Privacy & Data Protection Policy

1. Introduction

Atine Labs™ Limited ("we", "us", "our") is committed to protecting the privacy and personal data of all individuals whose data we process. This policy explains how we collect, use, store, and protect personal data in compliance with the EU General Data Protection Regulation (GDPR), the Uganda Personal Data Protection Office Act 2019 (PDPO), the Uganda Data Protection and Privacy Regulations 2021 (DPPR), and applicable Belgian ePrivacy requirements.

2. Data Controller

Atine Labs™ Limited
Origin: Oyam, Uganda
Email: admin@alglobal.systems

3. Personal Data We Collect

Identity data: name, job title, organisation
Contact data: email address, phone number, postal address
Technical data: IP address, browser type, device identifiers, cookies
Usage data: pages visited, features used, interaction timestamps
Communication data: enquiries, support tickets, booking details
HR/Payroll data (when using AtineHR™): employee records, payroll information, biometric data (with explicit consent)

4. Legal Bases for Processing

We process personal data under the following legal bases:

Contract performance: to deliver our products and services
Legitimate interests: security, fraud prevention, service improvement
Legal obligation: tax, employment, and regulatory compliance
Consent: marketing communications, cookies (where required)

5. Data Retention

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, and in accordance with our Data Retention Policy. Client data under SaaS agreements is retained for the term of the agreement plus 90 days, unless otherwise agreed.

6. Your Rights

Depending on your jurisdiction, you may have the right to: access your personal data; request correction or erasure; object to or restrict processing; request data portability; withdraw consent; and lodge a complaint with a supervisory authority. See our Data Subject Rights Policy for how to exercise these rights.

7. International Transfers

Where personal data is transferred outside the EEA or Uganda, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent mechanisms recognised under the Uganda PDPO.

8. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. See our Information Security Policy for details.

9. Third Parties & Sub-processors

We use carefully selected sub-processors to deliver our services. A current list is available in our Sub-processors Register. All sub-processors are bound by data processing agreements.

10. Cookies

We use cookies and similar technologies as described in our Cookie Policy.

11. Policy Updates

This policy is reviewed at least annually. Material changes are communicated to affected data subjects and published on this page with an updated effective date.