Privacy Policy

1. Introduction

Sea Stone Garden Consulting Ltd. ("Sea Stone Garden", "we", "us", or "our") is committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (seastonegarden.info), engage our services, or otherwise interact with us.

Please read this policy carefully. If you do not agree with any part of it, please discontinue your use of our website and services. For questions, contact us at contact@seastonegarden.info.

2. Information We Collect

We collect different types of information depending on how you interact with us:

2.1 Information You Provide Directly

• Contact information: name, email address, phone number, and organisation when you submit enquiry forms or book appointments.
• Communication content: the content of emails, messages, or notes you send us.
• Programme participation: information gathered during coaching assessments, workshops, or facilitated sessions (handled with strict confidentiality).
• Newsletter subscriptions: your email address if you subscribe to our communications.
• Payment information: billing details when you purchase services (processed securely via third-party payment processors; we do not store card details).

2.2 Information Collected Automatically

• Usage data: pages visited, time spent, referral sources, and browser/device information via cookies and analytics tools.
• IP address and location data: general location inferred from your IP address.
• Cookies: see our Cookies section below for full details.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to your enquiries and provide our coaching and consulting services.
• To manage our client relationships, including scheduling, billing, and programme delivery.
• To send you newsletters, insights, and promotional communications (only with your consent).
• To improve our website, services, and client experience through anonymised analytics.
• To comply with legal obligations, including financial record-keeping and anti-money-laundering requirements under Ugandan law.
• To protect the security and integrity of our systems and services.

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contractual necessity: to fulfil our service obligations when you engage us as a client.
• Legitimate interests: for website analytics, business development, and improving our services.
• Consent: for marketing communications and non-essential cookies. You may withdraw consent at any time.
• Legal obligation: where required by Ugandan law, including the Data Protection and Privacy Act, 2019.

5. Sharing Your Information

We do not sell your personal information. We may share it in the following limited circumstances:

• Service providers: trusted third-party providers who assist us in operating our website and services (e.g. email platforms, payment processors, video conferencing tools). They are contractually obligated to protect your data.
• Legal requirements: if required to do so by law, court order, or regulatory authority.
• Business transfers: in the event of a merger or acquisition, your data may be transferred to the successor entity, subject to the same privacy protections.
• With your explicit consent: for any other purpose not listed here.

All coaching and facilitation conversations are held in strict professional confidence and are not shared without your explicit, informed consent.

6. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including:

• Active client records: for the duration of our engagement plus 7 years (for financial and legal compliance under Ugandan law).
• Marketing subscribers: until you unsubscribe.
• Website analytics data: aggregated for up to 26 months.
• Enquiry records: 2 years after last contact if no engagement results.

7. Your Rights

Under Uganda's Data Protection and Privacy Act, 2019, you have the following rights regarding your personal data:

• Right of access: request a copy of the personal data we hold about you.
• Right to rectification: ask us to correct inaccurate or incomplete data.
• Right to erasure: request deletion of your data, subject to legal retention obligations.
• Right to restrict processing: ask us to pause how we use your data in certain circumstances.
• Right to data portability: receive your data in a structured, machine-readable format.
• Right to object: object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent: where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at contact@seastonegarden.info. We will respond within 30 days.

8. Cookies

Our website uses cookies and similar tracking technologies. Cookies are small text files stored on your device. We use:

• Essential cookies: necessary for the website to function correctly (e.g. session management). These cannot be disabled.
• Analytics cookies: to understand how visitors use our website (e.g. Google Analytics). These are only set with your consent.
• Preference cookies: to remember your settings and preferences.

You can control cookies through your browser settings. Note that disabling certain cookies may affect website functionality. For more information, visit allaboutcookies.org.

9. Data Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

• SSL/TLS encryption for data in transit.
• Secure, password-protected systems for data storage.
• Restricted access to personal data on a need-to-know basis.
• Regular security reviews and staff data protection training.

However, no internet transmission or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

10. Children's Privacy

Our services are directed at professionals aged 18 and over. We do not knowingly collect personal data from individuals under 18 years of age. If you believe we have inadvertently collected data from a minor, please contact us immediately at contact@seastonegarden.info and we will promptly delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the new policy on this page with a revised "Last Updated" date, and where appropriate, by email. We encourage you to review this page periodically.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

You also have the right to lodge a complaint with Uganda's Personal Data Protection Office (PDPO) if you believe your data has been handled unlawfully.