At Ary Invest Learning, we value your privacy and treat your personal information with care and respect. Please review our comprehensive secure data handling specifications below.
1. Introduction and scope
At Ary Invest Learning, we value your privacy and treat your personal information with care and respect. We want you to clearly understand:
- What information we collect about you
- Why we collect it
- How we use and protect it
- When we may share it
- What rights you have over your information
This Privacy Policy applies to:
- Our websites and learning platforms
- Our mobile or online applications (if any)
- Our online courses, in person trainings, workshops, and learning materials
- Any other services we provide as part of the Investment Learning Programme
By using our services, you agree that your personal data will be handled as described in this Policy and in line with applicable data protection laws in Uganda and any other relevant jurisdictions.
Last updated: [insert date]
2. Who we are
Ary Invest Learning is the organisation responsible for the Investment Learning Programme and for deciding how your personal data is used.
If you have questions about this Policy or how we handle your data, you can contact us at:
- Email:
- Phone:
- Address:
Where required, we work with the relevant data protection authority in Uganda or any other applicable country to make sure we handle your data lawfully and responsibly.
3. Who this policy covers
We may collect personal data about:
- Learners and participants (adults, youth, and children, where parents/guardians consent)
- Parents, guardians, teachers, and facilitators
- Staff, consultants, trainers, and volunteers
- Partners, suppliers, and service providers
- People who contact us by email, phone, or through our website
- People who subscribe to our mailing lists, webinars, or events
In this Policy, “you” or “your” refers to any of these individuals whose data we collect.
4. What personal data we collect
We only collect personal data that we reasonably need for education, communication, programme management, monitoring, or legal reasons. Examples include:
Basic identification and contact details
- First name and last name
- Email address
- Phone number or WhatsApp number
- Organisation, school, or group (if applicable)
Programme participation details
- Which courses or sessions you join
- Attendance records and certificates
- Your feedback and survey responses
- Your learning goals or areas of interest
For some activities or tools (optional)
- Simple information about your investment goals, experience, or preferences, when you choose to share it for learning exercises or planning templates
We do not ask for more personal data than we need. We do not collect sensitive financial details about your exact investment accounts or balances unless clearly necessary for a specific service and with your consent.
5. Special note on children and young people
Some parts of the programme are designed for children and youth. When we work with children:
- We encourage parent, guardian, or teacher involvement in the learning
- We collect only the minimum information necessary (for example, first name, age group, class, or school)
- We do not knowingly collect more personal data from children than needed for education and safety
- We do not use children’s data for unrelated marketing
Adults (parents, guardians, teachers) remain responsible for supervision and consent when children participate in the programme.
6. How we collect personal data
We collect personal data in several ways, including:
- When you fill in registration or sign up forms (online or paper)
- When you enroll in a course, workshop, or event
- When you subscribe to our mailing list or download materials
- When you contact us by email, phone, or social media
- When you respond to surveys, feedback forms, or evaluations
- When partners (such as schools, NGOs, or training centres) share limited information so that we can deliver the programme to their groups, in line with data protection rules and with appropriate consent
Where we collect data from third parties or partners, we require them to confirm they have a lawful basis and appropriate consent to share that information with us.
7. Why we use your personal data
We use your personal data only for clear purposes connected to education, programme delivery, and legal duties. For example:
- To register you for courses, events, and learning tracks
- To share learning materials, reminders, and updates with you
- To tailor content to your level and interests where possible
- To issue certificates or confirmations of participation
- To respond to your questions or support needs
- To monitor and improve the quality and impact of the Investment Learning Programme
- To comply with legal obligations (such as record keeping or reporting where required)
Sometimes we also use anonymised or aggregated data (which does not identify you personally) for:
- Programme reporting and improvement
- Designing new learning products and services
- Donor or partner reporting, where no individual can be identified
8. Legal basis and consent
We process your personal data based on one or more of the following legal grounds (depending on context):
- Your consent – for example, when you sign up to a mailing list, share goals for a coaching exercise, or agree to receive updates
- A contract or agreement – for example, when you pay to access a course or programme
- Legitimate interests – for example, to improve our education services or manage our relationship with you in a reasonable way
- Legal obligations – for example, record keeping required by law
Where we rely on consent, we will:
- Explain clearly what you are agreeing to
- Allow you to withdraw your consent at any time
If you withdraw your consent, we will stop the related processing from that point forward, unless another legal basis applies. Where appropriate, we will also inform relevant third parties that you have withdrawn consent.
9. How long we keep your data
We keep your personal data only for as long as we reasonably need it for the purposes described above or as required by law. For example:
- Learners and participants – for the duration of the course or programme and for a reasonable period afterwards (e.g., up to 1–3 years), to provide certificates, address follow up questions, and manage reporting, unless a longer period is required by law.
- Mailing list subscribers – until you unsubscribe or we no longer need to send such communications.
- Job applicants or potential staff – for a limited period (for example up to 1 year) after the recruitment process ends, unless you ask us to delete your data sooner.
We consider:
- The type and sensitivity of the data
- How long we need it to fulfil the purpose
- Any legal or regulatory requirements
- The risk of harm from storing it longer than needed
When we no longer need your data, we will delete it securely or anonymise it so that it can no longer identify you.
10. Who we share your data with
We do not sell your personal data.
We may share your personal data with trusted third parties, but only when necessary, for example:
- Service providers who help us with:
- IT, hosting, and learning platforms
- Payment processing and invoicing
- Communication tools (e.g., email or SMS services)
- Data analysis and programme reporting
- Partner organisations such as schools, NGOs, or training centres that help deliver the programme, where it is necessary to coordinate learning activities
- Public authorities or regulators, where required by law
- Any other third party where you have clearly authorised us to share information
We require all service providers and partners to:
- Protect your data
- Use it only for the specific purposes agreed
- Handle it according to applicable data protection laws
If Ary Invest Learning’s ownership or structure changes (for example, through a merger or transfer), your data may be transferred to the new entity, which must continue to respect this Privacy Policy or a similar one that offers equal protection.
11. International transfers (if applicable)
If we ever transfer personal data outside your country (for example, to a service provider in another country):
- We will only do so where it is necessary for our services (such as using a reputable cloud service or learning management system), and
- We will take appropriate steps to ensure your data is protected according to applicable data protection standards.
If this applies, we will explain it clearly in our detailed privacy notice or terms for that specific service.
12. How we protect your data (security)
We use appropriate technical and organisational measures to protect your personal data from:
- Loss
- Misuse
- Unauthorised access
- Disclosure
- Alteration or destruction
Examples include:
- Restricting access to personal data to authorised staff and service providers who need it to do their work
- Using secure systems and passwords
- Training staff on data protection and confidentiality
- Having procedures in place to respond to possible data breaches
However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security. You also play a role in keeping your data safe by:
- Protecting your passwords and devices
- Logging out of accounts after use, especially on shared devices
If we become aware of a serious data incident that affects your personal data, we will follow legal requirements for reporting and, where necessary, inform you and the relevant authority.
13. Your rights
Subject to local data protection law, you may have the following rights:
- Right of access – you can ask for a copy of the personal data we hold about you.
- Right to correction (rectification) – you can ask us to correct or update information that is inaccurate or incomplete.
- Right to deletion (erasure) – you can ask us, in some cases, to delete your personal data. We may need to keep certain information if the law requires it or for legitimate record keeping.
- Right to restrict or object to processing – you can ask us to limit how we use your data or object to certain types of processing (for example, direct marketing).
- Right to withdraw consent – when we process data based on your consent, you can withdraw that consent at any time.
- Right to complain – you can complain to us and, if you are not satisfied, to the relevant data protection authority.
To exercise any of these rights, contact us using the details in Section 2. We aim to respond within a reasonable time and in line with legal timelines.
14. Marketing and communication preferences
We may use your contact details to send you information about:
- New courses, workshops, or learning events
- Updated materials or tools
- Opportunities or content we believe may be relevant to you
We will:
- Only send such communications where the law allows (for example with your consent or based on a legitimate interest)
- Give you a simple way to opt out or unsubscribe at any time
If you no longer want to receive marketing or general updates:
- Click “unsubscribe” in our emails (if available), or
- Contact us directly to update your preferences
We may still send you important service messages related to active courses or legal notices, even if you opt out of marketing.
16. Changes to this Privacy Policy
We may update this Policy from time to time, for example when:
- The law changes
- Our services change
- We introduce new systems or processes
When we make significant changes, we will:
- Update the “last updated” date
- Where appropriate, notify you through the website, email, or other channels
Continued use of our services after an update means you accept the revised Policy.
17. How to contact us or raise a concern
Please contact us directly for questions, exercises of data rights, or structural compliance inquiries related to this platform:
Ary Invest Learning
Email: info@aryinvest.com
Phone: +256 772 723486
Address: Kampala - Uganda