Privacy Policy

This Privacy Policy describes the privacy practices for the publications, businesses, websites, mobile applications, crosswords, and other ancillary digital products, and related online services that we provide through the foregoing (collectively, “Products”) that are operated by theCooperator News, and its affiliates (“The Uhuru Institute” “we”, “our” “us”), and applies solely to the Personal Information (as defined below) that we collect and use relating to consumers and users residing within and outside Uganda.

To the extent permitted by applicable law, by using the Products and providing us with Personal Information (defined below), you agree to the practices described in this Privacy Policy and the Cookie Policy  referenced below and to the updates to these policies posted here from time to time. This Privacy Policy serves as notice of how we process your Personal Data (defined below) for which we are a controller. If we require your consent, we will request it formally, in adherence to applicable data protection laws.

For purposes of this Privacy Policy, unless a different definition is noted in a particular instance, “Personal Information” (or “Personal Data” as used in the “Individuals in the European Area (EEA) or UK” section below) means any information that identifies, relates to, describes, references, or is reasonably capable of being associated with an identified or identifiable natural person.
Personal Information for purposes of this Policy does not include your name, photo, and/or other information about you included in the news or editorial content.

We may collect the following types of Personal Information about you as described below:
(A) Personal Information you provide to us,
(B) Personal Information we may automatically collect, and
(C) Personal Information we may receive from third parties.

A. Personal Information You Provide to Us
In using our Products, you may provide us with Personal Information, which may include (the examples provided are illustrative and not intended to be exhaustive):
• Contact information such as name, email address, postal address, and telephone number(s);
• Demographic information such as birth date or gender;
• Account information and log-in credentials, including unique identifiers such as username and password;
• Payment and transaction information including credit or bank card information;
• Preferences for communications;
• Communications and opinions in chat rooms, message boards, forums, surveys, polls, and online forms;
• Access to your geo-location (including through our mobile app) or to other data held on social media platforms and other software (for example, access to your contacts, calendar or photos);
• Photos and/or videos; and
• Any additional information that we describe to you, when we collect your data with your consent.

You agree that you will provide to us only your own Personal Information, or the Personal Information of those whom you have the legal right to provide (such as in your capacity as a legal guardian). You agree to provide us with accurate Personal Information.

B. Personal Information We May Automatically Collect About You
Our Products may automatically collect certain Personal Information about you. This Personal Information may include the following (the examples provided are illustrative and not intended to be exhaustive). Any of this information may be combined with other Personal Information we may have or obtain about you from your use of our Products or from third parties as described below in “Personal Information We May Receive from Third Parties.”
• IP address, which is the number associated with the service through which you access the Internet, such as through your ISP (Internet service provider);
• Date and time of your visit, registration, login or use of our Products;
• Domain server from which you are using our Products;
• Type of computer, web browsers, search engine used, operating system, or platform you use;
• Your Social Media Platform login information
• Data identifying the web pages you visited prior to and after visiting or using our Products;
• Your location data
• Your behavior, movement and activity on or within the Product;
• Your profile information
• Geo-location information through the use of any of our mobile applications;
• Your list of contacts, friends or followers
• Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”); and
• Certain Personal Information about your activities on the Social Media Platform
• Mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from.
• If you sign up for text messaging, cookies or other tracking devices may be used to personalize your experience (for example, to send you personalized text message offers).

C. Personal Information We May Receive from Third Parties
We may collect additional Personal Information about you from third-party websites and apps, social media platforms, such as, but not limited, to Facebook, Twitter, Instagram, SnapChat (“Social Media Platforms”), third party data providers, and sources providing publicly-available Personal information (e.g., from the U.S. postal service) for the purposes described in “How We Use Personal Information” section below.

Personal Information we may access from Social Media Platforms may include, but is not limited to:
• Your Social Media Platform login information
• Your location data
• Your profile information
• Your list of contacts, friends or followers
• Certain Personal Information about your activities on the Social Media Platform
Please keep in mind that when you provide Personal Information to us on a third-party website or platform (for example, via our applications or by logging into any of our Products via a social media account), the Personal Information you provide may be separately collected by the third-party website or the Social Media Platform. Please review the privacy policies of the applicable third-party website or Social Media Platform for their privacy practices.

A. Use and Purpose of Processing Your Personal Information
We use and process your Personal Information for the following types of purposes (the examples provided are illustrative and not intended to be exhaustive).
• To provide you with the Products, and other promotions, newsletters and information we think you may be interested in
• To respond to your inquiries and provide you with requested information and to provide other communications, including by email, chat or text messages, and including alerts, notification of promotions, contests, and events
• For marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and other third parties, provided that you have not already opted-out of receiving such communications
• For billing and payment processing
• To deliver personalized advertising and content, including textual and audio-visual ads and content
• To fulfill contracts we have with you
• To manage, improve and support our relationships with third-parties that we contract with in connection with our business, Products and services, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners
• To maintain, improve, customize, or administer the Products, perform business analyses, or other internal purposes to improve the quality of our business, Products and services, , resolve technical problems, or improve security or develop other products and services
• To comply with our Terms of Service and Terms of Use for various Products
• To perform analytics for business purposes and business intelligence, such as monitoring traffic to our Products, counting ad impressions, and auditing legal and regulatory compliance
• To maintain the safety, security, and integrity of our Products, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators
• To identify and repair errors in our Products’ functionality
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information we hold is among the assets transferred
• To comply with any applicable laws and regulations and respond to lawful requests; and/or
• For any other purposes disclosed to you at the time we collect your Personal Information and/or pursuant to your consent  If we decide to use the Personal Information for materially different purposes, we will update this Privacy Policy.

If we decide to use the Personal Information for materially different purposes, we will update this Privacy Policy.

B. Disclosing Your Personal Information to Other Parties
We may disclose your Personal Information to other parties, including:
• Our affiliates
• Service providers
• Advertisers, advertising technology companies, analytics companies and other third parties with whom we have business relationships
• Government regulators
• Our legal advisors and parties involved in a legal process
• To an entity involved in the sale of our business
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or Services we provide to you

In order to provide advertisements and content that are more relevant to you, we and our advertising and content providers may collect certain types of Personal Information when you use our Products (such as, by way of example, your email, the IP address of your device, the identifier on your mobile device, or cookies stored on your device). We or our advertising and content providers may combine this information with other information we have, or that we collect through other sources, and may share the information we collect with third parties to provide interest based or targeted advertising and content, including textual and/or audio-visual ads or content. If you would like to opt out from this use, or for more information, please see our  Cookie Policy for more information.

If we decide to disclose Personal Information to additional categories of parties, we will update this Privacy Policy.

Do We Use “Cookies”?
Yes. Cookies, SDKs, tracking pixels and similar technologies are small files that a website or mobile application stores on your device that recognizes the user’s browser or device and captures and remembers certain information.

In general, we and our third-party providers, advertisers and marketing partners, use these technologies to optimize the functionality of the Products, to help us understand how the Products are used and to provide users with interest-based content and/or advertising, including textual and/or audio-visual ads or content based upon their browsing activities and interests.

If you sign up for text messaging, cookies or other tracking devices may be used to personalize your experience (for example, to send you personalized text message offers).

For more information about the cookies and other technologies that we, our affiliates and third party providers and advertisers use on our Products, please read our Cookie Policy.

In addition, you may opt out of certain interest-based advertising by using the following resources:

(a) You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at

(b) You may opt-out of receiving some permissible targeted advertisements by using the NAI Opt-out tool available at or visiting About Ads at

(c) You may opt-out of having your activity on our Products made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: for your web browser.

Our Products may contain links to other websites, applications or services that are not owned or controlled by us, including links to Social Media Platforms, or may redirect you off our Products to other locations for information or other services. This Privacy Policy only applies to information collected by our Products. We are not responsible for the privacy and security practices of other websites, applications or social media platforms or the information they may collect (which may include IP address or device identifiers). You should refer to such third parties’ privacy policies on their sites to determine their respective privacy practices. Links to any other websites, applications, Social Media Platform or content do not constitute or imply an endorsement or recommendation by us of the linked website, application, Social Media Platform, and/or content.

We use commercially reasonable procedures and various technical, administrative and physical safeguards to help protect the confidentiality of your Personal Information. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Personal Information or private communications will always remain private or secure. We do not guarantee that your Personal Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features.

If you believe that your Personal Information has been accessed or acquired by an unauthorized person, please promptly Contact Us so that necessary measures can quickly be taken.

As required by applicable laws, and subject to any permitted exceptions and limitations, we will comply with any verified consumer request you submit with respect to your Personal Information. Please submit a verifiable consumer request to us through the email provided below in Contact Us.

Your Personal Information may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers.

We may aggregate and/or de-identify any information collected through the Products so that such information can no longer be linked to you or your device  (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

This Section is included in this Privacy Policy to comply with the requirements of the General Data Protection Regulation (“GDPR”). It applies only to individuals visiting or using our Products from within the EEA, Switzerland or the UK and applies only (1) if we collect through the Products any
Personal Data of those individuals or (2) if we track individuals in the EEA, Switzerland or the UK who access our Products.

Rights of Individuals Based in the EEA
Subject to applicable law, you may be able to exercise any of the following rights in relation to your Personal Data:
• Right to know what information we have about you: This is known as the “right of access” and gives you the right to find out what, if any, Personal Data we have about you, how we process it, and to request a copy of the Personal Data.
• Right to correct your information: This is known as the “right of rectification” and gives you the right to ask that we correct or complete any Personal Data we have about you.
• Right to delete your information: This is known as the “right to erasure” or “right to be forgotten” and gives you the right to ask us to delete your Personal Data.
• Right to change how we use your information: This is known as the “right to restrict processing” and gives you the right to ask us to change how we use your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us using it in a certain way.
• Right to move your information: This is known as the “right to data portability” and gives you the right to ask to receive your Personal Data from us in a structured, commonly used and machine-readable format or to have it transmitted to another controller.
• Right to stop us from using your information: This is known as the “right to object” and gives you the right to ask us to stop using your Personal Data when applicable.
• Rights relating to how we use your information to categorize you or make decisions about you: This is known as the “right in relation to automated decision-making and profiling”: You have the right to be free from decisions we may make that are based solely on automated processing of your Personal Data, including profiling, if they produce a significant legal effect on you, unless such decision-making or profiling is necessary for entering into or performing a contract between you and us, or is made with your explicit consent.
• Right to withdraw consent: If we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. This will not affect our use of your data before we received notice that you wished to withdraw your consent.
• Right to file a complaint with the supervisory authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the supervisory authority that is authorized to hear those concerns in your jurisdiction, although we invite you to Contact Us with any concern as we would be happy to try and resolve it directly.

You may exercise your rights by contacting us as indicated under the “Contact Us” section below. To change your consent settings for our use of cookies and other technologies, please see our Cookie Policy.

The requests above will be considered and responded to in the period stated by applicable law. Certain information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests.

Legitimate Interests
“Legitimate interests” means the interests of our company in conducting and managing our organization. For example, and without limitation, we have a legitimate interest in processing your Personal Data to analyze how the Products are being used, to administer our contractual relationships, fulfil legal obligations, process employee data, prevent fraud or criminal activity or misuse of our products or services, ensure the security of our IT systems, architecture and networks, and meet our corporate and social responsibility objectives, and/or effectively and efficiently operate our business and provide you with the services offered through our Services, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section above.

Data Retention
We will keep your Personal Data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy based on the context in which you provided it, or for the duration required by law, whichever is the longer.

In general, the Products are not intended for use by children under the age of 13, or 16 where applicable, and the terms for certain Products may specify further age-related restrictions. In cases where certain Products are intended for use by children under the age of 13 (or 16 where applicable), we will post appropriate notices and take steps as required by applicable law to safeguard children’s data. In addition, we do not knowingly collect Personal Information from children under the age of 13 (or 16 where applicable) through form submissions on our Products, although certain third party sites that we link to may do so. These third-party sites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide information on our Products without their permission.

Involvement of parents: In accordance with the provisions of the Children’s Online Privacy Act, in the event that we do begin collecting any Personal Information or data from children under the age of 13 (or 16 where applicable), we will notify parents first, and will seek parental or guardian consent to collect, use and/or disclose certain Personal Information from children under the age of 13, or 16 where applicable. A parent may review and have deleted their child’s Personal Information, and may refuse to permit further collection or use of their child’s information by contacting us as noted at the end of this Privacy Policy. Parents may consent to our collection and use of their child’s Personal Information without consenting to the disclosure of that information to others.

If you have reason to believe that a child under the age of 13 (or 16) has provided Personal Information “Contact Us” below with sufficient detail to enable us to delete that information from our databases.


You agree to indemnify and hold harmless us, our affiliates, and each of our and their respective directors, officers, managers, employees, shareholders, agents, representatives and licensors, from and against any and all losses, expenses, damages and costs, including reasonable attorneys’ fees, that arise out of your provision of any inaccurate or unauthorized Personal Information to us or your violation of this Agreement or any rights of another. We reserve the right to take over the exclusive defense of any claim for which we are entitled to indemnification under this section. In such event, you agree to provide us with such cooperation as is reasonably requested by us.

We may amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on our Products and update the notice’s “Last Updated” date. Where permitted by applicable law, your continued use of our Website and/or Services following the posting of changes constitutes your acceptance of such changes.

This Privacy Policy, any terms of use or terms of service posted on or in or linked to from our Products or described on any form through which you registered or subscribed to a Product, as well as other policies referenced herein or therein constitutes the entire agreement (“Agreement”) between us and you with respect to the subject matter contained in this Agreement and supersedes all previous and contemporaneous agreements, proposals and communications, written or oral.

You also may be subject to additional terms and conditions that may apply when you use the products or services of a third party that are provided through the Digital Products. In the event of any conflict between any such third-party terms and conditions and this Privacy Policy (as it relates to Personal Information or Personal Data), this Privacy Policy will govern.

This Agreement will be governed by and construed in accordance with the laws of Uganda, without giving effect to any principles of conflicts of law.

This Agreement is personal to you and you may not assign it to anyone. We may assign this Agreement and all rights and obligations hereunder at any time. If any provision of this Agreement is found to be unlawful, void, or for any reason unenforceable, then that provision will be deemed severable from this agreement and will not affect the validity and enforceability of any remaining provisions. This Agreement is not intended to benefit any third party, and does not create any third party beneficiaries. Accordingly, this Agreement may only be invoked or enforced by you or us.

You agree that regardless of any statute or law to the contrary, any claim or cause of action that you may have arising out of or related to use of the Products or this Agreement must be filed by you within one year after such claim or cause of action arose or be forever barred.

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Information described here, your choices and rights regarding such use, or you wish to exercise your rights, please contact us as provided below.


• Email us through
• Write us at: theCooperator News, Bwindi Trust House, Plot 1 Katalima Crescent, Naguru, Kampala.

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