Who This Covers
This policy applies to paulbugembe.com and the services linked from it that are operated by Paul Bugembe, trading as Bugembe Systems SMC, based in Uganda: the client interview and intake forms, the MINDSET book store, ICT Skills Training, Legal OS, and SIMS (the School Information & Management System). Each of those products may also publish its own privacy notice for the specific data it handles as a signed-in application; this page covers the main site and is the starting point if you are not sure which notice applies.
What We Collect
We only collect what is actually needed to do the thing you asked for:
- Contact details you give us directly: name, email, phone number, and physical address, when you fill in an intake form, book a demo, or email us.
- Matter-specific information relevant to the service you requested: for example, proposed company names and subscriber details for a company registration, or a school's size and current setup for a SIMS demo request.
- Documents you upload, such as a national ID, passport, or supporting paperwork for a legal or tax filing.
- Account and session data for staff and paying users of our applications (Book Store, ICT Skills Training, Legal OS, SIMS): your login email, purchase and progress history, and the session cookie that keeps you signed in.
- Basic technical data that any web server logs automatically, such as your IP address and browser type, used only for security and keeping the site running.
We do not run advertising trackers or sell personal data to anyone, on this site or in any of the applications linked from it.
Why We Collect It
We process personal data for one of these reasons:
- To provide the specific service you asked for (legal drafting, company registration, a SIMS demo, ICT training progress, a book purchase).
- To meet a legal obligation, such as retaining records required for company registration or tax filings under Ugandan law.
- To run and secure our own systems, such as keeping you signed in or investigating abuse.
- Where you have separately given consent, such as ticking a consent box on an intake form.
Who Sees It
Personal data is handled by Paul Bugembe directly and, where a service genuinely needs it, a small number of trusted processors that keep the underlying systems running:
- Supabase (database, authentication, and file storage) for every application on this site.
- Pesapal (payment processing) for book and subscription payments; card and mobile money details are handled entirely by Pesapal, never stored on our own servers.
- Brevo (transactional email) for sending confirmations, receipts, and account emails.
- Africa's Talking (SMS), where a service you use sends text messages, such as SIMS fee reminders.
These providers process data on our instructions and under their own confidentiality and security commitments. We do not sell, rent, or trade personal data to third parties for marketing purposes.
Where Data Is Stored
Application data is hosted with Supabase and on a Contabo-managed server; both may store data outside Uganda depending on the hosting region in use at the time. Where personal data is transferred outside the country where you are located, we take reasonable steps to keep it under equivalent protections to those described in this policy, whether or not the destination country has its own data protection law with the same name.
How Long We Keep It
We keep personal data only as long as it is needed for the purpose it was collected for, or as long as the law requires (for example, statutory retention periods for company and tax records). Intake form submissions and uploaded documents for completed matters are kept as part of the client file; you can ask us to delete data that is no longer legally required to be kept, as described below.
Your Rights
If you are in Uganda, the Data Protection and Privacy Act, 2019 gives you the right to access, correct, and (where the law allows) have your personal data deleted, and the right to object to how it is processed. If you are located in a jurisdiction that grants you additional or different rights over your personal data, such as the EU/UK GDPR, we honour those rights here too, to the extent they apply. To exercise any of these rights, email paul@paulbugembe.com and we will respond within a reasonable time.
Children
SIMS holds student records on behalf of schools, which act as the data controller for that student data; a school using SIMS is responsible for having its own lawful basis (typically parental or guardian consent, or its own legitimate educational function) for the student records it enters. We process that data as a processor, under the school's instructions.
Changes to This Policy
If this policy changes in a way that meaningfully affects how your data is handled, we will update the date at the top of this page and, where practical, let active users know directly.
Contact
Questions about this policy or your data can go to paul@paulbugembe.com.
This policy is written in plain language for a small, Uganda-based business and is not a substitute for independent legal advice about your own specific situation.