PRIVACY POLICY
Dharmik Venture Limited
Medical Equipment Supply | Kampala, Uganda
Last Updated: April 08, 2026 | Effective Date: April 08, 2026
Version 2.0
Regulatory Framework: This Privacy Policy complies with the Data Protection and Privacy Act No. 9 of 2019 (DPPA) and the Data Protection and Privacy Regulations, 2021, as administered by the Personal Data Protection Office (PDPO) under the National Information Technology Authority – Uganda (NITA-U). It also reflects applicable requirements of the National Drug Policy and Authority Act (Cap. 206), the Surgical Instruments and Appliances Regulation (SI No. 77 of 2019), and the Ministerial Decree ADM.140/323/01 of 2020 governing medical devices in Uganda.
1. Introduction and Who We Are
Dharmik Venture Limited (“Company”, “We”, “Us”, “Our”) is a company incorporated and operating in Uganda, with its registered office at 1st Floor, Shop No. 3, R D’Almeida and Sons House, Bombo Road, Kampala, Uganda. We are engaged in the supply, distribution, and sale of medical equipment and surgical instruments within Uganda.
This Privacy Policy explains how We collect, use, store, share, and protect Your personal information when You interact with Our website (https://dharmikventuresltd.com/) and related business activities. It also describes Your rights under Ugandan law and how You can exercise them.
Data Controller Registration: As required by Regulation 15(1) of the Data Protection and Privacy Regulations, 2021, Dharmik Venture Limited is registered (or in the process of registering) as a Data Controller with the Personal Data Protection Office (PDPO), NITA-U, Kampala, Uganda.
Data Protection Officer: In accordance with Section 29 of the DPPA, We have designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy. You may contact the DPO at: info@dharmikventuresltd.com
2. Interpretation and Definitions
2.1 Interpretation
Words whose initial letters are capitalised have meanings defined below. These definitions apply whether terms appear in singular or plural form.
2.2 Definitions
Account: A unique account created for You to access Our Service or parts thereof.
Company / We / Us / Our: Refers to Dharmik Venture Limited, 1st Floor, Shop No. 3, R D’Almeida and Sons House, Bombo Road Kampala, Uganda.
Cookies: Small files placed on Your Device by a website, recording browsing details and preferences.
Country: Uganda.
Data Controller: A person, institution, or public body that determines the purposes and means of processing personal data, as defined in the DPPA.
Data Processor: Any person or institution that processes personal data on behalf of the Data Controller.
Device: Any device capable of accessing the Service, including computers, mobile phones, and digital tablets.
Medical Equipment: Surgical instruments, appliances, and medical devices regulated by the National Drug Authority (NDA) under Uganda’s regulatory framework.
PDPO: The Personal Data Protection Office, the independent data protection supervisory authority established under NITA-U, Uganda.
Personal Data / Personal Information: Any information relating to an identified or identifiable natural person, as defined under Section 2 of the DPPA.
Sensitive Personal Data: Includes health data, financial data, biometric data, and any other data classified as sensitive under Section 13 of the DPPA.
Service: Refers to the Website.
Service Provider: A natural or legal person who processes data on behalf of the Company.
Usage Data: Data collected automatically through the use of the Service, such as IP addresses, browser type, and session durations.
Website: Dharmik Venture Limited’s website, accessible at https://dharmikventuresltd.com/
You / Data Subject: The individual accessing the Service, or the entity on whose behalf such individual is acting.
3. What Personal Data We Collect
3.1 Data You Provide Directly
When You use Our Service, enquire about medical equipment, request a quotation, or contact Us for support, We may collect:
Full name and title
Organisation/institution name (hospital, clinic, medical practice)
Email address
Phone number and mobile number
Physical address (including city, district, and postal code)
Professional credentials and licensing information (where relevant for medical procurement compliance)
Communication records, including enquiries and correspondence
Any other information You voluntarily provide
3.2 Usage Data (Collected Automatically)
When You visit Our Website, We automatically collect technical data including:
Internet Protocol (IP) address
Browser type and version
Pages visited, time and date of visit, and time spent on pages
Unique device identifiers and diagnostic data
Referring URLs and exit pages
Mobile device type and operating system (when accessing via mobile)
3.3 Tracking Technologies and Cookies
We use Cookies and similar tracking technologies (beacons, tags, scripts) to improve and analyse Our Service. These include:
Session Cookies – deleted when You close Your browser; used for authentication and service delivery
Persistent Cookies – remain on Your Device after going offline; used for preference retention and cookie consent recording
Functionality Cookies – remember Your login details and language preference
Web Beacons – electronic files used to count page visits and verify server integrity
Where required by Ugandan law, non-essential cookies (analytics, advertising, or remarketing) will only be used with Your prior consent. You may withdraw or change consent at any time via Your browser settings. Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.
3.4 Health-Related and Sensitive Data
As a medical equipment supplier, We may in limited circumstances receive or process data that constitutes sensitive personal data under Section 13 of the DPPA (e.g., professional health credentials or institutional health-related procurement requirements). We collect and process such data only where: (a) You have provided explicit written consent; (b) processing is required by law; or (c) processing is necessary for the performance of a contract. We do not collect patient health data.
4. Legal Basis for Processing Your Personal Data
In accordance with the DPPA, We process Your personal data only where We have a lawful basis to do so. The legal bases We rely on are:
Consent (Section 14 DPPA) – Where You have given freely given, specific, informed, and unambiguous consent.
Performance of a Contract (Section 15(b) DPPA) – Processing is necessary for the performance of a contract to which You are party, or to take steps prior to entering into a contract at Your request (e.g., processing enquiries, quotations, orders for medical equipment).
Legal Obligation (Section 15(a) DPPA) – Processing is required to comply with applicable Ugandan law, including NDA licensing requirements, tax obligations (Uganda Revenue Authority), and financial reporting requirements.
Legitimate Interests – Processing is necessary for Our legitimate business interests, provided those interests are not overridden by Your rights and interests (e.g., improving our website, security monitoring, fraud prevention).
Vital Interests – In rare circumstances, where processing is necessary to protect life.
5. How We Use Your Personal Data
We use Your personal data for the following specific purposes:
To provide, operate, and maintain Our website and business services
To process and respond to your enquiries, quotations, and orders for medical equipment
To manage Your account and registered user access
To fulfil contractual obligations under purchase agreements for medical equipment
To send transactional communications relating to your orders or account (via email, phone, or SMS)
To send informational updates about medical equipment, product availability, and regulatory changes relevant to your procurement needs – where you have not opted out
To comply with NDA regulatory requirements applicable to the supply of medical devices and surgical instruments in Uganda
To comply with Uganda Revenue Authority (URA) tax and financial record-keeping obligations
To conduct business transfers, mergers, acquisitions, or restructuring activities, where necessary
To analyse website usage trends, improve our Service, and evaluate marketing effectiveness
To maintain security, detect fraud, and protect Our legal rights
We do not use Your personal data for automated decision-making or profiling that produces legal or similarly significant effects on You.
6. Payment Methods and Financial Data
Dharmik Venture Limited processes payments exclusively through offline channels. We do not collect, process, or store online payment card data or digital payment credentials through Our website. Our accepted payment methods are:
Cash – received at our registered premises
Cheque – payable to Dharmik Venture Limited
Mobile Money – via registered Ugandan mobile money platforms (MTN Mobile Money, Airtel Money)
Bank Transfer – to our designated business bank account
Financial transaction records (invoices, receipts, payment confirmations) are retained in accordance with Uganda Revenue Authority (URA) requirements and applicable tax law. These records may constitute personal data where they are linked to an identifiable individual and are processed in accordance with this Policy.
Important: We will never request payment credentials or sensitive financial information through Our website, by email, or via unsolicited communication. If You receive such a request purportedly from Us, please contact Us immediately at info@dharmikventuresltd.com.
7. Sharing and Disclosure of Your Personal Data
We may share Your personal data in the following circumstances:
7.1 Service Providers
We may share data with trusted third-party service providers who assist Us in operating Our business (e.g., IT support, website hosting, courier and logistics services). These providers are contractually obligated to handle Your data securely, only for the specified purpose, and in compliance with the DPPA.
7.2 Regulatory Authorities
We may disclose Your data to the National Drug Authority (NDA), Uganda Revenue Authority (URA), or other competent Ugandan authorities where required by law, regulatory obligation, or lawful request.
7.3 Law Enforcement
We may disclose Your data if required to do so by law, court order, or in response to valid requests by Ugandan public authorities for the purposes of national security, crime prevention, or legal proceedings.
7.4 Business Transfers
In the event of a merger, acquisition, asset sale, or restructuring, Your personal data may be transferred to the acquiring or successor entity. We will provide prior notice before Your data becomes subject to a different privacy policy.
7.5 Affiliates
We may share Your data with our parent company, subsidiaries, or joint venture partners, who are required to honour this Privacy Policy.
7.6 With Your Consent
We may disclose Your data for any other purpose with Your explicit and prior written consent.
7.7 No Sale of Personal Data
We do not sell, rent, or trade Your personal data to third parties for commercial or marketing purposes. Doing so would constitute a criminal offence under the DPPA.
8. International Transfer of Personal Data
Your personal data may be processed or stored outside Uganda where Our service providers are located. In accordance with the DPPA, any international transfer of personal data will only occur where:
The recipient country has adequate data protection measures at least equivalent to those under the DPPA; or
Appropriate contractual safeguards are in place between Dharmik Venture Limited and the recipient; or
Such transfer is authorised or required by Ugandan law.
We will take all reasonably necessary steps to ensure Your data is treated securely in any jurisdiction to which it is transferred.
9. Retention of Your Personal Data
We retain personal data only for as long as necessary for the purposes for which it was collected, and as required by Ugandan law. Our retention periods are as follows:
Account Information: Duration of account relationship plus up to 24 months after account closure
Customer Support Records (tickets, correspondence, chat transcripts): Up to 24 months from ticket closure
Website Usage Data (cookies, IP addresses, device identifiers, server logs): Up to 24 months from collection
Transaction and Financial Records (invoices, receipts, payment records): As required by the URA and applicable tax legislation (currently a minimum of 5 years under Ugandan tax law)
NDA Compliance Records (supplier licensing, adverse event reports): As required by the NDA and applicable medical device regulations
We may retain data beyond the above periods where required by legal obligation, to establish or defend legal claims, at Your explicit request, or due to technical backup limitations. At expiry, data is securely deleted, anonymised, or de-identified in accordance with Section 18 of the DPPA.
10. Your Rights as a Data Subject
Under the Data Protection and Privacy Act, 2019, You have the following rights regarding Your personal data:
Right of Access (Section 22 DPPA) – You may request confirmation of whether We hold Your personal data and obtain a copy of it.
Right to Rectification – You may request correction of inaccurate or incomplete personal data We hold about You.
Right to Erasure / Deletion (Section 24 DPPA) – You may request deletion of Your personal data, subject to Our legal obligations and legitimate interests.
Right to Object – You may object to the processing of Your personal data for direct marketing, profiling, or other purposes based on Our legitimate interests.
Right to Restriction of Processing – You may request that We restrict processing of Your data in certain circumstances.
Right to Data Portability – You may request that We provide Your personal data in a structured, machine-readable format where technically feasible.
Right to Withdraw Consent – Where processing is based on consent, You may withdraw consent at any time without affecting the lawfulness of prior processing.
Right to Lodge a Complaint – You have the right to lodge a complaint with the Personal Data Protection Office (PDPO) at NITA-U, Plot 10 Parliament Avenue, Kampala, Uganda. Tel: +256 417 801 038. Email: pdpo@nita.go.ug. Website: www.pdpo.go.ug
To exercise any of the above rights, please contact Us using the details in Section 14. We will respond to Your request within a reasonable time, and in any event within the period stipulated by the DPPA and its Regulations.
11. Security of Your Personal Data
We implement commercially reasonable administrative, technical, and physical safeguards to protect Your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include encrypted data storage, access controls, and regular security assessments.
However, no method of electronic storage or internet transmission is 100% secure. While We strive to protect Your personal data, We cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to Your rights and freedoms, We will notify the PDPO and affected individuals as required by the DPPA and Regulations.
12. Children’s Privacy
Our Service and medical equipment supply activities are directed exclusively to businesses, healthcare professionals, and institutional buyers. Our Service is not directed at individuals under the age of 18.
We do not knowingly collect personal data from anyone under the age of 18. If You are a parent or guardian and believe Your child has provided Us with personal data, please contact Us immediately at info@dharmikventuresltd.com and We will take steps to delete such data from Our systems.
Where We are required by law to rely on parental consent as the legal basis for processing data of a minor, We will obtain such consent before collection.
13. Medical Equipment Regulatory Compliance Notice
Dharmik Venture Limited operates as a supplier and distributor of medical equipment regulated by the National Drug Authority (NDA) of Uganda. In the course of our regulated activities, we may be required to collect and retain certain business and transactional data to comply with:
NDA licensing and registration requirements under the Surgical Instruments and Appliances Regulation, SI No. 77 of 2019
Ministerial Decree ADM.140/323/01 of 2020 on medical device regulation
Post-market surveillance and adverse event reporting obligations
Documentation requirements under NDA registration tracks
Data collected solely for NDA regulatory compliance purposes is retained for the legally mandated period and is not used for any other commercial purpose without Your consent.
We do not collect, store, or process patient health records or clinical data through Our website. Our data activities are limited to B2B commercial and procurement interactions with healthcare institutions, practitioners, and suppliers.
14. Links to Third-Party Websites
Our Website may contain links to third-party websites not operated by Us. If You click on a third-party link, You will be directed to that site. We strongly advise You to review the privacy policy of every site You visit. We have no control over, and assume no responsibility for, the content or privacy practices of third-party sites or services.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business practices, applicable Ugandan law, or PDPO guidance. We will notify You of material changes by:
Posting the revised Policy on this page with an updated effective date
Sending a notification to Your registered email address
Displaying a prominent notice on Our Website prior to the change becoming effective
We encourage You to review this Policy periodically. Continued use of Our Service after changes are posted constitutes Your acceptance of the updated Policy.
16. Contact Us and How to Exercise Your Rights
If You have any questions, concerns, or complaints about this Privacy Policy or Our data practices, or wish to exercise any of Your rights under the DPPA, please contact Us:
Company Name: Dharmik Venture Limited
Physical Address: 1st Floor, Shop No. 3, R D’Almeida and Sons House, Bombo Road, Kampala, Uganda
Email: info@dharmikventuresltd.com
Website: https://dharmikventuresltd.com/
For unresolved complaints, You may escalate to the Personal Data Protection Office (PDPO):
Address: NITA-U, Plot 10 Parliament Avenue, Kampala, Uganda
Email: pdpo@nita.go.ug
Website: www.pdpo.go.ug
This Privacy Policy was drafted to comply with the Data Protection and Privacy Act No. 9 of 2019,
the Data Protection and Privacy Regulations 2021, and applicable Ugandan medical device legislation.
© 2026 Dharmik Venture Limited. All rights reserved.