Legal

Privacy Policy

Last updated: January 2025

1. Introduction

Tullany Holdings Limited ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy sets out how we collect, use, store, and protect personal data in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Uganda Data Protection and Privacy Act 2019.

2. Data We Collect

We may collect and process the following personal data:

• Your name and email address when you submit an enquiry via our contact form;
• The content of messages you send to us;
• Technical data such as your IP address, browser type, and pages visited, collected automatically via standard server logging.

We do not collect sensitive personal data as defined under UK GDPR Article 9 unless specifically required and with your explicit consent.

3. How We Use Your Data

We use the personal data we collect for the following purposes:

• To respond to enquiries submitted through our contact form;
• To maintain and improve the functionality of this website;
• To comply with legal obligations to which we are subject;
• For legitimate business interests, where these are not overridden by your rights and interests.

4. Legal Basis for Processing

We process your personal data on the following legal bases:

• Consent — where you have submitted information to us voluntarily;
• Legitimate interests — for internal administration, security, and website improvement;
• Legal obligation — where processing is required to comply with applicable law.

5. Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. Enquiry data is typically retained for a period of 24 months from the date of receipt, after which it is securely deleted.

6. Data Sharing

We do not sell, rent, or trade your personal data to third parties. We may share data with trusted service providers acting on our behalf (such as email hosting providers), subject to appropriate data processing agreements. We may also disclose data where required by law or regulatory authority.

7. International Transfers

Given our international operations across Uganda, the United Kingdom, and the Caribbean, your personal data may be transferred to and processed in countries outside the UK or European Economic Area. Where such transfers occur, we ensure that appropriate safeguards are in place in accordance with applicable data protection law.

8. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• The right to access your personal data;
• The right to rectification of inaccurate data;
• The right to erasure ("right to be forgotten");
• The right to restrict processing;
• The right to data portability;
• The right to object to processing;
• Rights in relation to automated decision-making and profiling.

To exercise any of these rights, please contact us using the form on our Contact page.

9. Cookies

This website uses only essential technical cookies necessary for its operation. We do not use tracking, advertising, or analytics cookies. No cookie consent banner is therefore required.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security.

11. Complaints

If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the relevant supervisory authority. In the United Kingdom, this is the Information Commissioner's Office (ICO). In Uganda, this is the Personal Data Protection Office.

12. Changes to This Policy

We reserve the right to update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.