Privacy Policy

Last updated: 10/3/2026

1. Introduction

UpSend ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our payment services. By using UpSend, you agree to the collection and use of information in accordance with this policy.

UpSend is a product of CodeLab Enterprise Limited, a company registered in Uganda. We take your privacy seriously and are committed to protecting your personal information in accordance with the Data Protection Act, 2019 of Uganda and other applicable data protection laws.

2. Information We Collect

We collect the following types of information:

2.1 Personal Information

  • Full name and date of birth
  • Email address and phone number
  • Physical address
  • National ID or passport number (for verification)
  • Profile picture (optional)

2.2 Financial Information

  • Bank account details (encrypted)
  • Mobile money wallet information (MTN, Airtel)
  • Card information (encrypted)
  • Transaction history and amounts
  • Payment method preferences

2.3 Device and Technical Information

  • IP address and location data
  • Device type, model, and operating system
  • Browser type and version
  • Mobile network operator
  • Unique device identifiers

2.4 Usage Data

  • Pages visited and time spent
  • Features accessed
  • Transaction frequency and patterns
  • Error logs and crash reports

3. How We Use Your Information

We use your information to:

  • Process and complete your transactions
  • Verify your identity and prevent fraud
  • Provide customer support and respond to inquiries
  • Send important notifications about your account
  • Improve our services and develop new features
  • Comply with legal and regulatory requirements
  • Conduct security audits and risk assessments
  • Send marketing communications (with your consent)

4. Data Security

We implement industry-standard security measures to protect your information:

  • 256-bit SSL/TLS encryption for all data in transit
  • AES-256 encryption for stored sensitive data
  • Secure servers with 24/7 monitoring
  • Regular security audits and penetration testing
  • Multi-factor authentication for account access
  • Strict access controls for our employees

However, no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

5. Data Retention

We retain your information for the following periods:

  • Transaction records: 7 years (as required by financial regulations)
  • Account information: Until account closure + 7 years
  • Marketing communications: Until you opt-out + 30 days
  • Usage analytics: 2 years
  • Support tickets: 3 years after resolution

6. Your Rights

Under applicable data protection laws, you have the right to:

  • Access: Request a copy of your personal information
  • Correction: Request correction of inaccurate information
  • Deletion: Request deletion of your information (where legally permissible)
  • Portability: Request transfer of your data to another service
  • Objection: Object to processing of your information
  • Restriction: Request restriction of processing
  • Withdraw Consent: Withdraw consent at any time

7. Third-Party Disclosures

We may share your information with the following parties:

  • Mobile Network Operators: MTN Uganda and Airtel Uganda for transaction processing
  • Payment Processors: Banks and financial institutions for payment processing
  • Regulatory Authorities: Bank of Uganda and other regulators as required by law
  • Service Providers: Cloud hosting, security, and analytics providers
  • Law Enforcement: When required by valid legal process

We never sell your personal information to third parties for marketing purposes.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Remember your preferences and settings
  • Analyze website traffic and usage patterns
  • Improve our services and user experience
  • Provide personalized content and recommendations

You can control cookies through your browser settings. See our Cookie Policy for more details.

9. International Data Transfers

Your information may be transferred to and processed in countries other than Uganda. We ensure appropriate safeguards are in place to protect your information in accordance with applicable data protection laws.

10. Children's Privacy

Our services are not intended for children under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will take steps to delete such information.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on our website and updating the "Last updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.

12. Contact Us

If you have questions about this Privacy Policy or your personal information, please contact us:

  • Email: privacy@upsend.ug
  • Phone: +256 315 100 011
  • Address: 77 Market Street, Bugiri Municipality, Uganda