time to ensure that we have your correct information and contact preferences
• To implement any instructions that we are given if you withdraw consent, request to be forgotten, changes to your contact preferences, etc.
• To use IP addresses to identify the location of users of SHA’s website, to establish the number of visits from different places or countries
SHA will also use your personal information for marketing and fundraising purposes, which have already been described above. SHA will only use your personal information internally within the organization. SHA will never share your personal information with or sell it to, anyone else. Neither will you receive information from other companies, charities, or organizations because you have given personal information to SHA.
Updating Your Personal Information or Changing Your Contact Preferences
It is important to SHA that we communicate with you in the way that is best for you, and with the information that you want to see. If you want to update the information that we hold for you or change the way in which we communicate with you, then please contact us as follows:
• E-mail us on
• Telephone us on +256 (0) 770 474 142
• Use our website contact page:
Write to us at Smart Havens Africa, P.o Box 33525 Kampala – Uganda

Your Rights Regarding SHA’s Use of Your Personal Information
It is important that you understand your rights regarding the use of your personal information. This includes your rights to see, update, restrict, object to the use of, and withdraw consent to the use of your personal information.
You may have the right to request:
• To see the personal information that we hold for you and how we first received or obtained your details. You have the right to request to see a copy of the personal information that we hold for you. We will provide this as soon as possible, and within a month unless we notify you of any specific reason why it is not possible
• To correct any information that is either incorrect or out-of-date. You may request that we update or correct your personal information at any time
• To change the way in which we communicate with you. You may request a change in the way that we communicate with you at any time
• To stop receiving communications from SHA. You may request that we stop sending you communications via some or all channels, and we will always comply with your request
• To be forgotten, which is for your personal information to be deleted from our systems. If requested, we will delete all your personal information from our systems, or as much as we are allowed according to legislation and regulations. For example, if you have made donations to SHA, then HMRC rules dictate that we have to keep this information for seven years
You may contact us with any of these requests at any time, see the methods of contact above.
In order to protect the confidentiality of your personal information, we will ask you to verify your identity when you make any of the above requests.

Recruitment at SHA
• If you apply for a job with SHA, then we will receive and store the personal information that you provide in your cover letter, CV, application form, or any other details that you provide.
• This is likely to include your name, postal address, e-mail address, telephone numbers, information on your education and previous employers, as well as any skills and experiences that you describe in your application.
• This information will be stored securely on our system, and for those candidates who are not offered the position in question, their recruitment information will be deleted after a period of two years has elapsed.
• The candidate who is selected for the role will have their information transferred to their personnel file, where it will be kept for a period of ten years after the date that they leave SHA’s employment.

Working with SHA
As an employee of SHA, there is personal information that it is necessary for us to obtain, store, and process for the purposes of your employment, and to undertake the relevant administration necessary to pay your salary and make payments to URA and your pension provider.
This includes your:
• Full name
• Postal address
• Telephone numbers
• E-mail addresses
• Date of birth
• National Insurance Number
• Passport details and any visa or permit information necessary to prove you are able to live and work in Uganda
• Bank details for payroll purposes
• Details of your referees and the references they provided
• Details of your emergency contacts
• Demographic data – race, religion, nationality, disability, sexual orientation
• If you are in a role that includes overseas travel, then the information we hold will also include health information and details of vaccinations, etc. in order for us to carry out our responsibilities around duty of care for our employees.
This information is stored securely on our system in personnel files, to which access is restricted to a very small number of relevant employees and is kept for a period of ten years after your employment with SHA ends.
To notify us of changes to your details, tell us that you do not wish to receive any future information or updates from us, or if you have any questions about how we use your personal information, please email

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