Privacy Policy

Last updated: December 2025

Clear Draft ("we", "our", "us") is a trading name of Tullany Holdings Limited (Company Registration No. 80034919002213), a company registered in Uganda. We are committed to protecting your privacy and handling your personal data in accordance with the Uganda Data Protection and Privacy Act, 2019 and applicable international data protection standards.

1. Information We Collect

We collect personal data that you provide directly to us when using our services:

1.1 Contact Information

• Full name
• Email address
• Telephone number (if provided)
• Postal address (if relevant to your matter)

1.2 Case Information

To draft documents on your behalf, we may collect:

• Details of your legal matter or dispute
• Names of other parties involved
• Relevant dates, events, and circumstances
• Supporting documents you provide
• Court or tribunal reference numbers

1.3 Sensitive Personal Data

Depending on the nature of your matter, you may provide sensitive personal data including health information, financial circumstances, or family details. We only collect such data where necessary for the document drafting service you have requested and with your explicit consent.

1.4 Payment Information

We collect payment details necessary to process your order. We do not store complete payment card details on our systems.

2. Legal Basis for Processing

Under the Uganda Data Protection and Privacy Act, 2019, we process your personal data on the following lawful bases:

• Consent: You provide consent when you submit your case details and instruct us to draft documents on your behalf.
• Contract: Processing is necessary for the performance of the contract between us — namely, the provision of document drafting services.
• Legal obligation: We may process data to comply with legal requirements, including retention obligations and responding to lawful requests from authorities.

3. How We Use Your Information

We use your personal data to:

• Provide the document drafting services you have requested
• Communicate with you about your order
• Process payments
• Respond to enquiries and provide support
• Comply with legal and regulatory obligations
• Improve our services

We do not use your personal data for automated decision-making or profiling.

4. Data Sharing

We do not sell your personal data. We may share your data with:

• Service providers: Payment processors and email services that assist in delivering our services, under strict confidentiality agreements.
• Legal requirements: Authorities where required by law, court order, or to protect our legal rights.

We will not share your case details or documents with any third party without your explicit consent, except where required by law.

5. International Data Transfers

As a Ugandan company serving clients internationally, your data may be processed or stored in Uganda and the United Kingdom. Where we transfer data outside Uganda, we ensure adequate safeguards are in place as required by Section 19 of the Uganda Data Protection and Privacy Act, 2019.

For clients in the United Kingdom or European Economic Area, we handle your data in accordance with UK GDPR principles and ensure any transfers to Uganda are made with appropriate safeguards.

6. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Secure, encrypted communications
• Access controls limiting who can view your data
• Secure storage of electronic and physical records
• Regular review of security practices

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

• Case files and documents: Retained for six (6) years from completion of the matter, to allow for potential future reference or legal proceedings.
• Financial records: Retained as required by applicable tax and accounting laws.
• Communication records: Retained for two (2) years unless related to an ongoing matter.

After the retention period, data is securely deleted or anonymised in accordance with Section 9 of the Uganda Data Protection and Privacy Act, 2019.

8. Your Rights

Under the Uganda Data Protection and Privacy Act, 2019, you have the following rights:

• Right of access: Request a copy of the personal data we hold about you.
• Right to rectification: Request correction of inaccurate or incomplete data.
• Right to erasure: Request deletion of your data where there is no compelling reason for continued processing.
• Right to object: Object to processing of your data in certain circumstances.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, please contact us at info@tullany.org. We will respond to your request within thirty (30) days.

9. Complaints

If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with:

Personal Data Protection Office (Uganda)
National Information Technology Authority - Uganda (NITA-U)
Website: www.pdpo.go.ug

For UK-based clients, you may also contact:
Information Commissioner's Office (ICO)
Website: ico.org.uk

10. Cookies and Website Analytics

Our website may use essential cookies necessary for the website to function. We do not use tracking cookies or third-party analytics that collect personal data without your consent.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Significant changes will be communicated via our website or by email where appropriate. The "Last updated" date at the top of this policy indicates when it was last revised.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us: