PRIVACY NOTICE | WWW.UCL.CO.KE

Introduction

This Privacy Policy outlines Universal Corporation Limited (“we”, “our”, or “the Company”) practices regarding the collection, use, and disclosure of information from users who access our website at

[www.ucl.co.ke] (“the Site”), or otherwise share personal information with us (collectively, “Users”).

Grounds for Data Collection

The processing of your personal information (meaning any information that may allow your identification with reasonable means; hereinafter “Personal Information”) is necessary for the performance of our contractual obligations to you, to provide our services, to protect our legitimate interests, and to comply with legal and regulatory obligations.

By using the Site, you consent to the collection, storage, use, and disclosure of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read this Privacy Policy and use it to make informed decisions.

What Information We Collect

We collect two types of information from Users:

1.  Non-Personal Information

This is unidentified and non-identifiable information pertaining to a User, which may be collected through your use of the Site. We are not aware of the identity of the User from whom the Non-Personal Information was collected.

This information may include aggregated usage data, technical details transmitted by your device (e.g., browser type, operating system, language preferences, access time, etc.)

2.  Personal Information

This is individually identifiable information, meaning information that identifies an individual or can, with reasonable effort, identify an individual. Such information may include:

• Device Information: Geolocation data, IP address, unique identifiers (e.g., MAC address, UUID), and other information related to your device and Site activity.
• Registration Information: When registering on our Site, you may be required to provide details such as your full name, email address, phone number, and other relevant information.

How We Receive Information About You

We receive your Personal Information from various sources, including:

• When you voluntarily provide personal details to register or contact us through the Site.
• When you use or access the Site in connection with our services.
• From third-party providers, services, or public registers (e.g., analytics vendors).

How We Use the Information We Collect

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We may use the information to:

• Communicate with you, including sending notices, updates, or responding to service requests.
• Keep you informed about our latest updates and services.
• Serve advertisements when you use our Site.
• Market our websites and products.
• Conduct statistical and analytical activities to improve our Site and services.

We may also transfer or disclose Personal Information to our subsidiaries, affiliates, or subcontractors, as well as trusted third-party providers (who may be located in different jurisdictions) under strict contractual safeguards for purposes such as:

• Hosting and operating our Site.
• Providing personalized services.
• Storing and processing information on our behalf.
• Serving advertisements and evaluating campaign performance.
• Conducting research, analytics, and diagnostics.

We may disclose information if we believe in good faith that such disclosure is necessary to:

1. Comply with applicable laws, regulations, or legal requests.
2. Enforce our policies, including investigations of potential violations.
3. Prevent or address illegal activities, fraud, or security issues.
4. Defend against legal claims.
5. Protect the rights, property, or safety of our Users, ourselves, or others.
6. Cooperate with law enforcement agencies.

User Rights

You may request to:

• Confirm whether we process your personal information and access such data.
• Receive a copy of the personal information you provided in a structured, machine-readable format.
• Request correction or deletion of your personal information.
• Object to or restrict the processing of your data.
• Lodge a complaint with a supervisory authority.
• Right to withdraw consent.

Please note that these rights are not absolute and may be subject to our legitimate interests and legal obligations.

To exercise any of these rights, contact our Data Protection Officer (DPO) at [info@ucl.co.ke].

Retention

We will retain your personal information for as long as necessary to provide services and comply with legal obligations, resolve disputes, and enforce policies. Retention periods depend on the type and purpose of the information collected.

We may rectify, update, or remove incomplete or inaccurate information at our discretion.

Cookies

We and our trusted partners use cookies and similar technologies when you visit our Site.

A “cookie” is a small piece of information assigned to your device that enhances your browsing experience. Cookies help with navigation, feature activation, preference storage, and ensuring relevant advertising.

We use:

• Session cookies: Temporarily stored during browsing and deleted when the browser is closed.
• Persistent cookies: Saved for a fixed period to recognize you on repeat visits.
• Third-party cookies: Set by third-party services (e.g., analytics tools).

We also use Google Analytics to analyze Site usage and improve our services. Google’s use of data is governed by the Google Analytics Terms of Use and the Google Privacy Policy.

You can disable cookies in your browser settings, but doing so may limit Site functionality.

Third-Party Collection of Information

This Privacy Policy only governs information collected by us. Other websites or services you interact with may have their own privacy policies. We encourage you to review the terms and privacy policies of any third parties before disclosing your information.

How We Safeguard Your Information

We employ industry-standard procedures and policies to secure the Site and protect your information.

Although we take reasonable steps to safeguard data, we cannot guarantee complete protection against unauthorized access or misuse.

Advertisements

We may use third-party advertising technologies to deliver advertisements when you access the Site.

These may use cookies to display ads tailored to your interests. You can opt out of many third-party ad networks via:

• Network Advertising Initiative (NAI) Opt–Out
• Digital Advertising Alliance (DAA) Opt–Out

Marketing

We may use your Personal Information (such as your name, email, and phone number) to send promotional materials about our services.

You may opt out of marketing communications by following the unsubscribe instructions included in such materials.

Please note that we may still send you essential administrative or service-related communications even after you unsubscribe.

Corporate Transactions

In the event of a corporate transaction (e.g., sale, merger, consolidation, or asset transfer), we may share your information with the acquiring entity, which will assume the rights and obligations described in this Privacy Policy.

Minors

Protecting children’s privacy is important to us. The Site is not designed for or directed at minors.

We do not knowingly collect Personal Information from children without parental consent. If a parent or guardian becomes aware that their child has provided Personal Information without consent, they should contact us at [info@ucl.co.ke] for prompt action.

Updates or Amendments

We may update or revise this Privacy Policy from time to time.

Material changes will take effect immediately upon posting the revised Privacy Policy on the Site.

Your continued use of the Site constitutes your acknowledgment and acceptance of such changes.

How to Contact Us

For any questions about this Privacy Policy or our data practices, please contact us at:

Universal Corporation Limited info@ucl.co.ke www.ucl.co.ke