Effective Date: January 2026
WHO WE ARE?
The Anti-Counterfeit Network Africa Ltd (ACN) is a registered private sector organization dedicated to bridging intervention gaps among the various stakeholders that influence, and are impacted by, counterfeiting and parallel imports in Uganda. ACN designs and implements strategies aimed at controlling counterfeits and parallel imports through research and market surveys, provision of legal redress, mindset training, structured dialogue, and behavior-change–centered communication targeted at key sector stakeholders and the general public.
ACN Africa is committed to safeguarding the fundamental human right to privacy of all individuals with whom it engages. We recognize the importance of respecting and protecting personal data that is collected by, or disclosed to, us (“personal data”), as further defined below:
This Privacy Notice explains how ACN Africa collects, uses, discloses, and otherwise processes personal data through its website, in accordance with the Data Protection and Privacy Act, its attendant Regulations, and other applicable data protection laws.
IMPORTANT TERMS YOU NEED TO UNDERSTAND WHEN READING THIS POLICY
| Term | Definition/Meaning |
| Data Subject | ❖ Is an individual from whom or in respect of whom personal information has been requested, collected, collated, processed or stored. |
| Consent | ❖ Means any freely given, specific, informed and unambiguous indication of the data subject’s wish which he or she, by a statement or by a clear affirmative action, signifies agreement to the collection or processing of personal data relating to him or her. |
| Personal data | ❖ means information about a person from which the person can be identified, that is recorded in any form and includes data that relates to: a) the nationality, age or marital status of the person; b) the educational level, or occupation of the person; c) an identification number, symbol or other particulars assigned to a person; d) identity data; e) other information which is in the possession of, or is likely to come into the possession of the data controller and includes an expression of opinion about the individual; |
| Processing | ❖ means any operation which is performed upon collected data by automated means or otherwise including: a) organization, adaptation or alteration of the information or data; b) retrieval, consultation or use of the information or data; c) disclosure of the information or data by transmission, dissemination or otherwise making available; d) alignment, combination, blocking, erasure or destruction of the information or data; |
| Sensitive Personal data | ❖ A sub-set of personal data which is considered more sensitive than other categories of personal data. ❖ Sensitive personal data includes but is not limited to personal data revealing a data subject’s racial or ethnic origin; political opinions or persuasions; religious or philosophical beliefs; trade union membership, genetic data, biometric data concerning health; and or data concerning a data subject’s sex life or sexual orientation. |
WHAT DATA DO WE COLLECT AND PROCESS?
ACN Africa may collect, process, store, use, disclose, and otherwise transfer various categories of personal data relating to its clients, employees, service providers, agents, partners, and other stakeholders, as necessary for the purpose of conducting its operations and fulfilling its legal, contractual, and regulatory obligations. Such personal data may be collected directly from data subjects or obtained indirectly from lawful and legitimate sources. ACN Africa processes personal data in accordance with applicable data protection laws and principles, including lawfulness, fairness, and transparency, and ensures that personal data is adequate, relevant, accurate, limited to what is necessary for the intended purposes, retained only for as long as required, and protected through appropriate technical and organizational measures to safeguard its integrity, confidentiality, and security.
The table below summarizes the types of data that we collect and process.
| Type of Information | Examples |
| Identification and contact information | Telephone number, email address, social media accounts |
| General information | Age, gender, profession |
| Audio-visual information | Photographs, videos |
| Online activity information | Data obtained as a result of interacting with ACN website. |
| Communications and Correspondence | Emails, contact form submissions, feedback, inquiries,reports and other communications exchanged through the website or official channels of ACN |
| Location information | General geographic location derived from IP addresses, country, city or region of access |
HOW IS YOUR DATA COLLECTED?
ACN Africa primarily endeavors to collect personal data directly from you in the course of your interactions with us. However, this is not the exclusive means by which personal data may be obtained. In certain circumstances, ACN Africa may also collect personal data from third-party sources, including publicly available databases, regulatory authorities, partners, or other lawful sources, where such collection is permitted by applicable law.
In addition, ACN Africa may collect personal data through the use of technological tools and digital platforms, including cookies and similar tracking technologies, when you access or interact with our website or other online platforms operated or affiliated with ACN Africa.
Where personal data is obtained from third parties, ACN Africa ensures that such data is collected and processed in full compliance with the Data Protection and Privacy Act and its attendant Regulations.
We obtain personal data about you from sources such as:
a) Application forms, proposal forms, registration forms, and any other documentation or forms completed and submitted to ACN Africa through its website;
b) Cookies
c) Technology platforms, digital tools, and software applications made available by ACN Africa for use;
d) ACN Africa’s website and other affiliated digital platforms;
e) Meetings, interviews, telephone conversations, email correspondence, and other forms of communication with ACN Africa;
f) Social media platforms where you engage, interact, or communicate with ACN Africa
WHAT IS THE PURPOSE FOR PROCESSING YOUR PERSONAL DATA?
ACN Africa collects and processes personal data for legitimate and lawful purposes connected to the operation, security, and improvement of its website and services. In particular, personal data may be collected and used for the following purposes:
For Safety, Security, and Integrity: to protect our website, systems, users, and operations from unauthorized access, fraud, misuse, cyber threats, and other security risks, and to ensure the integrity and reliability of our digital platforms.
Provision and Administration of Services: to facilitate the operation, maintenance, and administration of our website and services, including responding to inquiries, reports, requests, and submissions made through our digital platforms.
Communication and Engagement: to communicate with you regarding our services, activities, updates, training programs, events, policy changes, and other information relevant to the provision of our services to you.
Monitoring and Improvement of Services: to monitor and evaluate the performance, reliability, and effectiveness of our website and services, through usage analysis and feedback mechanisms.
TO WHOM DO WE DISCLOSE YOUR DATA?
ACN Africa uses personal data obtained from its website primarily for its internal business operations and purposes related to the fulfillment of its mandate, vision and objectives.
Subject to applicable data protection laws, ACN Africa may disclose personal data to third parties where such disclosure is made at your request, with your consent, or where it is necessary to pursue ACN Africa’s legitimate interests. Such third parties may include, but are not limited to, government authorities, regulatory bodies, law enforcement agencies, business partners, service providers, and relevant industry associations.
Wherever feasible and legally permissible, ACN Africa shall inform you and obtain your consent prior to disclosing your personal data to third parties. Notwithstanding the foregoing, ACN Africa may disclose personal data without your prior consent where such disclosure is required or authorized by the laws of Uganda, Court orders and any other lawful authority.
HOW DOES ACN SECURE MY PERSONAL DATA?
ACN Africa has implemented appropriate physical, technical, legal, and organizational measures designed to safeguard the personal data it collects, processes, stores, and transmits in connection with its services and operations. These measures are intended to protect personal data against unauthorized access, accidental or unlawful loss, alteration, disclosure, or destruction.
Such safeguards include, but are not limited to, requiring employees, agents, and other persons who handle personal data to adhere to strict confidentiality obligations; limiting access to personal data to authorized personnel on a need-to-know basis; and implementing information technology security controls such as user access management, system permissions, firewalls, encryption, and secure network infrastructure.
HOW DO WE RESPOND TO PERSONAL DATA BREACHES?
While ACN implements reasonable and appropriate technical and organizational measures to safeguard personal data, it is acknowledged that no method of data transmission over the internet or electronic storage system is entirely secure. As such, we cannot guarantee absolute security of personal data; however, we remain committed to the continuous review, enhancement, and improvement of our data protection and information security practices in line with evolving technological standards and applicable legal and regulatory requirements.
In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of data subjects, we shall act promptly and responsibly to assess, investigate, contain, and mitigate the impact of the breach. Such response shall be carried out in accordance with ACN’s internal incident management policies and procedures governing the identification, reporting, handling, remediation, and resolution of personal data breaches, and in compliance with applicable data protection laws and regulatory obligations.
USE OF COOKIES AND TRACKING TECHNOLOGIES
ACN Africa’s website uses cookies and similar tracking technologies to enhance user experience, improve website functionality, analyze website usage, and support our operational objectives. Cookies are small text files that are placed on your device when you visit our website and allow the website to recognize your device, store certain preferences, and collect information about how you interact with it and the rest of our online platforms.
The information collected through cookies may include technical and usage data such as your internet protocol (IP) address, browser type, device identifiers, operating system, pages visited, date and time of access, and referring URLs. This information does not usually identify you on its own, but it may still be considered personal data under applicable data protection laws in Uganda and other jurisdictions.
You may choose to restrict, block or delete cookies from our websites through your browser settings. Please note that if you disable all cookies, we cannot guarantee the full functionality or performance of our website, and certain features may not operate as intended.
WHAT ARE YOUR RIGHTS?
Subject to applicable legal limitations, you are entitled to exercise the following rights in relation to your personal data in accordance with the rights accorded to you under the Data Protection and Privacy Laws of Uganda.
a) The Right to object to the processing of your personal data You have the right to object to the processing of your personal data, on grounds relating to your particular situation, where such processing is based on legitimate interests. This includes circumstances where you object to receiving direct marketing communications or where you believe there is no lawful basis for the continued processing of your personal data.
b) The Right to rectification of your personal data You have the right to request the correction of inaccurate personal data and the completion of incomplete personal data held by ACN Africa.
c) The Right to data portability You have the right to receive personal data concerning you in a structured, commonly used, and in a machine-readable format and to request the transmission of such data to another data controller, or third party provided that such transfer is technically feasible.
d) The Right to Access and Correction You have the right to request access to the personal data held about you by ACN Africa through its website and other digital platforms it operates or manages. For security purposes, ACN Africa may require proof of identity and sufficient information about your interactions with us before providing access or making any corrections.
e) The Right to Lodge Complaints with the Personal Data Protection Office You have the right to lodge a complaint with the Personal Data Protection Office if you believe that your data has been processed unlawfully, or that there has been a breach of this privacy policy or applicable the data privacy and protection laws of Uganda.
f) Right to withdraw consent Where the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time. Upon withdrawal, ACN Africa will cease processing your personal data through its website or any other technology digital platforms it operates unless there is an alternative lawful basis for continued processing, in which case you will be duly informed.
g) Rights Relating to Automated Decision-Making and Profiling You have the right not to be subject to a decision based solely on automated processing, including profiling, where such decision produces legal or similarly significant effects on you, except where such processing is permitted by applicable law.
DATA RETENTION
We will not retain your personal data on our website for longer than is necessary to fulfill the purposes for which it was collected and processed, unless:
a) Retention is required or authorized under the applicable laws of the user’s jurisdiction;
b) You have provided consent for the continued retention of your personal data;
c) The data is needed for historical, statistical, or research purposes, and appropriate safeguards have been implemented to ensure it is not used for any other purpose. We will ensure that personal data which is no longer required, or which we are no longer authorized to retain, is de-identified or securely destroyed as soon as reasonably practicable. Where appropriate, this may include permanent erasure using effective and secure methods.
INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA
When you access or use the ACN Africa website or our affiliated digital services, your personal data may be processed or transferred to countries outside Uganda. These countries may have data protection laws that differ from, or provide a lower level of protection than, those in Uganda.
In such instances, ACN Africa will take appropriate measures to ensure that any third-party recipient of your personal data maintains safeguards consistent with Ugandan data protection standards, as well as the principles outlined in this Privacy Policy. These safeguards are designed to protect your personal data from unauthorized access, use, or disclosure.
By continuing to access or use the ACN Africa website and their affiliate digital services, you acknowledge and consent to the international transfer, processing, and storage of your personal data as described above. If you do not wish for your personal data to be transferred to, processed in, or maintained outside the country or jurisdiction in which you reside, you should discontinue access to and use of the website and related services.
CHANGES/AMMENDMENTS TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our data protection practices. Where updates are made, the “Effective Date” at the top of this Privacy Policy will be revised accordingly. Any material changes that may affect you will be communicated through the appropriate channels customarily used to engage with our users, including publication on the website.
CONTACT US
POSTAL ADDRESS: P.O Box 6074 Kampala
EMAIL: info@acnafrica.org
CONTACT DETAILS: +256 393216402