CeremonyWallet

Privacy Policy

A Product of Luak Holdings Limited

Effective Date: 12 June 2026·Last Updated: 12 June 2026

Luak Holdings Limited ("we", "us", "our"), the owner and operator of CeremonyWallet, is committed to protecting the privacy and personal data of all individuals who use our platform. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you access or use CeremonyWallet ("Platform", "Service") at https://ceremonywallet.com.

This Policy is drafted in compliance with the Uganda Data Protection and Privacy Act, 2019 ("DPPA"), the Uganda Data Protection and Privacy Regulations, 2021, and all other applicable data protection laws. By using CeremonyWallet, you consent to the practices described in this Policy.

1. Who We Are

CeremonyWallet is a digital treasury and fundraising management platform owned and operated by:

Luak Holdings Limited Website: https://ceremonywallet.com Email: support@ceremonywallet.com

For the purposes of the Uganda Data Protection and Privacy Act, 2019, Luak Holdings Limited is the Data Controller responsible for your personal data collected through the CeremonyWallet Platform.

2. Personal Data We Collect

We collect personal data that is necessary to provide, maintain, and improve the CeremonyWallet Service. The categories of personal data we collect include:

2.1 Information You Provide Directly

Full name and display name.
Email address.
Mobile phone number (used for Mobile Money transactions and account verification).
Password and account credentials (stored in encrypted form).
Event details you create, including ceremony name, date, and description.
Financial information such as Mobile Money account numbers and transaction references (we do not store full payment card numbers).
Communications you send to us, including support requests and feedback.

2.2 Information Collected Automatically

Device information including device type, operating system, and browser type.
IP address and approximate geographic location.
Usage data such as pages visited, features used, time spent, and clicks.
Log data including access times, error reports, and referring URLs.
Cookies and similar tracking technologies (see Section 8 on Cookies).

2.3 Information from Third Parties

Transaction data from Mobile Money providers (MTN Mobile Money Uganda, Airtel Money Uganda, and other payment partners), including payment confirmation, transaction ID, and amount.
Fraud detection and compliance data from our payment processing partners (PawaPay).

3. How We Use Your Personal Data

We process your personal data only for specified, explicit, and legitimate purposes. We use the personal data we collect to:

3.1 Provide and Operate the Service

Create and manage your CeremonyWallet account.
Set up and operate Ceremony Wallets (fundraising campaigns) on your behalf.
Process contributions and payments through Mobile Money and other payment channels.
Enable contributors to make and track pledges and payments.
Send you transaction confirmations, receipts, and account notifications.

3.2 Improve and Develop the Platform

Analyse usage patterns to understand how users interact with the Platform.
Identify and fix technical issues, bugs, and errors.
Develop new features and improve existing functionality.
Conduct internal research and analytics to enhance the user experience.

3.3 Communications and Support

Respond to your enquiries, support requests, and feedback.
Send you important service updates, security alerts, and policy changes.
Send promotional communications and product news, where you have given consent (you may opt out at any time).

3.4 Legal and Compliance Obligations

Verify your identity and comply with anti-money laundering (AML) and know-your-customer (KYC) requirements under Ugandan law.
Detect, investigate, and prevent fraudulent transactions, abuse, and security incidents.
Comply with requests from regulatory authorities, including the Uganda Financial Intelligence Authority (FIA), Uganda Communications Commission (UCC), and law enforcement agencies.
Enforce our Terms and Conditions and other legal agreements.

4. Legal Basis for Processing

Under the Uganda Data Protection and Privacy Act, 2019, we process your personal data on the following legal bases:

Contractual necessity: processing is necessary to perform the contract between you and Luak Holdings Limited when you use CeremonyWallet.
Legal obligation: processing is necessary to comply with our obligations under Ugandan law, including financial regulations and anti-money laundering requirements.
Legitimate interests: processing is necessary for our legitimate business interests, such as fraud prevention, improving our services, and ensuring platform security, provided such interests are not overridden by your rights and interests.
Consent: where we rely on your consent (for example, for marketing communications), you may withdraw that consent at any time by contacting us at support@ceremonywallet.com.

5. Sharing Your Personal Data

We do not sell your personal data to third parties. We may share your personal data only in the following circumstances:

5.1 Payment Service Providers

We share your mobile phone number, name, and transaction details with licensed Mobile Money operators and payment processors (such as MTN Mobile Money Uganda and Airtel Money Uganda) solely to process transactions initiated through the Platform. These providers are bound by their own data protection obligations.