Snowvue Technologies Limited · Version 1.2 — Website Edition · Last updated November 2026

Privacy Policy

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1. Who We Are

This Privacy Policy explains how Snowvue Technologies Limited (“Snowvue,” “we,” “us,” or “our”), a private company limited by shares incorporated under the laws of Uganda (Companies Act 2012), with its Uganda registered office at Wampewo, Kampala, Uganda, collects, uses, discloses, and safeguards your information when you use the Snowvue mobile app, Progressive Web App, and any related services we operate under that brand (collectively, the “Platform”). Snowvue Technologies Limited is the data controller for personal data processed through the Platform.

Corporate structure & beneficial ownership

The Platform is operated by Snowvue Technologies Limited, a Uganda private company limited by shares. Beneficial-ownership details are maintained in the URSB Beneficial Ownership Register and are available on lawful request. Shareholders do not have access to user data. Access is limited to authorised staff, our Data Protection Officer and our auditor, each under a contractual confidentiality obligation. “Snowvue” is a trademark of Snowvue Technologies Limited.

2. Scope and Governing Law

This Policy applies to all users of the Platform. We comply with applicable data-protection laws, including but not limited to:

• The Uganda Data Protection and Privacy Act, 2019 (“Uganda DPPA”) and the Data Protection and Privacy Regulations, 2021;
• The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA/CPRA”);
• The EU General Data Protection Regulation and the UK GDPR (where applicable);
• Any other state, federal, or national privacy laws that apply to you.

3. Definitions

• Personal Data — any information that identifies or could reasonably identify you.
• Agricultural Data — information you record about your farming activities, including crops, livestock, yields, inputs, expenses, weather observations, and field locations.
• Aggregate Data — data that has been combined and stripped of identifiers so that it cannot reasonably be linked back to you.
• Processor — a third-party we engage to process Personal Data on our behalf under contract.

4. Information We Collect

4.1 Account & Profile Information

Name, email, phone (only collected if you choose to provide it for password reset), preferred language (English/French/Swahili), district, role (farmer, local admin, global admin), avatar (optional).

4.2 Authentication & Security Data

Securely hashed password or PIN, Multi-Factor Authentication seeds for Multi-Factor Authentication (MFA), backup codes, login timestamps, IP addresses, device user-agent, and risk-scoring signals used to detect brute-force attempts.

4.3 Agricultural Data

Crop type, growth stage, area under cultivation (acres), pest and disease observations, harvest and yield records, expense and sales entries, activity logs.

4.4 Market Price Data

Prices you report for produce in named districts, your reporter score, and verification status.

4.5 Marketplace Data

• Barter listings: item description, photos, district, owner display name, handshake-verification PINs.
• Sell listings: item, price, quantity, unit, photos, district, status (active, sold, removed).
• Chat threads: messages exchanged with buyers/sellers, timestamps. Phone numbers are never displayed inside the marketplace UI to other users.
• Deals: sale value, service-fee percentage (6% individual / 4% SACCO), payment status, mutual buyer/seller ratings.

4.6 Aerial Mapping Imagery Data

When you upload an aerial mapping scan we collect: the image, optional GPS-boundary GeoJSON, area (acres), crop type, growth stage, pest and disease severity. EXIF metadata, including embedded GPS coordinates inside the image file, is stripped on upload before storage — only the boundary GeoJSON you explicitly draw is retained.

4.7 AI Inputs and Outputs

Queries you submit to our AI assistant, AI yield estimates derived from your inputs, pest/disease analysis results, and AI moderation classifications applied to user-generated content.

4.8 Weather Data

District-level weather forecasts and severe-weather alerts retrieved from third-party weather APIs (see §6 below); we associate forecasts only with district names you select — not with your precise coordinates.

4.9 Push Notification Tokens

If you grant notification permission, we collect anonymous device push tokens issued by Apple or Google so we can deliver weather alerts and marketplace updates.

4.10 Technical and Usage Data

Device information, IP address, app version, language, crash logs, audit logs (every administrative action), and rate-limit counters.

4.11 Cookies and Similar Technologies

Strictly-necessary cookies for session management (HTTP-only, Secure, SameSite-Lax), and consent-stored cookie preferences. We do not use advertising or behavioral tracking cookies.

5. How We Use Your Information

We use your information to:

• Provide and operate the Platform, including agricultural record management, market price reporting, marketplace, aerial mapping, AI insights, and weather alerts;
• Authenticate you and protect your account (including MFA, brute-force lockout, and audit logging);
• Facilitate transactions between users (Barter, Sell marketplace, SACCO onboarding);
• Process the fees you authorise and reconcile them;
• Generate AI yield estimates, pest/disease analyses, and moderation classifications;
• Deliver weather alerts, push notifications, and broadcasts you opt into;
• Improve the Platform through internal analytics using aggregated and de-identified data only;
• Comply with legal obligations and respond to lawful requests from authorities;
• Detect and prevent fraud, abuse, and security incidents. We do not sell your Personal Data, and we do not use your Personal Data for targeted advertising.

6. Named Third-Party Processors

We use carefully selected third-party service providers (“processors”) who handle personal data on our behalf under written data-processing agreements. They fall into the following categories:

Where your data is stored. Your personal data may be stored and processed in data centres located outside Uganda. Wherever data is stored, we apply the safeguards required by the Uganda Data Protection and Privacy Act, 2019 (including written data-processing agreements and appropriate contractual clauses) and, where applicable, the EU/UK GDPR.

We contractually require every processor to apply technical and organisational measures consistent with the Uganda DPPA and industry best practice, and to process your data only on our documented instructions. A current list of processor categories is available from our Data Protection Officer on request.

7. AI Processing Disclosure

When you use AI-powered features (yield estimates, pest/disease analysis, AI Q&A, content moderation), the inputs (and, for image features, the image itself) are transmitted to our artificial-intelligence service provider (see §6). AI outputs are advisory only and do not constitute professional agronomic, veterinary, or financial advice. We retain the inputs and outputs solely for service quality, audit, and dispute resolution.

8. Aerial Mapping Imagery

Aerial mapping scans you upload are stored in either:

• Personal scope — visible only to you and our administrators in case of legal request, or
• SACCO scope — visible to your cooperative’s administrators and members. All aerial mapping scans are automatically deleted 365 days after upload automatically, unless you delete them sooner via your profile. We strip EXIF GPS metadata from aerial image files before storage; the only geographic information retained is the field boundary you explicitly draw.

8A. Energy Estimate (Wellbeing Feature)

If you switch on “Show my energy estimate”, the app estimates the calories you burnt on the farm today from the activities you log, using published exertion values (MET) and a weight band you choose. This is health-related information (special personal data under DPPA s.9), so:

• It is off by default and requires your separate, explicit consent (Consent Form item “Energy estimate”).
• The weight band and the estimate are calculated and stored only on your device (secure storage). They are never uploaded, never used for research, advertising, matching, or shared with sponsors, SACCOs, or extension officers.
• We store only the consent event (on/off, timestamp, policy version) for audit purposes.
• It is an estimate, not medical advice. There are no goals, rankings, or comparisons with other farmers.
• Turning it off deletes the weight band and history from your device immediately.
• The feature is available to adults (18+) only.

9. Privacy-Safe Map Aggregates

When Personal Data is rendered on aggregate heat-maps (e.g., reported price density, aerial-scan density), we apply a K-anonymity threshold of K ≥ 20: any grid cell containing fewer than 20 contributing records is suppressed or shown as null, so an individual user cannot be re-identified from the map.

10. Photo Content and Metadata

For marketplace and community-shorts photos you upload, we strip EXIF GPS metadata before storage. The image you see, and the image other users see, contains no embedded location data.

11. Push Notifications

With your permission, we send push notifications for severe weather, marketplace activity, admin broadcasts, and refund updates. You may revoke push permission at any time through your device settings; in-app notifications remain available.

12. How We Share Information

We disclose Personal Data only:

• With your direction — advisors, extension officers, SACCO administrators, or buyers/sellers you choose to transact with;
• In a Barter or Sell transaction — limited contact information shared with the counterparty after both parties confirm the deal;
• To processors named in §6, under contract;
• To research partners — only de-identified, aggregated datasets, never your raw records;
• As required by law — court order, regulator demand, or to protect rights, property, or safety;
• In a corporate transaction — successor entity in a merger or acquisition, subject to this Policy.

13. Cross-Border Transfers

Your personal data may be stored and processed in data centres located outside Uganda. Wherever data is stored, we apply the safeguards required by the Uganda Data Protection and Privacy Act, 2019 (including written data-processing agreements and appropriate contractual clauses) and, where applicable, the EU/UK GDPR. We do not transfer your personal data to any country for the purpose of selling it or for targeted advertising.

14. Geographic Eligibility

The Platform is geofenced for use within the Republic of Uganda. While accounts may be created or accessed elsewhere, all marketplace, price-reporting, and SACCO features are restricted to Ugandan districts.

15. Children's Privacy

The Platform is intended for users aged 18 years or older. We do not knowingly collect Personal Data from anyone under 18. If we learn we have collected such data, we will delete it without undue delay. Parents or guardians who believe their child has provided data to us may contact privacy@snowvue.com.

16. Security Measures

We apply technical and organisational measures appropriate to the risk, aligned with recognised industry standards, including:

• Encryption of data in transit and at rest;
• Secure hashing of passwords and PINs — we never store them in readable form;
• Optional Multi-Factor Authentication with backup recovery codes;
• Protection against brute-force sign-in attempts and automated abuse;
• Role-based access control and separation of duties for administrators;
• Logging of administrative actions;
• Regular security reviews and vulnerability assessments. No system is perfectly secure. Strong security also depends on you keeping your PIN or password private and enabling Multi-Factor Authentication.

17. Data Retention Schedule

Upon receipt of a verified deletion request, we permanently delete or fully de-identify your data within the timeframes above, except where law requires longer retention.

18. Your Rights

Subject to applicable law, you have the right to:

• Access — obtain confirmation of, and a copy of, the Personal Data we hold about you (delivered in a common machine-readable format via Profile → Export my data);
• Correct — update inaccurate or incomplete data via the in-app profile editor;
• Delete — request erasure of your account and Personal Data;
• Port — receive your data in a machine-readable format;
• Restrict or Object — limit certain processing activities;
• Withdraw Consent — at any time, without affecting prior lawful processing;
• Lodge a Complaint — with the Uganda Personal Data Protection Office (PDPO) or with your local data-protection authority. To exercise any right, email privacy@snowvue.com. We respond within 30 days. We will verify your identity before acting on any request.

19. Data Protection Officer (DPO)

Snowvue Technologies Limited has appointed a Data Protection Officer in accordance with Uganda DPPA §§27–28:

• Name / Title: Data Protection Officer, Snowvue Technologies Limited
• Email: privacy@snowvue.com
• Postal address: Wampewo, Kampala, Uganda Registration with the Uganda Personal Data Protection Office (PDPO) is in progress.

20. Breach Notification

In the event of a personal-data breach that is likely to result in a risk to your rights or freedoms, we will:

• Notify the Uganda Personal Data Protection Office within 72 hours of becoming aware of the breach, in accordance with Uganda DPPA §§27–28;
• Notify affected users without undue delay, by email and in-app banner, where the breach poses a high risk;
• Publish a summary of remediation actions on our website.

21. Changes to This Policy

We may update this Policy. Material changes will be notified at least 30 days before they take effect by in-app banner and email, and will increment the version number. Continued use after the effective date constitutes acceptance. Each version is archived and available on request.

22. Contact Us

• Privacy inquiries: privacy@snowvue.com
• DPO: privacy@snowvue.com
• Support: support@snowvue.com
• Postal: Snowvue Technologies Limited, Wampewo, Kampala, Uganda

© 2026 Snowvue Technologies Limited. All rights reserved.

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