Privacy Policy

Effective Date: 1 January 2025  |  Last Updated: 1 January 2025

Transnet Consultants Ltd ("Transnet", "we", "our", "us") is committed to protecting the privacy and confidentiality of information provided by users of this website and clients engaging our services. This Privacy Policy explains how we collect, use, store, share, and protect your personal data in accordance with applicable Ugandan law and internationally recognised data protection principles.

By accessing our website or contacting us, you acknowledge that you have read and understood this Privacy Policy.

1. Who We Are

Transnet Consultants Ltd is a gold trading firm registered in Uganda with the Uganda Registration Services Bureau (URSB) and licensed by the Ministry of Energy and Mineral Development (MEMD). Our registered office is located in Kampala, Uganda.

For all privacy-related enquiries, contact us at: info@transnet-consultants.com

2. Information We Collect

We may collect the following categories of personal data:

  • Identity Data: Full name, title, and business affiliation.
  • Contact Data: Email address, telephone number, and postal address.
  • Communications Data: The content of emails, phone call notes, and correspondence with us.
  • Transaction Data: Details relating to gold trading enquiries, orders, and transactions.
  • Compliance Data: Know Your Customer (KYC) documentation including government-issued identification, proof of address, and source of funds documentation — required by applicable regulations.
  • Technical Data: IP address, browser type, and basic usage analytics if collected through website infrastructure.

We do not collect sensitive personal data (e.g. biometric, health, or political opinion data) unless required by law.

3. How We Collect Information

  • Directly from you: when you contact us by email, telephone, or WhatsApp.
  • During client onboarding: when we conduct KYC and due diligence processes.
  • Through our website: basic technical data may be collected through hosting infrastructure.

4. How We Use Your Information

We process your personal data for the following purposes:

  • To respond to and manage your trading enquiries and service requests.
  • To conduct required regulatory compliance, anti-money laundering (AML), and KYC checks.
  • To fulfil contractual obligations arising from trading agreements.
  • To maintain proper business records as required by Ugandan law.
  • To protect our legal rights and comply with court orders or regulatory demands.

We will not use your data for automated decision-making or profiling.

5. Legal Basis for Processing

We process personal data under the following lawful bases:

  • Contractual necessity: to perform or prepare to perform a trading agreement with you.
  • Legal obligation: to comply with AML, KYC, export control, and regulatory requirements.
  • Legitimate interests: to operate our business effectively, manage communications, and protect against fraud.
  • Consent: where you have given specific consent (which may be withdrawn at any time).

6. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may disclose data to:

  • Regulatory authorities and government agencies as required by law (e.g. MEMD, Uganda Revenue Authority, financial intelligence units).
  • Professional advisors (lawyers, auditors, insurers) bound by confidentiality obligations.
  • Logistics and assay partners involved in fulfilling your transaction, on a need-to-know basis.
  • Financial institutions involved in settlement, as required for transaction processing.

All third parties are required to respect the security of your data and to process it only in accordance with our instructions.

7. International Transfers

As a gold trading business serving international clients, data may be transferred to or processed in countries outside Uganda. Where such transfers occur, we take appropriate safeguards to ensure your data remains protected to standards equivalent to those in this Policy.

8. Data Retention

We retain personal data for as long as is necessary to fulfil the purposes set out in this Policy, including for the duration of any trading relationship and for a period of at least 7 years thereafter, as required by Ugandan commercial and financial regulations. KYC documentation is retained in accordance with applicable AML regulations.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include restricted access controls, secure email communications, and confidentiality obligations for staff handling personal data.

No method of electronic transmission is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

10. Your Rights

Subject to applicable law, you have the right to:

  • Access the personal data we hold about you.
  • Request correction of inaccurate data.
  • Request erasure of your data (where no legal obligation requires us to retain it).
  • Object to or restrict processing in certain circumstances.
  • Withdraw consent (where processing is based on consent).

To exercise any of these rights, please contact us at info@transnet-consultants.com. We will respond within 30 days.

11. Cookies and Website Analytics

This website may use minimal technical cookies required for basic functionality. We do not currently use third-party tracking, advertising, or behavioural analytics cookies. If this changes, this Policy will be updated accordingly.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites and encourage you to read their privacy policies before submitting personal data.

13. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be posted on this page with a revised effective date. We encourage you to review this Policy regularly. Continued use of our services after changes constitutes your acceptance of the updated Policy.

14. Contact and Complaints

If you have questions, concerns, or complaints regarding this Privacy Policy or how we handle your data, please contact us:

Transnet Consultants Ltd
Kampala, Uganda
Email: info@transnet-consultants.com
Phone: +256 769 650 839

If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.