Privacy Policy

1. Introduction

Thank you for using the services of Vanvaa. We built a service for stars and creators to collect donations from their generous and passionate supporters/fans.

This Privacy Policy applies to the processing of personal data by Vanvaa.

We may change this Policy from time to time. If we do, we shall post a revision of this Privacy Policy and your continued use of this Website/App and the Services shall be subject to such revised terms.

2. Our services

Our Core Service:

Tipping and Payment Processing Platform This includes a Wallet that enables adding funds and giving functionality where you choose which person to give (giving with one tap). We reserve the right to upgrade, maintain, tune, backup, amend, add to or remove items from, redesign, improve or otherwise alter our Services at our sole and absolute discretion.

3. Information we collect about you

1. User Information

We collect information from people who visit our website, make enquiries or otherwise contact us, trial our software, or set up and operate an account on behalf of an organisation (including Organisation Administrators and Authorized Users).   We call this ‘Customer Information.’

The Customer Information we collect includes:

  • Name, email address and phone number and other contact details;
  • Organisation name, location, website and number of members;
  • Financial information such as your organisation’s bank account details and Tax ID;
  • Legal representative information such as name, address, date of birth and copy of personal identification;
  • Electronic data such as IP addresses.

We collect and process this information as a Data Controller (for GDPR purposes).

2. Individual Information 

Personal information is also collected from individuals and Donors who use our Services to interact with, or donate to, organisations. We call this information ‘Individual Information.’

Information collected from individuals and Donors includes:

  • Name, email, phone number, address, and contact details;
  • Other information required for verification purposes such as date of birth and copy of personal identification;
  • Donation amount and designation of funds;
  • Payment information such as bank account details or credit / debit card information.

We collect and process Individual Information as a Data Controller (for GDPR purposes).

3. Customer Collected Information 

You may use our Services by attending an event hosted through Events, or by using an account in our Management Software which will have been set up by your Organization Administrator.

We process User Collected Information as a Data Processor (for GDPR purposes).

We assume that organisations collect and process all User Collected Information lawfully, and in accordance with their obligations as Data Controllers pursuant to the GDPR and other applicable data protection laws. 

4. Sensitive Data

The Customer Information, Individual Information and Customer Collected Information processed as part of our Services will include “special category data” for the purposes of the Uganda GDPR, or “sensitive data” under other privacy laws, as it includes information that relate to an individual’s religious affiliation.

We need your consent to collect this type of data (where we are acting as Data Controller as outlined above). To support this requirement, we have included confirmation of your consent in our on-line forms and on our website. If you do not provide this information, we may not be able to provide our Services.

User Collected Information is also special category or sensitive information, but this information has been collected and is processed by your church or other organisation as Data Controller. 

If you are concerned about the User Collected Information that has been included in any of our Services, we recommend you contact the organisation you are affiliated with.

5. Cookies and Web Beacons 

Vanvaa may collect information through the use of common information-gathering tools such as web beacons or cookies. 

  • A cookie is a small string of text that a website can send to your browser which helps the Site remember and customize your visit. You have the option to delete or decline cookies by changing your browser’s settings. 
  • Web beacons help sites to understand the browsing, viewing, and click activity of visitors to our site.

6. Other information

Vanvaa may also collect information from your interaction with the Site, such as statistics in connection with pageviews, IP address, and standard web log information.

Other information that may be collected includes the average donation amount, the geographic breakdown of donations by area, what times of the day have the heaviest traffic, and which type of charity receives the most gifts. This information, collected in the aggregate, allows Vanvaa to better serve all users and in the development of new products and services. None of this information is used to identify individuals. 

When browsing the Site through a mobile phone or mobile application, we will attempt to collect your location through GPS in order to pair you with nearby users for tipping purposes. You may remove this location sharing authorization.

7. Children

Vanvaa does not knowingly collect any Personal Information from or about a child (which we generally regard as anyone under the age of 16 years, subject to local law requirements) without the consent of the child’s parent or legal guardian. We may ask for evidence of a user’s date of birth to help us verify this.

If we discover that we have inadvertently collected information from a child without the appropriate consent, we will promptly take all reasonable measures to delete that data from our systems.

4. How we collect your personal information

We collect Customer Information and Individual Information directly through forms on the Website or when an Organization Administrator or other individual signs up for a Service or establishes an Account directly with us.

We may also collect information:

  • When you interact with us via our website, Chatbot or other online channel;
  • When you connect with us via one of our social media platforms.
  • When you contact us via email or over the phone.

Customer Collected Information is collected by the organization you are connected to, including when you interact with one of the Vanvaa Services. In most cases, Vanvaa does not directly collect or control any Customer Collected Information.

If you are concerned about the Customer Collected Information that has been included in any of Vanvaa's Services, we recommend you contact the organisation you are affiliated with.

5. How we use your personal information

1. Use in delivering services

We will only use Personal Information for purposes related to building and providing you with great products and services and giving you a great experience. These purposes include:

  • To provide organisations and Individuals with the goods and services they have requested;
  • To allow users to create or register and manage accounts;
  • To enable individuals to give to organisations via a Giving account, and to administer Giving accounts, including pre-authorised recurring donations.
  • To enable us to administer accounts, including billing and dealing with payment issues;
  • To respond to requests, enquiries or complaints and other customer care related activities;
  • For administrative purposes including fraud and security checks;
  • To improve our website and Services and support the development of new products and services, including undertaking surveys and market research;
  • To generate statistics and aggregate reports for internal and external use;
  • To improve our understanding of all our Customers and our broader community, to help give all users and visitors a great experience.

We reserve the right to use all data collected, processed or derived by us in relation to the Services, for the purpose of industry trend and best practices reporting, statistical analysis and research relating to the development or improvement of any of our services or products. We will not publish or disclose statistical findings of individual Customer or Donor activity.

We will not use your information for purposes other than described in this Policy unless we have your consent or there are specified law enforcement or public health and safety reasons or other uses required by law.

2. Direct Marketing and Mailing List

We may communicate directly with you by sending newsletters, promotions, charitable stories and other updates about our products and services.

If you do not wish to receive marketing communications from Vanvaa, you may unsubscribe by:

  • following the instructions in the communications sent to you; or
  • contacting us by email to vanvaa@gmail.com 

Vanvaa does not participate in bulk email solicitations (i.e., “spam”) without your consent. 

Your Personal Information will not be disclosed to third party marketers. We never sell, share, or otherwise use personal information for any commercial purposes outside of Vanvaa.  However, we may share aggregated anonymous information with third party advertisers, but this aggregated anonymous information cannot be matched with you personally unless you voluntarily share your Personal Information with the third-party advertisers.

3. Other sharing

Personal data may be shared among the different members of the Vanvaa group (subject to compliance with any legal restrictions on cross-border transfers). 

Vanvaa may disclose or transfer personal information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of Vanvaa in order for you to continue to receive the same services from the third party.

6. How we disclose your personal information

Unless you consent, we will not disclose any Customer Information or Individual Information to third parties, other than data processors or sub-processors we use as part of delivering our services.

1. Processors and Sub-processors

For all our processors and sub-processors:

Each has agreed that it will only access and use personal information to the extent necessary to perform the functions contracted to it by us and which are necessary for us to be able to provide the Services.

2. Optional Third-Party Services

We give our Customers the option to use services that may involve third parties. This may be done via a link to another service or website and may include, as an example, links to easypay or Visa for online payment as part of our service.

The decision to use these services is at the discretion of each Customer.

Although we try to only partner with reputable and trustworthy suppliers, we cannot control or be responsible for the policies of other sites we may link to, or the use of any personal information you may share with them. Please note that this Policy does not cover these other websites, and we recommend that you review the privacy policies attached to the use of those services and websites before deciding whether to proceed.

If you opt to use an optional third-party processor, you give that processor the right, power, and authority to act on your behalf to access and transmit your personal and other information (including Financial Information) according to terms of that third-party provider’s privacy policy. 

If you do not want your Individual Information to be shared with third parties for example for the purposes of emailing or texting you or supporting event registration, please let the Organization you are affiliated with know and they can disable these services for you.

3. Financial Information

When undertaking a financial transaction via our Services, for example, when lodging a donation, you may provide information including credit, debit or bank account details, and your name and address (“Financial Information”).  Vanvaa does not disclose Financial Information except to the appropriate banking institutions or payment processing provider in order to process a credit or debit authorization for payment, or to resolve a dispute or for other related purposes. 

Vanvaa does not have any access to your Financial Information inputted via third party payment processors

4. Social Networks 

We use social networking services such as Twitter, Facebook, Instagram and YouTube to communicate with Customers, Organisation Administrators, Authorized Users, organizations and the public about our Services. When you communicate with us using these services, we may collect your personal information. The social networking service will also handle your personal information for its own purposes. 

Our Site may also contain links to websites not affiliated with Vanvaa.

These social networking and non-affiliated sites have their own privacy policies and we recommend that you review them. We cannot control or be responsible for the policies of other sites we may link to, or the use of any personal information you may share with them.

7. Security and retention of personal information

1. Securing your account

Access to your account is secured via unique user passwords.  You can help to keep your personal information secure by ensuring that any password you use is kept strictly confidential and by logging off when you have finished using a shared device such as mobile phone, tab or computer.

2. Data Security

We take steps to protect the security of the personal information we hold from both internal and external threats by:

  • regularly assessing the risk of misuse, interference, loss, and unauthorised access, modification or disclosure of that information
  • conducting regular internal and external audits to assess whether we have adequately complied with or implemented these measures.
  • encrypting the transfer of data all the way from the browser to where the data is stored. We use HTTPs and all our data is encrypted at rest.

3. Data Breaches

Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be 100% secure. As a result, while Vanvaa attempts to protect all Personal Information, Vanvaa cannot ensure or warrant that Personal Information will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network. 

If a data breach (as defined by applicable laws) involving Personal Information occurs, Vanvaa will:

  • notify you of it as soon as reasonably possible after it comes to our attention;
  • take reasonable steps to secure the affected data and minimise harm to all individuals; and
  • provide you with whatever reasonable assistance might otherwise be required.

Please note, our obligations in regard to notification of data breaches may vary depending on whether we are acting as Data Controller or Data Processor in regard to the Personal Information affected by the data breach.

4. Retention of Personal Information

Generally, we will keep Personal Information for as long as a Customer is actively using Vanvaa’s Services or the period during which any legal claim may be made in regard to the provision of Services in accordance with legal requirements or to meet our legal obligations. For example, we hold billing records, and any information associated with those records (such as the number of supporters a user had) for 7 years.

If we hold personal information about you, and we do not need that information for any purpose, we will take reasonable steps to securely destroy or de-identify that information unless we are prevented from doing so by law.

We apply the following rules to the permanent deletion of information:

  • Customer accounts and associated Individual Information, where there has been no activity for more than 7 months (and where not required for Vanvaa’s own records or administrative processes) will be deleted permanently; and
  • Individual Information which has been deleted or disabled, will be permanently deleted or de-identified 90 days after deletion or disabling (or 18 months where members have financial data associated to them).

8. Your rights in relation to personal information

1. Access and Amendments

If you would like to request details about Customer Information or Individual Information that we hold about you and how we process it, contact us via the contact details below and we’ll be more than happy to help.

If you ever wish to amend personal information held by us, you may do so by:

  • logging into your account using your login credentials and password; or
  • contacting us at omushugugu@gmail.com or via the contact details below.

2. Deleting your Personal Information

Persons who wish to delete any personal information held by Vanvaa can contact us via the contact details below and we’ll be more than happy to help.

Customer Information

In relation to Customer Information, an Organization Administrator can ask us to delete Customer Information at any time, and we will delete it from all live systems and make sure we do not process it further in any way (other than as we may need to support your account or for other reasonable administrative or legal purposes, such as billing).

Customer Collected Information

Organizations also can delete or disable Customer Collected Information at any time. 

Individuals who wish to delete or stop the use of their Customer Collected Information for the purposes of any of the Services should contact the organization they are affiliated with directly. If an individual feels their organization has not dealt with their request promptly or effectively, we will work with the relevant data controller to attempt to resolve their request.

Last updated February 2022.