Privacy notice
Effective from 1 January 2026. We update this notice as our practices evolve and will date-stamp every revision.
1. Who we are
Jolems Property Solutions Ltd ("Jolems", "we", "us") is a private limited company registered in Uganda. Our registered address is Plot 21, Kira Road, Kamwokya, Kampala. For privacy queries, contact our Data Protection Officer at info@jolemspropertysolutions.com.
2. What we collect
We collect information you provide directly through our forms (name, email, phone, organisation, country, investor type, ticket size, message text), information generated by your interactions with our services (transactions, escrow events, e-signatures, KYC submissions), and limited technical data (IP address, browser type, referrer) for security and analytics.
3. How we use it
We use personal data to respond to your inquiries, process property transactions, verify identity and title (KYC, OCR), manage escrow, comply with anti-money-laundering obligations, send investor communications you have requested, and improve our services. We do not sell personal data.
4. Lawful basis
We process personal data on the lawful bases of (a) your consent — for marketing communications and optional features; (b) contract — to deliver services you have requested; (c) legal obligation — to comply with Ugandan law including the Data Protection and Privacy Act 2019 and AML/KYC obligations; and (d) legitimate interest — to operate, secure and improve our business in ways that do not override your rights.
5. Sharing
We share personal data with vetted processors who support our operations: payment processors (Flutterwave for MTN MoMo, Airtel Money, M-Pesa), KYC providers, hosting providers, escrow account banks, legal counsel and auditors. Each processor is bound by a written data processing agreement. We may also disclose data when compelled by law or to protect our legal rights.
6. Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or to comply with legal, accounting or reporting obligations. Transaction and KYC records are retained for the minimum period required by Ugandan law (typically seven to ten years).
7. Your rights
You have the right to request access to your personal data, correction of inaccurate data, deletion of data we no longer need, restriction of processing, objection to processing based on legitimate interest, and portability of data you have provided. Submit requests to our DPO at the email above. We respond within 30 days.
8. Cookies
We use a minimal set of cookies for essential session functionality and aggregate analytics. We do not use third-party advertising cookies. You may disable cookies in your browser without losing access to most of our public website.
9. International transfers
Some of our processors are located outside Uganda. Where transfers occur, we rely on contractual safeguards (model clauses) to ensure protections equivalent to those required by the Ugandan Data Protection and Privacy Act 2019 and, where applicable, the EU GDPR.
10. Contact
Direct any questions, requests or complaints to info@jolemspropertysolutions.com. You also have the right to lodge a complaint with the Personal Data Protection Office of Uganda.