Privacy Policy

1. Who we are

NOOA Energies Ltd ("NOOA Energies", "we", "us" or "our") is a Ugandan company that connects households with last-mile energy and utility solutions. We are the company behind NOOA Pay, our bill payment app, and Flexi Gas, our cooking gas ordering and delivery service. Our head office is at Seal Estates, Uganda.

This Privacy Policy applies to our corporate website at nooaenergies.com and to our dealings with website visitors, customers, business partners and people who contact us. NOOA Pay and Flexi Gas each have their own app-specific privacy notices that explain how data is handled inside those apps. Where an app notice applies, it takes priority for data collected through that app.

We handle personal data in line with the Data Protection and Privacy Act, 2019 of Uganda and its regulations. By using our website or contacting us, you confirm that you have read this policy.

2. Information we collect

Information you give us:

• Contact details and messages: your name, email address, phone number and the content of any message you send through our website, email, phone or WhatsApp.
• Order details: if you order cooking gas or accessories through us, your name, phone number, delivery address or location, the products you order and your order history.
• Payment confirmation details: confirmation that a mobile money payment was made, such as a transaction reference. We do not see or store your mobile money PIN.
• Business and partner information: details of suppliers, distributors, delivery partners and other business contacts, such as company name, contact person and business registration details.
• Job or partnership applications: any information you include in a CV, application or proposal you send us.

Information collected automatically when you visit our website:

• Device and technical information: IP address, browser type and version, device type, operating system, language and approximate location based on your IP address.
• Usage information: the pages you visit, how long you stay, and the website you came from.
• Cookies and similar technologies, as described in section 5.

We do not knowingly collect sensitive personal data through our website, and we ask that you do not send it to us.

3. How we use your information

We use personal data to:

• Respond to your questions, requests and feedback.
• Take, process, deliver and support gas and accessory orders.
• Operate, secure and improve our website, products and services.
• Understand how our website is used so we can make it better.
• Work with suppliers, delivery partners and other business partners.
• Review and respond to job and partnership applications.
• Detect, prevent and investigate fraud, abuse and security incidents.
• Meet our legal, tax, accounting and regulatory obligations.
• Send you updates or offers about our products only if you have agreed to receive them. You can opt out at any time.

4. Our legal grounds for using your data

Depending on the situation, we rely on one or more of these grounds:

• Your consent, for example when you subscribe to updates or accept non-essential cookies.
• Performance of a contract, because we need your details to fulfil an order or agreement you have asked for.
• Compliance with a legal obligation, such as financial record keeping.
• Our legitimate interests, such as keeping our website secure and improving our services, where these are not outweighed by your rights.

Where we rely on consent, you can withdraw it at any time. This does not affect processing that happened before you withdrew it.

5. Cookies and similar technologies

Our website may use cookies and similar tools. Essential cookies keep the site working and secure. Analytics tools help us understand how visitors use the site. You can control or delete cookies in your browser settings. Blocking some cookies may affect how parts of the website work.

6. Who we share your information with

We do not sell your personal data. We share it only where needed and only with:

• Service providers who work for us under contract, such as website hosting, email, messaging, analytics and customer support providers. They may only use your data to provide services to us.
• Gas suppliers and delivery partners, so that your Flexi Gas order can be filled and delivered to the right place.
• Mobile money providers and payment networks, to confirm and complete payments.
• Professional advisers such as lawyers, accountants and auditors.
• Authorities, regulators and courts, where the law requires it or where it is needed to protect our rights, our customers or the public.
• A successor business, if NOOA Energies is involved in a merger, acquisition or sale of assets. We will tell you if this affects your data.

7. Security

We use technical and organisational measures to protect personal data, including encrypted connections, access controls and limiting who at NOOA Energies can see personal data. No system is completely secure, so please take care when sending information online and never share your mobile money PIN or passwords with anyone.

If we become aware of a breach affecting your personal data that is likely to cause you harm, we will notify you and the relevant authority as required by law.

8. How long we keep your data

We keep personal data only as long as we need it for the purposes in this policy, including to meet financial, tax, accounting and regulatory record keeping requirements, to resolve disputes and to prevent fraud. When we no longer need data, we delete it or anonymise it.

9. Your rights

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

• Be informed about how your personal data is used.
• Access the personal data we hold about you.
• Ask us to correct data that is wrong or incomplete.
• Ask us to delete data we no longer have a lawful reason to keep.
• Object to or ask us to restrict certain uses of your data, including direct marketing.
• Withdraw your consent at any time where we rely on it.
• Complain to the Personal Data Protection Office (PDPO) at the National Information Technology Authority, Uganda (NITA-U) if you believe your data has been handled unlawfully.

To use any of these rights, email support@nooaenergies.com. We may need to confirm your identity first and will respond within a reasonable time. Some data must be kept by law, and we will tell you if that applies to your request.

10. Children

Our website and services are not intended for people under 18, and we do not knowingly collect personal data from children. If you believe a child has given us personal data, contact us and we will delete it.

11. Transfers outside Uganda

Some of our service providers, such as hosting, email and analytics providers, may process data on servers outside Uganda. Where this happens, we take steps to make sure your data receives a level of protection that meets the requirements of Ugandan law.

12. Links to other websites

Our website links to other sites and services, such as the Google Play Store, our NOOA Pay and Flexi Gas sites, and social media pages. We are not responsible for the privacy practices of sites we do not operate, and we encourage you to read their policies.

13. Changes to this policy

We may update this policy from time to time. When we make important changes, we will post the new version on this page with a new "Last updated" date. Continuing to use our website after a change means you accept the updated policy.

14. Contact us

If you have questions about this policy or how your data is handled, contact us:

• Email: support@nooaenergies.com
• Phone: +256 200 909 475
• WhatsApp: +256 766 180 571
• Address: NOOA Energies Ltd, Seal Estates, Uganda