Legal

Privacy Policy

AI in HR Management — Online Masterclass · Last updated: 9 April 2026 · Effective date: 9 April 2026

This Privacy Policy describes how Phoenix Fortunes (SMC) Limited (trading as Coach Andeh) and Utile Solutions Limited, both incorporated in Uganda, collect, use, share and protect your personal data when you register for or participate in the AI in HR Management Online Masterclass ("the Programme"). This Policy is written to be consistent with the EU General Data Protection Regulation (GDPR), the UK GDPR, and the Uganda Data Protection and Privacy Act, 2019.

1. Who We Are (Data Controller)

Phoenix Fortunes (SMC) Limited is the data controller for your personal data in relation to the Programme. Utile Solutions Limited is a joint controller for the delivery and certification of the Programme. You can contact either entity at andeh@coachandeh.com.

2. What Personal Data We Collect

Data category	Examples	Source
Identity & contact	First name, last name, email address, mobile/WhatsApp phone number, country	You, on registration
Professional context	Organisation / employer, job title, HR role, how you heard about us	You, on registration
Cohort preferences	Weekend or weekday cohort selection, session attendance records	You and Zoom attendance logs
Payment data	Payment method, payment status, transaction reference, mobile money MSISDN (PawaPay), email (Stripe)	Stripe and/or PawaPay. We do not store full card numbers or PINs.
Programme engagement	Capstone submission, workbook entries, any automations shared in sessions	You, during the Programme
Technical data	IP address (for fraud prevention and country detection on mobile money), device/browser type, visited pages	Automatically, via your browser
Marketing preferences	Whether you have opted in to receive further communications from Coach Andeh after the Programme	You

3. How We Use Your Personal Data and the Legal Basis

Contract performance — processing your registration, allocating your cohort seat, delivering sessions, issuing the Certificate, responding to support queries.
Legal obligation — tax records, fraud prevention, responding to valid legal requests from Ugandan or other competent authorities.
Legitimate interests — improving the Programme content and materials, producing anonymised participant statistics, keeping our services secure, and recovering unpaid invoices. These interests are balanced against your rights.
Consent — sending you optional marketing communications, newsletters, invitations to future events, or using testimonials you provide publicly. You can withdraw consent at any time.

4. Who We Share Your Personal Data With

We do not sell your personal data. We share the minimum data needed with:

Payment providers — Stripe, Inc. (card payments) and PawaPay Ltd (mobile money). They act as independent controllers for fraud-prevention purposes and as processors for handling your payment.
Delivery and hosting partners — Zoom Video Communications (sessions), n8n (automation platform access during and after the Programme), Google Workspace (Sheets used as our registration log, Gmail for confirmations), Telegram (operational notifications to the trainer).
Website hosting & infrastructure — Hostinger and our VPS providers.
AI service providers — OpenAI and OpenRouter (LLM access for your automations). We do not send your personal identifiers to AI providers during the Programme; the automations you build are yours to configure.
Professional advisors — legal, accounting, audit, and tax advisors when strictly necessary.
Authorities — where required by law, court order or regulatory request.

5. International Transfers

Our service providers (Stripe, Zoom, Google, OpenAI, etc.) are based in the United States, the European Union and the United Kingdom. Where your personal data is transferred outside Uganda, the EEA or the UK, we rely on adequacy decisions or on Standard Contractual Clauses (SCCs) and equivalent safeguards approved under GDPR and the Uganda Data Protection and Privacy Act.

6. How Long We Keep Your Data

Registration & cohort records — for the duration of the Programme and up to 24 months thereafter to support alumni and testimonials.
Financial records (invoices, receipts) — 7 years, as required by Ugandan tax law.
Marketing data — until you unsubscribe or object, whichever comes first.
Technical logs — up to 12 months for security and fraud prevention.

Once the retention period ends, your personal data is deleted, anonymised, or archived in a secure form with access restricted to accounting and legal use only.

7. Your Rights

Subject to the applicable law, you have the right to:

Access — request a copy of the personal data we hold about you.
Rectification — have inaccurate or incomplete data corrected.
Erasure ("right to be forgotten") — request deletion of your data, subject to legal retention obligations.
Restriction — ask us to pause processing of your data while a request is being resolved.
Objection — object to processing based on our legitimate interests, or to direct marketing at any time.
Data portability — receive your data in a structured, machine-readable format.
Withdraw consent — at any time, where consent is the legal basis.
Lodge a complaint — with the Personal Data Protection Office (Uganda) or your local data protection authority in the EU/UK.

To exercise any of these rights, email us at andeh@coachandeh.com. We will respond within 30 days.

8. Cookies & Similar Technologies

This website uses essential cookies only to support navigation and to remember your cohort selection across pages. We do not use advertising or tracking cookies on this programme site. Google Fonts are loaded directly from Google's CDN.

9. Security

We apply reasonable technical and organisational measures to protect your personal data, including encryption in transit (HTTPS), restricted access to our internal systems, regular security reviews of our infrastructure, and strict access controls on the registration Google Sheet. No system is 100% secure; you share information with us at your own risk.

10. Children

The Programme is intended for working HR professionals. We do not knowingly collect personal data from children under the age of 18. If you believe a child has registered, please contact us and we will delete the data.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The version at the top of this page will show the date of the most recent update. Material changes will be communicated to registered Participants by email.

12. Contact & Complaints

For any privacy-related question or to exercise your rights, contact:
Phoenix Fortunes (SMC) Limited — andeh@coachandeh.com
Trading as Coach Andeh · Kampala, Uganda

If you are not satisfied with our response, you have the right to lodge a complaint with the Personal Data Protection Office of Uganda, or with your local data protection authority in the EEA or the UK.