Data Protection Statement
WELCOME
This Data Privacy Notice informs you about how and for which purposes we will process your personal data and explain your rights under the Data Protection and Privacy Act Cap 97.
We are strongly dedicated to handling your personal data always responsibly, diligently and in compliance with all legal requirements. State of the art professional standards will be applied to protect the integrity and security of your personal data.
WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?
Your personal data will be controlled by Hima Cement Limited who is identified as responsible controller in the communication you receive from us or who is responsible for the security and integrity of your personal data.
FOR WHICH PURPOSES WILL WE USE YOUR PERSONAL DATA?
We will process your personal data strictly only for the following purposes ("Permitted Purposes"):
Planning, performing, managing and administering your (or a third party's to whom you are related) contractual business relationship with Hima Cement e.g. by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging shipments and deliveries, and providing support services or providing you with other services or things you may have requested as applicable to Hima’s business line;
Maintaining and protecting the security of our products, services and websites or other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
Ensuring compliance with legal obligations (such as record keeping obligations), compliance screening or recording obligations (e.g. under antitrust laws, export laws, trade sanction and embargo laws, anti-bribery or corruption laws and internal rules or to prevent white-collar or money laundering crimes), which may include automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party lists and contacting you to confirm your identity in case of a potential match or recording interaction with you which may be relevant for antitrust purposes;
Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests;
We may also use your personal information in situations, which are likely to be rare such as where we need to protect your interests (or someone else’s interests) and where it is needed in the public interest or for official purposes;
Informing you, where permitted in accordance with the laws, within an existing business relationship about Hima Cement's products or services which are similar or relate to such products and services which have already been purchased or used within that business relationship;
Solving disputes, enforcing our contractual agreements and to establish, exercise or defend legal claims or
Ensuring compliance with legal obligations, e.g. to keep sales records for tax purposes or to send notices and other disclosures as required by law. Where the Data Protection and Privacy Act requires and, to comply with the law, we have asked you and you have given us your consent in the format provided [insert link to consent], we may process your personal data also for the following purposes:
Communicating with you through the channels you have approved to keep you up to date on the latest announcements, special offers and other information aboutHima Cement products and services (including marketing-related newsletters) as well as events and projects of Hima ;
Administrating and performing events including customer events, customer surveys, marketing campaigns, market analysis, sweepstakes, contests or other promotional activities or events or
Collecting information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).
With regard to marketing-related types of communication (i.e. emails and phone calls), we will where legally required only provide you with such information after you have opted in and provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us. The legal bases for processing of your personal data are set in the Data Protection and Privacy Act and regulations.
Depending on the above purposes for which we use your personal data, the processing is either necessary for the performance of a contract or other business agreement with Hima Cement or for compliance with our legal obligations or for purposes of legitimate interests pursued by us, always provided that such interests are not overridden by your interests or fundamental rights and freedoms. In addition, the processing may be based on your consent where you have expressly given that to us.
CHANGE OF PURPOSE
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted.
SCOPE OF PERSONAL DATA
We may collect and process in particular the following categories of personal data:
Contact information, such as full name, work address, work telephone number, work mobile phone number, work fax number and work email address,
Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
Further business information necessarily processed in a project or contractual relationship with Hima Cement or voluntarily provided by you, such as orders placed, payments made, requests and projects;
Information collected from publicly available resources, integrity data bases and credit agencies; and
If legally required for compliance purposes: information about relevant and significant litigation or other legal proceedings against you or a third party related to you and interaction with you which may be relevant for antitrust purposes.
Special categories of Personal Data. In connection with the registration for and provision of access to an event or seminar, we may ask for information about your health for the purpose of identifying and being considerate of any disabilities or special dietary requirements you may have. Any use of such information is based on your consent. If you do not provide any such information about disabilities or special dietary requirements, we will not be able to take any respective precautions.
Other Personal Data. We may sometimes ask for your data of birth, your habits or your preferences as we would like to send you greeting messages on important days for you. Any use of such information is based on your consent.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We will typically collect your personal data directly from you. We do not obtain personal data from third parties unless specified herein (e.g. information from publicly available resources, integrity data bases and credit agencies).
HOW DO WE PROTECT YOUR PERSONAL DATA
We maintain physical, electronic and procedural safeguards in accordance with the legal data protection requirements to protect your personal data from unauthorized access or intrusion. These safeguards include implementing specific technologies and procedures designed to protect your privacy, such as secure servers, firewalls and Secure Sockets Layer (SSL) encryption. We will comply with applicable laws and regulations regarding the confidentiality and security of personal data.
WITH WHOM WILL WE SHARE YOUR PERSONAL DATA?
We may share your personal data as follows:
We may also instruct service providers (Data Processors) within or outside of Hima Cement, domestically or abroad, e.g. shared service centers, to process personal data for the Permitted Purposes on our behalf and in accordance with our instructions only. Hima Cement will retain control over and will, as permitted by law and best practice, remain responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers.
With courts, law enforcement authorities, regulators or attorneys if legally permitted and necessary to comply with a legal obligation or for the establishment, exercise or defense of legal claims.
Otherwise, we will only disclose your personal data when we are required by applicable law or regulations or judicial or official request to do so, or when we suspect fraudulent or criminal activities.
WHERE WILL YOUR PERSONAL DATA BE PROCESSED?
In the course of our business activities, we may transfer your personal data also to recipients in other countries (“third countries”). These may include the United States of America and the European Union etc. The third countries to which we transfer your data are countries which are deemed to provide an adequate level of protection for your personal information. When doing so, we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data.
YOUR DATA PROTECTION RIGHTS
Subject to the Data Protection and Privacy Act and Regulations of Uganda, you may request in writing access to, rectification, erasure or restriction of processing of your personal data. You may also object to processing or request data portability. In particular, you have the right to request a copy of the personal data that we hold about you. If you make this request more than once, we may make an adequate charge for this. For any of the above requests, please send a description of your personal data concerned stating your name, customer number to the contact details below.
Email Address; hima.kampala@himacement.com
We may require additional proof of identity to protect your personal data against unauthorized access. We will carefully consider your request and may discuss with you how it can best be fulfilled. If you have given us your consent for the processing of your personal data, you can withdraw the consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. In case consent is withdrawn, we may only further process the personal data where there is another legal ground for the processing. If you have any concerns about how your personal data is handled by us or wish to raise a complaint, you can contact us at the contact details below to have the matter investigated. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the competent Data Protection Office.
DATA SECURITY
We have put in place measures to protect the security of your information. Details of these measures are available upon request. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
ARE YOU REQUIRED TO PROVIDE PERSONAL DATA?
As a general principle, you will provide us with your personal data entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide personal data. However, there are circumstances in which Hima Cement cannot take action without certain of your personal data, for example because this personal data is required to process your orders, provide you with access to a web offering or newsletter or to carry out a legally required compliance screening. In these cases, it will unfortunately not be possible for Hima Cement to provide you with what you request without the relevant personal data.
RETENTION OF YOUR PERSONAL DATA
Your personal data will be deleted when legally required. We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including where it is required for Hima Cement to assert or defend against legal, accounting, or reporting requirements until the end of the relevant retention period or until the claims in question have been settled.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company, we will retain and securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations.
UPDATES TO THIS DATA PROTECTION NOTICE
Hima Cement reserves the right to update and change this Data Protection Notice from time to time to reflect any changes to the way in which we use your personal data or changing legal requirements. We may also notify you in other ways from time to time about the processing of your personal information. In case of any such changes, we will publish the changed Data Protection Notice on our website or otherwise.
HOW TO GET IN TOUCH WITH US
For any questions and comments or in case you want to assert your rights including but not limited to reviewing, verifying, correcting or requesting erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing, you can also contact us in writing at: hima.kampala@himacement.com
