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Last Updated: February 2024 | Effective Date: February 2024
1. Introduction
SparkLab Technologies Limited ("SparkLab", "we", "us", or "our") operates the Yello Booth service, a comprehensive digital financial and communication platform designed for students in Uganda. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Yello Booth services.
By using Yello Booth, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this privacy policy, please do not access or use our services.
2. Information We Collect
2.1 Personal Information
We collect information that identifies, relates to, or could reasonably be linked to you, including:
- Student Information: Name, date of birth, school, class, student ID number
- Parent/Guardian Information: Name, phone number, email address, national ID
- Contact Information: Phone numbers, email addresses, physical addresses
- Financial Information: Transaction history, wallet balance, payment methods
- Communication Data: Call logs, approved contact lists, voice message records
2.2 Usage Information
We automatically collect certain information about your device and usage patterns:
- Device information (type, operating system, unique identifiers)
- IP address and location data
- App usage statistics and preferences
- Transaction patterns and timing
2.3 School-Provided Information
We receive information from partner schools including:
- Student enrollment data
- Academic term schedules
- Approved calling windows and restrictions
3. How We Use Your Information
We use the collected information for the following purposes:
3.1 Service Delivery
- Process transactions and maintain wallet balances
- Enable voice communication services during approved hours
- Manage student accounts and verify identities
- Provide parent dashboard access and controls
3.2 Safety and Security
- Enforce calling restrictions and approved contact lists
- Monitor for fraudulent or unauthorized activities
- Comply with school policies and schedules
- Protect minors in accordance with child protection laws
3.3 Communication
- Send transaction notifications and alerts
- Provide customer support and respond to inquiries
- Inform about service updates and new features
3.4 Improvement and Analysis
- Analyze usage patterns to improve our services
- Develop new features and functionalities
- Generate aggregated insights for schools
4. Information Sharing and Disclosure
We do not sell, trade, or rent your personal information. We may share information in the following circumstances:
4.1 With Parents/Guardians
Parents have full access to their child's account information, including:
- Transaction history and wallet balance
- Call logs and communication records
- Spending patterns and analytics
4.2 With Schools
We share limited information with partner schools for:
- Verification of student enrollment
- Aggregated usage statistics (non-personal)
- Compliance with school policies
4.3 With Service Providers
We work with trusted third parties who assist in:
- Payment processing and banking services
- Telecommunications services for voice calls
- Cloud storage and data hosting
- Analytics and technical support
4.4 Legal Requirements
We may disclose information when required by law or to:
- Comply with legal processes and government requests
- Protect the rights and safety of SparkLab Technologies and users
- Investigate fraud or security issues
5. Data Protection for Minors
Yello Booth is designed for use by students with parental consent and oversight. We implement special protections for minor users:
- Parental consent required for account creation
- Parents maintain full control and visibility over accounts
- Restricted communication to approved contacts only
- No marketing or advertising directed at minors
- Enhanced security measures for minor accounts
6. Data Security
We implement industry-standard security measures to protect your information:
- Encryption of data in transit and at rest
- Secure authentication and access controls
- Regular security audits and testing
- Employee training on data protection
- Incident response procedures
However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.
7. Data Retention
We retain personal information for as long as necessary to:
- Provide our services and maintain accounts
- Comply with legal and regulatory requirements
- Resolve disputes and enforce agreements
- Meet school record-keeping requirements
Transaction records are typically retained for 7 years in accordance with financial regulations. Communication logs are retained for the duration of the academic year unless longer retention is required by law.
8. Your Rights and Choices
You have the following rights regarding your personal information:
8.1 Access and Correction
- Request access to your personal information
- Correct inaccurate or incomplete information
- Receive a copy of your data in a portable format
8.2 Control and Consent
- Manage communication preferences
- Update approved contact lists
- Adjust privacy settings within the app
8.3 Deletion
You may request deletion of your account and personal information, subject to legal retention requirements and school policies.
9. Updates to This Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by:
- Posting the new Privacy Policy on this page
- Updating the "Last Updated" date
- Sending notifications through the app or email for material changes
Your continued use of Yello Booth after changes indicates acceptance of the updated policy.
10. Contact Information
If you have questions or concerns about this Privacy Policy or our data practices, please contact us:
11. Governing Law
This Privacy Policy is governed by the laws of the Republic of Uganda, including the Data Protection and Privacy Act, 2019. Any disputes arising from this policy shall be resolved through the appropriate Ugandan courts or regulatory authorities.