Privacy Policy

Last Updated: February 11, 2026

Boldstone Investments, its subsidiaries and affiliates ("Boldstone," "we," "us," or "our") respects your privacy. This Privacy Policy ("Policy") describes how we collect, use, process, disclose, and safeguard your information when you engage with our real estate investment syndications, agricultural projects, and related services (collectively, the “Services”).

This Policy applies to all services offered by Boldstone Investments in Uganda and internationally where expressly adopted.

We are committed to complying with the Data Protection and Privacy Act, 2019 (Uganda) and applicable regulations.

1. Information We Collect

We may collect personal information to provide, improve, market, and legally administer our Services.

“Personal Information” refers to information that identifies you directly or indirectly.

You may not be required to provide all requested Personal Information; however, failure to provide certain information may limit our ability to offer investment services.

Categories of Personal Information We Collect

A. Identifiers

Full name
National ID number / Passport number
Tax Identification Number (TIN)
Physical and postal address
Email address
Phone number
Date of birth
IP address
Device identifiers

B. Financial Information

Bank account details
Source of funds
Income verification
Investment experience
Risk tolerance
Transaction history
Capital contributions

C. Professional Information

Employment details
Business ownership information

D. Website & Technical Data

Browsing activity
Session data
Device type
Browser type
Location data (where permitted by law)

We may also generate anonymized or aggregated data that does not identify any individual.

2. Sources of Information and Purpose of Collection

We collect Personal Information from the following sources:

A. Directly From You

Investment application forms
Subscription agreements
Email correspondence
Investor onboarding processes
KYC compliance documentation

Purpose:

Provide and administer investment services
Conduct due diligence and compliance checks
Prevent fraud and financial crime
Communicate investment updates
Fulfill legal obligations

B. Third Parties

Financial institutions
Regulatory authorities
Credit reference bureaus
Professional advisors

Purpose:

Regulatory compliance
Identity verification
Anti-money laundering compliance

C. Website Interactions

When you visit our website, we may collect technical information through cookies and analytics tools.

Purpose:

Improve user experience
Enhance platform security
Analyze performance
Market our services

3. How We Share Information

We do not sell your Personal Information.

We may share your information with:

A. Operational Service Providers

Legal advisors
Auditors
Fund administrators
Agricultural operators
Payment processors

B. Regulatory and Government Authorities

Where required under Ugandan law or international regulations.

C. Professional Advisors

Accountants, compliance consultants, and legal counsel.

D. Business Transfers

In the event of restructuring, merger, or acquisition.

All third parties are contractually required to protect your data.

4. Cookies and Tracking Technologies

We use cookies and similar technologies to:

Improve website performance
Analyze traffic
Enhance security
Remember user preferences

You may disable cookies in your browser settings. Some website functions may be limited if cookies are disabled.

5. Data Security

We implement administrative, technical, and physical safeguards to protect Personal Information against unauthorized access, loss, misuse, or alteration.

However, no digital transmission or storage system can be guaranteed 100% secure.

6. Data Retention

We retain Personal Information only as long as necessary to:

Fulfill investment obligations
Comply with legal and tax requirements
Resolve disputes
Enforce agreements

Retention periods are guided by Ugandan regulatory requirements.

7. Your Rights Under Ugandan Law

Under the Data Protection and Privacy Act, 2019 (Uganda), you have the right to:

Access your Personal Information
Request correction of inaccurate information
Request deletion where legally permissible
Withdraw consent (where processing is based on consent)
Object to certain types of processing

Requests may require identity verification.

8. International Data Transfers

If you are located outside Uganda, your information may be processed in Uganda or other jurisdictions where our service providers operate, subject to appropriate safeguards.

9. Updates to This Policy

We may update this Policy periodically. Updates will be posted on our website with a revised “Last Updated” date.

10. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us via boldstone.investments@gmail.com