Privacy Policy

1. Who we are

Sentefy is operated by Sentefy Solutions Limited, a company incorporated under the laws of the Republic of Uganda (“Sentefy”, “we”, “us” or “our”). We are the data controller responsible for the personal data we collect through the platform.

If you have any questions about this policy or how we handle your data, you can reach our data protection contact at privacy@sentefy.com.

2. Who this policy applies to

This policy applies to everyone who uses Sentefy, including:

• Campaign creators — individuals and organisations who register to create and manage fundraising campaigns.
• Donors and contributors — people who give to campaigns, whether or not they create an account.
• Visitors to our website and platform.

3. Information we collect

3.1 Account information

When you create an account, we collect your Ugandan mobile phone number, which we use to sign you in securely using a one-time password (OTP) sent by SMS. You may also provide your full name, an email address, a short bio and a profile photo. The OTP code itself is generated and delivered by our authentication provider and is never stored by Sentefy.

3.2 Identity verification (KYC)

Campaign creators must verify their identity before they can activate a campaign or receive funds. It is how contributors know who they are giving to, and it guards against fraud and money laundering.

Today this is a manual review by Sentefy: starting verification creates a request and we contact you directly to confirm your identity. No identity documents or ID numbers are collected through the platform, and no data is sent to any third-party verification provider. The remainder of this section describes the Smile ID integration that is built but not yet live — it becomes accurate only once we switch it on, and we will update this policy and tell you before we do.

Verification will be carried out by Smile ID (Smile Identity Inc.), a specialist identity-verification provider used by banks and financial institutions across Africa. When you verify, you are taken to a secure page operated by Smile ID, where you photograph your National ID and take a selfie. Those images are captured by Smile ID, not by Sentefy. Smile ID authenticates the document, matches your selfie to it, and cross-checks the ID details against the National Identification & Registration Authority (NIRA) database.

When the check is complete, Smile ID sends the result to Sentefy. That result includes some of the identity details Smile ID read from your ID (such as your ID number and date of birth), which we use only momentarily, in memory, to complete the required NIRA cross-check — and then discard. Sentefy permanently stores only the outcome of the verification: whether it passed or failed, which checks were performed, and reference numbers. We never keep or log your ID images, selfie, National Identification Number or date of birth. Smile ID processes your identity data under its own privacy policy, available at smile.id/privacy-policy.

3.3 Enhanced checks for large donations

For large donations (currently those of UGX 5,000,000 or more), we carry out enhanced due diligence before processing the payment. We ask you to provide the source of the funds, the purpose of the transaction, how frequently you expect to give, and, optionally, your relationship to the campaign. This information is encrypted and held with the donation record for the retention period required by law.

3.4 Donation and contribution information

When you make a donation, we collect the amount, the payment status, and the reference provided by our payment partner. If you choose to provide them — whether or not you have an account — we collect your name, phone number and email so the campaign can recognise your contribution. You may also give anonymously, in which case your donation is linked only to the campaign and the payment reference.

3.5 Campaign information

If you create a campaign, we collect the campaign title, description, fundraising goal and any images you upload. This information may be displayed publicly or, for invitation-only campaigns, to invited supporters.

3.6 Transaction and technical information

To keep the platform secure and to meet our record-keeping obligations, we log details of each payment event, including the data exchanged with our payment partner and any error information. We also use IP addresses temporarily to limit abusive or automated requests.

To see which pages people use, we count visits with Vercel Web Analytics, which sets no tracking cookies. For each visit it records the page address (without any invitation or sign-in code), the site you came from, your approximate location (country and city), and your browser, operating system and device type. It does not tie visits to your name, phone number or IP address, and it forgets who you are after 24 hours, so it cannot follow you from one day to the next.

To keep pages fast on slow connections, Vercel Speed Insights measures how quickly each page loads. With each measurement it records the page address (again without any code), your connection speed (such as 3G or 4G), your country, and your browser, operating system and device type. It is not tied to you or your IP address.

3.7 Compliance information

We keep records of the identity checks described above, of the additional information collected for large donations, and of any reports we are required to make to the authorities. Where the law requires it, we will share transaction and identity data with the Financial Intelligence Authority, the Bank of Uganda or other authorities.

We screen campaign creators against sanctions lists. When a creator’s identity is verified, and every night while they stay verified, we compare the name on their account with the United Nations Security Council Consolidated List, the sanctions list of the United States Treasury (OFAC) and the UK Sanctions List. We download those lists from the official sources and compare the names on our own systems, so your name is not sent to any screening provider. We use the name only, not your date of birth or ID number.

A name alone often fits a different person, so a possible match is looked at by a person before anything is decided. Until then a verification waits, and nothing happens automatically to a creator who is already verified. We keep the result: when the screening was done, whether anything matched, the listed entry it matched and any decision about it, with the reviewer’s note. We do not screen the names donors enter when they contribute.

We also ask each creator whether they, or a close family member, hold a senior public position (a “politically exposed person”). We keep the answer with the verification. A “yes” means a person checks the verification by hand, which can include a search of public news about the name. We do not use a paid list of politically exposed persons.

3.8 Cookies and storage on your device

Sentefy keeps a few small things on your phone or computer, only to make the platform work. We use no advertising or tracking cookies, and nothing here is shared with advertisers.

• Signing in (a cookie named sb-…-auth-token) — keeps you signed in after you log in with your phone number. It expires after seven days without use, and signing out removes it. Contributors, who never sign in, never get it.
• Your dashboard’s side menu (a cookie named sidebar-open) — remembers whether you left it open. Kept for a year.
• Your last visit (a cookie named sentefy-last-visit) — the time you last left your dashboard on this device, so contributions that came in since can be marked as new. It holds only that time, is sent only to your dashboard, and is kept for a year.
• A payment in progress (your browser’s storage, not a cookie) — while a mobile money payment waits for approval on your phone, your browser remembers its amount and the last four digits of the number, so the page can still show where it stands if you come back to it. It is cleared once the outcome is known, and dropped after 24 hours.
• A report you made (your browser’s storage) — after you report a campaign, your browser remembers that you did, so the same report isn’t sent twice.

When you report a campaign, the form uses Cloudflare Turnstile to check that you are a person rather than an automated program. Turnstile also checks each request for a sign-in code, before Sentefy texts or emails one. Cloudflare processes technical information about your browser to do this, under its own privacy policy.

You can clear all of these in your browser’s settings. Clearing the sign-in cookie signs you out.

4. How we use your information and our legal basis

We use your personal data to:

• create and manage your account and provide the platform to you;
• process donations and provide campaign creators with records of funds received;
• verify your identity and meet our KYC and anti-money-laundering obligations;
• keep financial and audit records as required by Ugandan law;
• detect, prevent and investigate fraud and abuse;
• communicate with you about your account, campaigns or contributions; and
• improve the security and reliability of the platform.

Depending on the activity, we rely on one or more of the following legal bases under the Data Protection and Privacy Act, 2019: performance of our contract with you; compliance with a legal obligation (for example, KYC, AML and record-keeping requirements); your consent (for example, when you choose to begin identity verification); and our legitimate interests in operating a secure and trustworthy platform.

5. Who we share information with

We do not sell or rent your personal data. We share it only with the service providers who help us operate the platform, and with authorities where the law requires it. Each provider listed below processes data under its own privacy policy.

• pawaPay — our mobile money payment partner. We send the donor’s phone number and the donation amount so the payment can be authorised through MTN Mobile Money or Airtel Money. pawaPay returns a transaction reference and status. We never receive or store your mobile money PIN.
• Smile ID (Smile Identity Inc.) — our intended identity-verification partner. No data is sent to Smile ID today: the hosted check is built but not switched on, and verification is currently a manual review (section 3.2). Once it is live, campaign creators will submit their National ID photos and selfie on Smile ID’s own secure page rather than through Sentefy, and we will store only the outcome and reference numbers. We will update this policy before that begins.
• Supabase — our backend infrastructure provider, which hosts our database, authentication and file storage.
• Vercel — our website and application hosting provider, which also counts page visits and measures page speed for us (see 3.6).
• Sentry — our error-monitoring provider, which helps us detect and fix technical problems.
• Regulators and authorities — including the Bank of Uganda, the Financial Intelligence Authority and the Personal Data Protection Office, where we are legally required to report or disclose information.

6. What we do not collect

To be clear, we never collect or store:

• any lasting copy of your identity-document images, your selfie, your National Identification Number or your date of birth — today no identity documents are collected through the platform at all. If we switch on the hosted Smile ID check, capture will happen on their secure page, and any identity detail reaching Sentefy inside a result will be used only momentarily and never stored or logged;
• your mobile money PIN, password or any payment authentication credential;
• card numbers, card security codes or card expiry dates (we do not offer card payments);
• your one-time login codes (OTPs); or
• your real-time location.

7. How long we keep your data

We keep personal data only as long as necessary for the purposes described in this policy, or for as long as the law requires us to.

• Verification outcomes, donation, transaction and compliance records are kept for 10 years, in line with anti-money-laundering requirements. We are not able to delete these records earlier on request, as we are legally required to retain them. Sentefy holds no identity documents at all — none are collected through the platform.
• Account and profile information is kept for as long as your account is active and is anonymised shortly after you close your account.
• Campaign information is kept as a record of the fundraising activity.
• Abuse reports have the reporter’s identity and details removed after 90 days.
• Short-lived technical data (such as rate-limiting records) is kept only for minutes to hours.

8. International data transfers

Some of our service providers store and process data on servers located outside Uganda (for example, in the European Union and the United States). Where your personal data is transferred outside Uganda, we take steps to ensure it remains protected to a standard consistent with Uganda’s Data Protection and Privacy Act, 2019, including through our agreements with those providers.

9. Your rights

Under the Data Protection and Privacy Act, 2019, you have the right to:

• access the personal data we hold about you;
• ask us to correct inaccurate or incomplete data;
• ask us to delete your data, except where we are legally required to keep it (for example, financial and KYC records);
• ask us to restrict or object to certain processing; and
• withdraw your consent where our processing is based on consent.

To exercise any of these rights, contact us at privacy@sentefy.com. We aim to respond within 30 days. You also have the right to lodge a complaint with Uganda’s Personal Data Protection Office if you believe your data has been handled unlawfully.

10. How we protect your data

We use technical and organisational measures to protect your data, including encrypted connections, encryption of sensitive compliance information at rest, access controls that limit who can view sensitive information, a no-retention design for identity documents (none are collected through the platform today; if the hosted check is switched on, capture happens on our partner’s secure page and any identity detail returned to us is used only transiently and never stored), verified payment notifications, and limits to prevent abuse. If a data breach occurs that affects your rights, we will notify the Personal Data Protection Office and affected individuals as required by law.

11. Children's privacy

Sentefy is not intended for anyone under 18 years of age, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

12. Changes to this policy

We may update this policy from time to time. When we make material changes, we will update the “Last updated” date above and, where appropriate, notify you through the platform. Please review this policy periodically.

13. How to contact us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

• Sentefy Solutions Limited, Uganda
• Data protection: privacy@sentefy.com
• General support: support@sentefy.com

This Privacy Policy should be read together with our Terms & Conditions.