Dhahab Mines respects your privacy. We are committed to ensuring all information we collect or hold is handled respectfully and by relevant privacy laws.
The purpose of this Policy is to provide a clear statement of our commitment to protecting the personal information we collect, store, use and disclose.
Application
All officers, employees, embedded consultants, and entities controlled by Dhahab Mines (‘we’) are required to comply with this Policy.
Personal and sensitive information
Personal information includes a broad range of information that could identify an individual, including your name, contact details, identification details, qualifications, employment history, relevant record checks, payroll information, and shareholder information.
Sensitive information is personal information that includes information or an opinion about certain sensitive matters such as an individual’s health, criminal record, and racial or ethnic origin.
Compliance with laws
We will only collect, store, use and disclose personal information or modify this Policy by applicable laws.
Dhahab Mines will:
- only collect the personal information we reasonably need for our business operations and to comply with applicable laws;
- if appropriate, inform you why we are collecting personal information from you and how we plan to use the information;
- if possible, collect personal information directly from you. There may be circumstances where we collect information about you through a third party;
- use or disclose personal information for appropriate purposes;
- use or disclose sensitive information only as necessary;
- where practicable, use physical and electronic measures to protect personal information and restrict access to the information we hold; and
- allow you to update your personal information, make complaints about privacy concerns, and exercise your privacy rights under relevant laws.
If any of the above commitments conflict with applicable laws, the applicable laws take precedence.
The types of information we collect and why
We collect personal information from individuals as required to conduct our business operations. This includes when individuals use our website, apply for a position, work with us, attend our sites, invest in us, or engage with us in other ways.
We collect, use, store, and disclose this personal information to:
- manage our operations (including safety and security);
- protect and enforce our legal rights and obligations;
- comply with applicable laws, regulations, and Dhahab Mines’ Code of Conduct, policies, and standards;
- assist us with queries raised;
- keep records of our shareholders;
- consider applications from prospective employees or contractors;
- conduct or participate in investigations or due diligence;
- facilitate transactions involving Dhahab Mines or any of our affiliates.
We also collect some personal information under laws including, in Uganda, the Fair Work Act, the Income Tax Assessment Act and other tax laws, the Corporations Act, the occupational health and safety act, and Workers’ compensation acts.
If we intend to use or disclose your personal information in ways not described in this Policy, we will give you prior notification.
Sometimes, we may collect sensitive information including from our employees and contractors to:
- comply with the workplace or equal opportunity laws and improve our workplace diversity; and
- conduct criminal records and medical checks.
Where appropriate, we will confirm your express consent before collecting such information.
We may not be able to do the things described above if we are unable to collect your personal information. For example, we may not be able to communicate with you or process your request or application.
If you don’t want Dhahab Mines to use your personal information in a particular way, you can contact our Privacy Officer (details below) to discuss how we can limit the collection, use, or disclosure of your personal information.
De-identified personal information
We may anonymize and aggregate your personal information so that you are not identifiable and disclose the information to third parties or publicly.
We may use that information for any purpose, including understanding our employees, improving employee programs, and marketing or promotional purposes.
We do not disclose aggregate information in a way that would identify you personally unless permitted by law. However, there is always a risk of re-identification of de-identified personal information.
How we collect personal information
We collect personal information directly from you where possible. Sometimes, we may collect personal information about you from third parties, our employees (such as details of family members or next of kin), or from publicly available information.
How we secure your personal information
We use physical and electronic measures to protect personal information, including taking steps to restrict access to databases, maintain firewalls, and encrypt data.
However, the internet is not a secure environment and no computer system is perfectly secure. Although all care is taken, Dhahab Mines cannot guarantee the security of the information provided to us. This means there is always a risk that your personal information may be accessed or used without authorization.
To whom we disclose personal information to
We may disclose certain information to (and collect it from) third-party service providers (including recruitment, share registry, payroll, superannuation, employee benefits, training, investigation, legal, insurance, IT/data or surveillance providers), professional advisers, agents and any other third parties who assist us with our business operations.
We may also disclose personal information to (and collect it from):
- any Dhahab Mines entities covered by this Policy;
- our joint ventures;
- our related entities; and
- parties who are investing in Dhahab Mines or involved in a transaction with Dhahab Mines.
We may disclose personal information to service providers and other recipients across our operating jurisdictions. Dhahab Mines, those service providers, and other recipients may process personal information in jurisdictions including Uganda, Kenya, Tanzania, Zambia, Zimbabwe, South Sudan, and the Democratic Republic of Congo.
Privacy laws between these countries vary and may be less stringent than the laws in your country. Personal information may be accessible to governments, courts, law enforcement, national security authorities, and regulatory agencies of these countries by applicable laws.
We may also make other disclosures, including:
- to government agencies or regulatory bodies if Dhahab Mines considers it appropriate from a legal, regulatory or reputational perspective;
- for staff, inclusion in our websites, online channels, and publications where appropriate;
- to referees and other employers seeking a reference; and
- making limited shareholder details available to members of the public on request, by company laws.
How long do we store your personal information?
Except where permitted by law, we only keep your personal information as long as required to conduct our business operations and maintain an appropriate record of our relationship with you.
If we are legally required to keep your personal information for a certain period, we will do so.
Exemptions or other permitted conduct
We may sometimes engage in conduct that is permitted under the laws of particular countries (e.g. under legal exemptions), even if that conduct differs from this Policy.
For example:
- some countries may allow us to collect, use and disclose personal information without consent in certain circumstances;
- Uganda’s Privacy Act does not apply to certain records we hold relating to current or former employees.
Access to and correction of personal information
You can request access to or correction of personal information that we hold about you. You may do so by contacting our Privacy Officer (details below). We may need to verify your identity before giving you access to your personal information.
In some circumstances, we may not be able to provide you with all the personal information or data we have about you (for example, where a legal exemption applies). If we cannot provide you access, we will tell you why.
Complaints and inquiries
If you wish to make a complaint about how we have handled your personal information or if you believe we have breached the privacy laws that apply to your personal information, you may contact our Privacy Officer at:
Privacy Officer
Dhahab Mines Limited
E: privacy.officer@dhahabmines.com
Our Privacy Officer will investigate your complaint and respond to you promptly.
You can also contact our Privacy Officer if you have any queries about our Privacy Policy.
Our website
We use cookies and IP address tracking to administer our Dhahab Mines website and improve our service and content. Information collected through cookies and IP address tracking may include your email address and device details. We may also track patterns of use and visitors to our website. We do not seek to identify individuals through cookies or IP tracking.
Our website may use Google services such as Google Analytics. For more about how Google collects and processes its data, please see Google’s privacy policy and their information at
www.google.com/policies/privacy/partners/
Updates to this Policy
Dhahab Mines may update this Policy from time to time. Where required, Dhahab Mines will inform you of any significant modifications before we make changes. We encourage you to check the Dhahab Mines website regularly to ensure that you are aware of the current policy.
Approved by the Board December 2020