Data Controller Identity
This Privacy Policy governs data processing activities carried out by SYSTRA – SMC LIMITED, a private Single Member Corporation incorporated under the Companies Act of the Republic of Uganda (URSB Registration Number: 80034927231456), operating headquarters in Kampala, Uganda, and its operating subsidiaries including GateGrocer.
1. Regulatory Framework & Scope
SYSTRA – SMC LIMITED operates in strict fidelity with statutory data protection legislation, primarily the Uganda Data Protection and Privacy Act, 2019 and its subordinate regulations, alongside cross-border standards including the European Union General Data Protection Regulation (EU GDPR 2016/679) where applicable to international counterparties.
This document applies to all personal information, commercial transactional metadata, biometric identifiers, and telemetry data ingested through:
- Corporate web portals and subsidiary interfaces (including
systracorp.comand GateGrocer web/mobile applications). - Enterprise B2B API integrations (URA PRN generation, EFRIS fiscal signing, and WhatsApp Cloud banking channels).
- Supply-chain fulfillment, logistics tracking, and last-mile order delivery registries.
2. Categories of Data Collected
GateGrocer Commerce & Fulfillment
Customer names, delivery physical addresses across Greater Kampala, telephone numbers, order SKU histories, delivery driver geolocation timestamps, and mobile money payment transaction confirmation codes.
B2B Middleware & Financial Rails
Institutional Taxpayer Identification Numbers (TINs), PRN registration tokens, EFRIS fiscal invoice signatures, API client keys, IP whitelists, and webhook delivery audit trails.
Corporate & Career Applicants
Curriculum vitae, national identification numbers, professional references, employment histories, and executive communications submitted to our recruitment or governance desks.
System Telemetry & Cookies
Encrypted session tokens, CDN routing headers, anonymized latency benchmarks, and consent state cookies managed via our GDPR preference modal.
3. Legal Basis for Data Processing
We process information strictly under lawful bases specified by Section 7 of the Uganda Data Protection Act and Article 6 of the GDPR:
- Performance of a Contract: Necessary for fulfillment of FMCG deliveries through GateGrocer or the execution of B2B enterprise software contracts.
- Statutory Obligation: Compliance with mandatory statutory filings, Uganda Revenue Authority (URA) tax invoicing, anti-money laundering (AML), and know-your-customer (KYC) requirements.
- Legitimate Interests: Securing enterprise systems against cyber intrusion, preventing fraudulent payment injection, and maintaining platform uptime.
- Explicit Consent: Granted by data subjects for marketing updates, performance cookies, or voluntary talent pool submissions.
4. Security Safeguards & Encryption Architecture
All data in transit is encrypted using Transport Layer Security (TLS 1.3). Data at rest in our distributed cloud databases is protected with AES-256 encryption. Cryptographic keys used for URA EFRIS fiscal signing and payment tokenization are sequestered inside hardware security modules (HSM) with strict role-based separation of privilege.
5. Data Subject Rights & Escalation
Under Uganda law and international standards, you hold enforceable rights regarding your personal records, including the right to request access, rectification, erasure, restriction of processing, or data portability.
Data Protection Officer Contact
To exercise statutory rights or submit an inquiry regarding data practices, contact our Data Protection Officer:
SYSTRA – SMC LIMITED (URSB BRN: 80034927231456)
Email: partnerships@systra.ug
Headquarters: Kampala, Uganda












