Privacy Policy

Who we are

Near You is a product of Niamee Investments SMC Ltd [registration number and registered address, to be added once the company is registered] ("we"). We decide how and why your personal data is used, which makes us the data controller. [Registration with the Personal Data Protection Office: to be completed.] Contact: info@nambale.com.

What we collect, and why

• Your account: a phone number or an email address (or both), your name if you give it, your home Hub, and a password. We keep only a scrambled form of your password, never the password itself. Why: to make your account, sign you in and keep it secure.
• What you post: listings, pictures, requests and offers. Why: to run the marketplace. Pictures are re-saved by our server and the hidden data inside them, including the place a photo was taken, is removed.
• A meeting point, if you add one: a point on a map that a seller may choose for a listing. It is stored rounded to about 100 metres and shown on the listing. We never take it from your phone's location.
• Your conversations: messages you send and receive about a listing or an offer. Only the two people in a conversation can read it. Our team can read a conversation only after one of the two people reports it. Why: to let buyers and sellers contact each other without sharing phone numbers, and to deal with scams and abuse.
• Messages we send you: sign-in codes, reminders to refresh or close a listing, and notices about your requests and offers, by text message or email.
• Applications: if you apply to become a Hub Agent or Area Partner, the details on the form. Why: to decide the application.
• Safety and security records: a log of important actions (sign-ins, listing changes, moderation decisions), reports made about listings, and the network address of requests, kept briefly to stop abuse such as guessing codes. Why: to protect users and the service.
• Visit statistics: anonymous counts of page visits, with no cookies and no IP address kept. See Cookies and tracking.

We do not show your phone number or email to other users. We do not store your live location. If we add features that use your location, such as delivery tracking, we will ask you first and update this policy.

Our legal basis

We use your data to provide the service you asked for (your account, your listings), to protect the service and its users (security, preventing fraud and misuse), to meet legal duties, and, where the law requires it, with your consent. [Counsel to confirm the basis for each purpose.]

Who helps us handle your data

We use a small number of providers, only for the jobs below, and we do not sell your data:

• Contabo, which hosts our servers in the European Union [exact country to be confirmed].
• EgoSMS, which delivers text messages in Uganda.
• Brevo, which delivers email.
• OpenFreeMap, which supplies map pictures to your browser on pages that show a map (it can see your IP address; see Cookies and tracking).

Some of these providers are outside Uganda, so your data may be processed in other countries. [Counsel to confirm the safeguards and the wording for cross-border transfers.] Hub Agents and Area Partners may see counts and the listings and requests in their own area; people counts of one to four are hidden from them. We may share information with the police or a court where the law requires it.

How long we keep it

We keep your account while it is open. When you ask us to delete it, we remove your personal details, except what we must keep for security, to resolve disputes or to meet legal duties. [Retention periods for each kind of data, to be set and published.]

Your rights

You can ask to see the personal data we hold about you, to correct it, to delete it, to object to or limit how we use it, and to withdraw consent you gave. You can also complain to the data protection authority in your country; in Uganda that is the Personal Data Protection Office. To make a request, write to info@nambale.com from the phone number or email on your account. We will answer within [period, to be confirmed].

Security

Connections to our site and API are encrypted. Passwords are stored in scrambled form. Sign-in is limited so that codes and passwords cannot be guessed. No service is perfectly secure. If a breach affects your data, we will tell you and the regulator as the law requires.

Children

Near You is for people aged 18 and over. We do not knowingly collect data from children.

Other countries

We are starting in Uganda and plan to open in other countries. When we do, we will add the notices that country's law requires and name the local rules that apply. [Counsel to prepare a version for each new country.]

Changes

If we change this policy in a way that matters to you, we will tell you in the app or on the site before it takes effect.