Privacy Policy

1.1 We are Bowline Knot Company Limited, a company incorporated in Uganda, with registered office at Plot 8, Spring Road, Nakawa, Kampala, trading as "OmutiClub". We are the data controller of your personal information when you use the Services.

1.2 You can contact us on support@omuticlub.com.

2.1 This Policy applies to personal information we collect through the App, our website, customer-support channels, and from third parties (including KYC vendors, the Custodian and the Fund Manager) in connection with the Services. It is intended for natural persons aged 18 or over.

3.1 We do not collect precise GPS location. We do not use third-party advertising trackers in the App. We do not sell your personal information.

We use your personal information to: (1) provide and operate the Services, including the Wallet, Orders to the Fund Manager, statements and Club tools; (2) verify your identity and meet our KYC, AML, sanctions, PEP, fraud-prevention and tax obligations; (3) process payments and settlements with the Custodian, the Fund Manager and payment-service providers; (4) communicate with you about your account, transactions, security and changes to the Services; (5) provide customer support and resolve disputes; (6) monitor, secure, debug and improve the Services, including via aggregated analytics and crash reports; (7) comply with applicable law, court orders and lawful demands by the FIA, BoU, CMA, Uganda Revenue Authority and Personal Data Protection Office ("PDPO"); and (8) with your separate consent, send marketing about OmutiClub features. You may withdraw marketing consent at any time.

We rely on the following legal bases under section 7 of the Data Protection and Privacy Act, 2019: (a) performance of a contract with you (Services delivery, Wallet, Orders); (b) compliance with a legal obligation (KYC, AML, tax, regulator demands); (c) our legitimate interests (security, fraud prevention, analytics, product improvement, debt recovery), balanced against your rights; and (d) your consent (marketing, optional contact-list access for Club invites, biometric login).

6.1 Where we are required to disclose information by law, court order or a lawful demand by a competent authority, we may do so without notifying you, particularly where notification is prohibited (for example, under AML "tipping-off" rules).

6.2 We do not sell or rent your personal information. We do not share your data with third parties for cross-app advertising or tracking.

7.1 Some of our service providers may process your data outside Uganda. Where we transfer personal data internationally, we do so on the basis of: (a) adequacy under section 19 of the Data Protection and Privacy Act, 2019; (b) standard contractual safeguards with the recipient; or (c) your explicit consent. We will identify the hosting region in the App's privacy disclosures and update it if it changes.

9.1 We use technical and organisational measures appropriate to the risk, including: TLS in transit; AES-256 at rest for sensitive data; environment segregation; least-privilege access controls and audit logging; biometric and PIN-based authentication on the device; periodic vulnerability scanning and code review; secure software-development practices; vendor due diligence; and staff training.

9.2 No system is completely secure. You are responsible for keeping your device, credentials, biometric, PIN and OTP codes confidential, and for notifying us immediately at support@omuticlub.com if you suspect unauthorised access.

9.3 Where we suffer a personal-data breach that is likely to result in risk to your rights and freedoms, we will notify the Personal Data Protection Office and affected Users within 72 hours of becoming aware, in line with regulations under the Data Protection and Privacy Act, 2019.

11.1 Under the Data Protection and Privacy Act, 2019, you have the right to: (a) access your personal data; (b) correct inaccurate data; (c) request deletion (subject to legal retention obligations under AML/tax law); (d) object to or restrict certain processing; (e) data portability for data you provided; (f) withdraw consent where processing is based on consent; and (g) lodge a complaint with the Personal Data Protection Office ("PDPO") of Uganda.

11.2 To exercise your rights, contact us at dpo@omuticlub.com. We will respond within thirty (30) days. We may need to verify your identity before acting on a request.

11.3 In-App Account and Data Deletion. You can request deletion of your account and personal data from inside the App. Tap Profile, then Settings, then Account, then Delete Account, and follow the on-screen steps. You can also email support@omuticlub.com from your registered email address requesting deletion. On receiving a deletion request we will: (a) close any open Orders and prompt you to redeem Units and withdraw your Wallet balance; (b) delete or anonymise your personal data within thirty (30) days, except information we are required to retain under AML, tax or other applicable law (see section 8); and (c) confirm deletion to you.

The Services are intended for users aged 18 or over. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child, we will delete it promptly.

13.1 Apple Privacy Nutrition Label. Data linked to you: Contact Info, Identifiers (national ID, passport, TIN), Financial Info, Sensitive Info (selfie image, biometric on-device only), Usage Data, Diagnostics, Device ID, Coarse Location, Contacts (only when you initiate Club invites). Data not used to track you. No third-party advertising SDKs are included in the App.

13.2 Google Play Data Safety. Data collected and shared aligns with the categories above. Data is encrypted in transit and at rest. Users can request data deletion in-app and by email per section 11.3. We comply with the Google Play Financial Services and Families policies.

We may update this Policy from time to time. We will give at least thirty (30) days' prior in-app and email notice of any material change. Non-material changes (such as drafting fixes) take effect on posting in the App. The Effective Date on the cover indicates the version in force.

Bowline Knot Company Limited (OmutiClub)
Plot 8, Spring Road, Nakawa, Kampala, Uganda
Email: support@omuticlub.com