Privacy Policy
Effective Date: August 17, 2026
Tukule ("we," "our," or "us") operates the financial groups management platform available at app.tukule.com. This Privacy Policy outlines how we collect, use, store, process, and protect personal and financial data in strict compliance with the Data Protection and Privacy Act, 2019 of the Republic of Uganda.
1. Scope of Policy
This policy applies to all administrators, executives, and individual members of SACCOs (Savings and Credit Cooperative Organizations) and Investment Clubs registered on the Tukule platform. By using the platform, the subscribing organization and its members consent to the data collection and processing activities detailed herein.
2. Information We Collect
Tukule collects personal and financial data necessary to facilitate accounting, member tracking, loan auditing, and communication services. This includes:
- Member Personal Identifiable Information (PII): Full names, phone numbers, email addresses, physical addresses, national ID numbers (NIN), passport photos, and system access credentials.
- Financial Group Data: Organization name, registration certificates, bylaws, physical office location, and administrative structures.
- Financial Transactions and Records: Weekly/monthly member savings balances, share capital holdings, capital contributions, investment capital distributions, loan requests, repayment schedules, guarantor allocations, penalties, ledger postings, trial balances, and periodic financial statements in Uganda Shillings (UGX).
- Governance Records: Meeting schedules, attendance lists, voting records, and resolutions made during assembly meetings.
- System Log Data: Audit trails tracking administrative actions, system access timestamps, device identifiers, and IP addresses to ensure operational accountability and fraud prevention.
3. Legal Basis and Purposes of Processing
Consistent with Section 10 of the Data Protection and Privacy Act, 2019, we process data under the following legal bases:
- Performance of a Contract: To provision system functionalities including savings tracking, loan calculations, ledger updates, and dividend distribution calculations.
- Legal and Regulatory Compliance: To enable cooperative societies and SACCOs to fulfill regulatory audit reporting mandated by the Uganda Cooperative Alliance (UCA), the Ministry of Trade, Industry and Cooperatives (MTIC), and the Uganda Microfinance Regulatory Authority (UMRA).
- Legitimate Interest: To secure the platform against accounting manipulation, unauthorized access, and internal member disputes by maintaining detailed, unalterable audit trails.
4. Data Storage, Location, and Retention
All data processed by Tukule is stored in secure, logically isolated cloud server environments utilizing industry-standard encryption protocols. Data is housed in secure data centers. We retain financial and personal records for the active duration of the organization’s subscription. Upon termination of service, data is preserved for a minimum of seven (7) years to comply with statutory financial auditing and cooperative records retention requirements under Ugandan law, after which it is safely purged or anonymized.
5. Data Security and Isolation
We implement professional, bank-grade technical and organizational measures to safeguard your information:
- Tenant Isolation: Data from different SACCOs or Investment Clubs is strictly partitioned. No organization has access to the records, accounts, or configurations of another group.
- Encryption: Data transmitted to and from the platform is encrypted using Secure Socket Layer (SSL/TLS) technology. Sensitive configuration settings, passwords, and access credentials are encrypted at rest.
- Role-Based Access Control (RBAC): Access to member data is strictly controlled. Administrators determine what information can be viewed by general members, committee heads, and auditors.
6. Disclosure and Sharing of Data
Tukule does not sell, lease, trade, or distribute your personal or financial data to commercial third parties. Information is only shared under the following conditions:
- Authorized Users: Member records and transaction details are made visible only to registered members of your specific organization, based on the access permissions granted by your organization's administrators.
- Legal Mandates: We may disclose data to authorized government bodies, regulators (such as UMRA or MTIC), or law enforcement agencies only when compelled by a valid legal order, court warrant, or statutory mandate under the laws of Uganda.
- Third-Party Integrations: Where the organization requests integrations (e.g., mobile money APIs, commercial bank feeds, SMS gateways), data necessary to complete the transactions is shared securely with licensed operators in Uganda.
7. Rights of the Data Subject
Under Section 24 to 28 of the Data Protection and Privacy Act, 2019, members of financial groups registered on Tukule have the right to:
- Request access to all personal data and statement records stored on the platform.
- Request rectification of inaccurate, outdated, or incomplete records.
- Object to processing or request deletion of data, subject to legal overrides regarding audit trail preservation for financial groups.
- Lodge complaints regarding data processing practices with the Personal Data Protection Office (PDPO) of Uganda.
8. Contact Us
For any queries, data access requests, or issues related to data protection, please contact our Data Protection Officer at:
Tukule Data Protection Desk
Email: support@tukule.com
Phone/WhatsApp: +256 782 195634
Kampala, Uganda.