Privacy Policy

1. Organization Information

Community Fund Uganda Inc. is a 501(c)(3) tax-exempt nonprofit organization registered in the District of Columbia, United States. Our Employer Identification Number (EIN) is 20-5829304. We are also registered with the Uganda National NGO Bureau under registration number S.5914/14023.

Data Controller: Community Fund Uganda Inc., 1220 L Street NW, Suite 750, Washington, DC 20005, United States. For privacy-related inquiries, contact privacy@communityfunduganda.org or call (202) 555-0381.

2. Information We Collect

Donor Information: When you make a donation or submit a contact form, we collect your name, email address, mailing address, phone number (if provided), donation amount, and payment method details. Payment processing is handled by our secure third-party payment processor; CFU does not store credit card numbers or bank account details on our servers.

Website Usage Data: We collect standard web analytics data including IP addresses, browser type, operating system, pages visited, time spent on pages, and referring URLs. This data is collected through first-party analytics and is used exclusively to improve website functionality and user experience.

Beneficiary Information: Our field operations collect personal information from program beneficiaries in Uganda, including names, ages, location, household composition, income data, health records (for Community Health Clinic participants), and academic records (for scholarship recipients). This information is collected with informed written consent and is used exclusively for program delivery, monitoring, and evaluation.

3. How We Use Your Information

We use donor information to process donations, issue tax receipts, send quarterly program updates and annual reports, acknowledge gifts, and communicate about field visit opportunities. We use beneficiary information solely for program administration, impact measurement, and reporting to donors and grant-makers. We use website analytics to improve site performance and understand how visitors interact with our content.

We will never sell, rent, trade, or share your personal information with third parties for their marketing purposes. This is an absolute, unconditional commitment. We do not engage in list exchanges with other nonprofit organizations. We do not share donor data with political campaigns, advocacy organizations, or commercial entities under any circumstances.

4. International Data Transfer

CFU operates in both the United States and Uganda. Donor information collected through our website is stored on servers located in the United States. Beneficiary information collected by our field staff in Uganda is stored in secured databases maintained at our Gulu field office and backed up to encrypted cloud storage hosted in the European Union.

When beneficiary information is transmitted between our Uganda and US offices for reporting purposes, we use encrypted communication channels (TLS 1.3 minimum). Beneficiary personally identifiable information is anonymized or pseudonymized in all donor communications and public reports unless the individual has provided specific written consent for their name and story to be shared.

5. Beneficiary Confidentiality

We recognize that our program beneficiaries are among the most vulnerable populations we serve, and we treat their personal information with the highest level of care. Health records collected through our Community Health Clinic program are treated as protected health information and are accessible only to our clinical staff. Scholar academic records are shared only with the student, their parent or guardian, and the partner school administration.

Photographs, video, and personal stories of beneficiaries are published only with informed written consent obtained in the individual's preferred language (English, Acholi, Luganda, or Ateso). Consent may be withdrawn at any time, and we will promptly remove the individual's information from all public channels. We never publish photographs of children without explicit parental or guardian consent. Our storytelling guidelines prohibit imagery or narratives that depict beneficiaries as passive victims; we emphasize agency, resilience, and the specific actions individuals and communities have taken to improve their circumstances.

6. Data Security

We implement administrative, technical, and physical safeguards to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encrypted data transmission (TLS 1.3), access controls limiting data access to authorized personnel on a need-to-know basis, regular security assessments of our web infrastructure, and staff training on data protection best practices. Our website does not use third-party advertising trackers, retargeting pixels, or social media tracking scripts. While no data transmission over the Internet can be guaranteed 100 percent secure, we strive to use commercially acceptable means to protect your personal information.

7. GDPR Compliance (European Economic Area)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR). These include the right to access, rectify, erase, restrict processing, and port your personal data, as well as the right to object to processing and to withdraw consent. To exercise any of these rights, contact privacy@communityfunduganda.org.

Our lawful basis for processing donor data is legitimate interest (maintaining donor relationships and organizational communications) and, where applicable, consent (for email marketing). Our lawful basis for processing beneficiary data is consent (obtained at program enrollment) and legitimate interest (program delivery and impact measurement).

8. CCPA Compliance (California Residents)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information. You have the right to know what personal information we collect and how it is used, the right to request deletion of your personal information, and the right to opt out of the sale of your personal information. As stated above, we never sell personal information to any third party, so this right is satisfied by default. To exercise your CCPA rights, contact privacy@communityfunduganda.org or call (202) 555-0381. We will respond to verified consumer requests within 45 days.

9. Cookies & Tracking

Our website uses only essential cookies required for basic site functionality such as session management and security. We do not use third-party advertising cookies, social media tracking pixels, or behavioral profiling tools. Our first-party analytics collect anonymized usage data to help us understand how visitors navigate our site and improve the user experience. You can disable cookies in your browser settings without affecting your ability to access our website content.

10. Data Retention

We retain donor records for seven years after the most recent transaction to comply with IRS record-keeping requirements for tax-exempt organizations. After this period, records are securely destroyed. Beneficiary program records are retained for five years after program completion to support longitudinal impact evaluation, then anonymized or destroyed. Website analytics data is retained for 26 months. You may request earlier deletion of your personal information by contacting privacy@communityfunduganda.org, subject to our legal record-keeping obligations.

11. Children's Privacy

Our website is not directed at children under the age of 13, and we do not knowingly collect personal information from children under 13 through our website. Our scholarship program serves minors; all data collected for that program is obtained with parental or guardian consent and is governed by the beneficiary confidentiality provisions in Section 5 above.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the updated policy on this page with a revised "last updated" date. For material changes, we will notify donors via email. We encourage you to review this page periodically.

13. Contact Us

For questions, concerns, or requests related to this Privacy Policy or your personal data, contact us at:

Privacy Officer
Community Fund Uganda Inc.
1220 L Street NW, Suite 750
Washington, DC 20005
Email: privacy@communityfunduganda.org
Phone: (202) 555-0381