Privacy Policy

At 2geme.org, we are committed to safeguarding your privacy and protecting your personal and health data. This Privacy Policy outlines how we collect, use, share, and secure your information in line with Uganda’s data protection laws and health sector guidelines.

1. Who We Are

2geme.org is a Ugandan startup focused on improving immunization programs by offering free tools to parents, caregivers, and healthcare providers. We are registered with the Personal Data Protection Office (PDPO) under the National Information Technology Authority (NITA-U) to ensure compliance with Uganda’s data protection framework.

Data Controller: 2geme.org determines how and why your personal data is processed.
Contact: Reach us at info@2geme.org or our physical address.

2. What Data We Collect

We collect only the data necessary to provide our services and support Uganda’s immunization efforts. This includes:

Personal Information:
- For parents/caregivers: Name, phone number, and relationship to the child (e.g., parent or guardian).
- For children: Name, date of birth, and vaccination history.
- For healthcare providers: Name, professional ID, and workplace details.
Health Data: Vaccination records, appointment schedules, and related health information (considered sensitive under Ugandan law).
Usage Data: Automatically collected data like device type, app usage patterns, and interaction logs.
Feedback Data: Information you share via surveys, forms, or support requests.

We do not collect data on religious beliefs, political opinions, sexual life, or financial details unless required by law or with your explicit consent.

3. How We Collect Data

We gather data through:

Direct Input: When you register, schedule appointments, or provide feedback via the 2geme app or dashboard.
Healthcare Providers: When they update vaccination records or manage appointments for you.
Automated Means: Through app analytics (e.g., how you use features) to enhance our services.
Partners: With your consent, from authorized health organizations like the Uganda Ministry of Health for public health purposes.

4. Why We Collect Data

Your data helps us deliver 2geme’s services and improve vaccination outcomes. We use it to:

Provide personalized vaccination schedules and reminders.
Maintain accurate digital immunization records.
Offer vaccine-related educational content.
Enable healthcare workers to monitor vaccination progress.
Create anonymized, aggregated data for public health insights (e.g., vaccination trends).
Enhance our app and dashboard based on usage and feedback.

We process data only with your explicit consent, except when:

Required by law (e.g., public health reporting).
Necessary for medical or public health purposes.
Used for anonymized research or statistics.

5. Legal Basis for Processing

We process your data under the Data Protection and Privacy Act, 2019, based on:

Consent: You (or your guardian, for children) agree to data collection and use.
Legal Obligation: To meet public health or regulatory requirements.
Public Duty: To support Uganda’s immunization goals.
Legitimate Interests: To improve our services, without compromising your rights.

Children’s data requires prior consent from a parent or guardian, unless processing is legally mandated or for research.

6. How We Protect Your Data

We prioritize the security of your data, especially sensitive health information. Our safeguards include:

Encryption: Data is encrypted in transit and at rest using industry-standard methods (e.g., SSL/TLS).
Access Controls: Only authorized personnel access data, based on their roles.
Multi-Factor Authentication (MFA): Required for dashboard logins.
Audit Logs: We track all data access for accountability.
Anonymization: Aggregated data for analytics cannot identify you.
Regular Audits: We assess and update security measures periodically.

These align with the Uganda Health Data Protection, Privacy, and Confidentiality Guidelines. While no system is fully immune to breaches, we use best practices to protect your data.

2geme.org Terms of Use

Last Updated: December 14, 2025

These Terms of Use (“Terms”) constitute a legally binding agreement between you, whether personally or on behalf of an entity (“you” or “User”), and TUBAGEME TECHNOLOGIES UGANDA LIMITED (“2geme,” “Company,” “we,” “us,” or “our”), governing your access to and use of the 2geme mobile application (“App”), website (“Website”), and any related media, channels, or connected services (collectively, the “Platform” or “Site”).

By accessing or using the Platform, you confirm that you have read, understood, and agree to be bound by these Terms, our Privacy Policy, and any applicable laws.

If you do not agree with these Terms, or if you are under the age of eighteen (18), you must not access or use the Platform. We reserve the right to update these Terms at any time, and changes will be effective upon posting with an updated “Last Updated” date. Your continued use of the Platform after any changes constitutes acceptance of the revised Terms.

The Platform is intended for users in Uganda and complies with Ugandan laws, including the Data Protection and Privacy Act, 2019. Users accessing the Platform from other jurisdictions do so at their own risk and are responsible for compliance with local laws.

1. Definitions

Confidential Information: Any non-public information disclosed by one party to the other, including documents, data, and materials related to the Platform.
Content: All source code, databases, functionality, software, designs, audio, video, text, photographs, graphics, and other materials on the Platform.
Contributions: Any content or materials you submit, post, or transmit via the Platform.
Marks: Trademarks, service marks, and logos owned or licensed by us.
Platform: The 2geme App, Website, and related services.
User Data: Data transmitted by you or related to your use of the Platform.

2. Security of Information and Confidentiality

We prioritize the security of your information. All personal and client data, including addresses, telephone numbers, and health details, will be kept confidential and not shared with third parties except as outlined in our Privacy Policy or required by law.

2.1 Confidential Information Obligations

Confidential Information provided in connection with these Terms remains the property of the disclosing party. Each party agrees to:

Maintain such information in strict confidence.
Not use or disclose it except as necessary to perform under these Terms.
Limit disclosure to employees, agents, or affiliates who need to know and are bound by confidentiality obligations.

2.2 Exceptions to Confidentiality

This does not apply to information that:

Becomes publicly known through lawful means.
Is already in the recipient’s possession without restriction.
Is received from a third party without confidentiality obligations.
Is independently developed by the recipient.
Is disclosed with written permission from the disclosing party.

If a party receives a legal request for Confidential Information, it will promptly notify the other party (if permitted) to allow for protective measures.

2.3 Return or Destruction

Upon termination of these Terms or at the disclosing party’s request, the receiving party must return or destroy all Confidential Information and certify compliance. Confidentiality obligations survive termination.

3. Intellectual Property Rights

Unless otherwise stated, the Platform and all Content and Marks are our proprietary property, protected by Ugandan and international copyright, trademark, and intellectual property laws.

You are granted a limited, non-exclusive, non-transferable, revocable license to access and use the Platform for personal, non-commercial purposes, subject to these Terms. You may not copy, reproduce, modify, distribute, or exploit any part of the Platform without our prior written consent.

By using the Platform, you grant us a non-exclusive, irrevocable, perpetual, worldwide, royalty-free license to use, reproduce, and modify any content you provide (e.g., Contributions) for providing and improving the Services.

You are solely responsible for your Contributions and warrant that they do not infringe third-party rights. We may remove or disable Contributions that violate these Terms.

4. User Representations and Warranties

By using the Platform, you represent and warrant that:

You have the legal capacity to enter these Terms.
You are at least eighteen (18) years old.
All information you provide is accurate, current, and complete.
You will not access the Platform via automated means (e.g., bots or scripts).
Your use will comply with all applicable laws and not violate third-party rights.

If any information is untrue, we may suspend or terminate your access.

5. User Data and Privacy

We collect and maintain User Data to manage and improve the Platform. You are responsible for the accuracy of your data and any backups. Refer to our Privacy Policy for details on data collection, use, and protection, which complies with Uganda’s Data Protection and Privacy Act, 2019.

By using the Platform, you consent to our use of cookies and electronic communications.

6. Acceptable Use and Prohibited Activities

You must use the Platform lawfully and in accordance with these Terms. Prohibited activities include:

Causing damage or impairing the Platform’s availability.
Transmitting viruses, spyware, or malicious software.
Conducting automated data collection without consent.
Sending unsolicited communications.
Systematically retrieving data to create databases without permission.
Tricking, defrauding, or misleading users.
Circumventing security features.
Harassing, abusing, or threatening others.
Impersonating users or using unauthorized accounts.
Interfering with the Platform’s operation.
Competing with us using Platform data.

We reserve the right to monitor, remove content, and terminate access for violations.

7. User Generated Contributions

If the Platform allows Contributions, you warrant that:

They do not infringe intellectual property, privacy, or other rights.
You have necessary consents for any identifiable individuals.
They are not false, obscene, harassing, or illegal.

Contributions may be viewable by others and treated as non-confidential. You retain ownership but grant us a license as described in Section 3. We are not liable for Contributions.

8. Submissions and Feedback

Any submissions or feedback you provide become our property, and we may use them without compensation. You waive moral rights and warrant originality.

9. Account Setup and Security

To create an account, provide accurate information. You are responsible for securing your credentials and notifying us of breaches. Accounts must be created by humans, not bots.

Report any harassment or abuse to info@2geme.org, but we are not liable for user interactions.

10. Booking and Payments

Bookings for services are facilitated through the Platform, which may include third-party payment links. We are not liable for payments or interactions with service providers but will assist with issues.

11. Restricted Access

We may restrict access to certain areas. Keep any provided credentials confidential. We may disable them without notice.

12. Term and Termination

These Terms remain in effect while you use the Platform. We may terminate or suspend access at any time for violations, without liability. Upon termination, cease all use and return/destroy Confidential Information.

To close your account, email info@2geme.org.

13. Modifications and Interruptions

We may modify or discontinue the Platform without notice. We are not liable for interruptions or resulting losses.

14. Corrections

We may correct errors or inaccuracies on the Platform without notice.

15. Dispute Resolution

Any disputes shall be resolved through binding arbitration under the Rules of the International Commercial Arbitration Court, with three arbitrators, seated in Nairobi, Kenya, in English, governed by Ugandan law.

Arbitration is individual only; no class actions. Exceptions include intellectual property disputes, which may be litigated in Ugandan courts.

16. Disclaimer

The Platform is provided “AS IS” without warranties. We disclaim all implied warranties, including merchantability and fitness for purpose. We are not liable for third-party content or linked sites.

17. Limitations of Liability

To the fullest extent permitted by law, we are not liable for indirect, consequential, or punitive damages arising from Platform use.

18. Indemnification

You agree to indemnify us against claims arising from your use, breaches, or violations of rights.

19. Exclusion of Warranties

Services are “AS IS.” We do not guarantee uninterrupted or error-free operation.

20. Assignment

We may assign these Terms without notice. You may not.

21. Severability

Invalid provisions do not affect others.

22. Relationship of Parties

No employer-employee, partnership, or agency relationship is created.

23. Force Majeure

Neither party is liable for delays due to events beyond control (e.g., acts of God, strikes).

24. Governing Law

These Terms are governed by Ugandan law.

25. Entire Agreement

These Terms supersede prior agreements.

26. Contact Us

For questions or complaints, email info@2geme.org.