PRIVACY, REFUND & RETURNS POLICY

Enjoy Tech Group  Ltd

Websites: www.enjoytechgroup.com

Effective Date: July 8, 2026

Last Updated: July 8, 2026

PART B - REFUND POLICY & RETURNS TERMS

1. Introduction & Who We Are

Enjoy Tech Group  Ltd ("we," "our," or "us") is a technology company incorporated under the laws of Uganda, providing online e-commerce services and technology solutions to customers in Uganda and beyond.

We are committed to protecting the privacy and personal data of every person who interacts with our platforms, websites, and services (collectively, the "Services").

This Privacy Policy explains:

• What personal data we collect and how we collect it 

• Why we collect it and the lawful basis for processing 

• How we use, store, and protect it 

• With whom we share it 

• How long we retain it 

• Your rights under Ugandan law 

By accessing or using our Services, you confirm that you have read, understood, and agree to this Privacy Policy.

We act as the Data Controller in relation to the personal data you provide - meaning we determine the purposes and manner in which your personal data is processed.

2. Personal Data We Collect

We collect only the personal data that is necessary, proportionate, and relevant to the purposes stated in this Policy.

2.1 Identity & Contact Information

• Full name - to identify you, personalise your experience, and address communications 

• Email address - for account registration, order confirmations, invoices, and service communications 

• Phone number - for order updates, delivery coordination, and customer support 

• Physical / delivery address - for processing and fulfilling orders 

2.2 Account Information

• Username and securely encrypted password 

• Account preferences and settings 

• Order history and transaction records 

• Saved items and wishlist data 

2.3 Payment Details

• Payment method type (e.g. mobile money - MTN MoMo, Airtel Money; credit/debit card; bank transfer)

• Billing name and billing address

• Transaction reference numbers, amounts, and timestamps 

Important: We do not store your full card numbers, mobile money PINs, CVV codes, or bank account credentials on our servers. All payment transactions are processed by PCI-DSS-certified third-party payment processors. We receive only tokenised references and confirmation data from those processors.

2.4 Technical & Device Data

• IP address and approximate geolocation (country / city level) 

• Browser type, version, and operating system 

• Device type and identifiers 

• Pages visited, time spent, and clickstream/navigation data 

• Referring website or search query 

2.5 Cookies & Tracking Data

See Section 5 (Cookies Policy) below.

2.6 Communications Data

• Messages you send us via email, live chat, or contact forms 

• Customer feedback, reviews, ratings, and survey responses you submit 

• Records of correspondence if you contact us about an order, refund, or complaint 

2.7 Children's Data

We do not knowingly collect personal data from children under the age of 18 without verifiable parental or guardian consent. If you believe we have inadvertently collected a child's data, please contact us immediately at the address in Section 11 and we will delete it promptly.

3. How We Collect Personal Data

We collect personal data through the following means:

• Directly from you - when you register an account, place an order, complete a form, contact support, or subscribe to communications 

• Automatically - through cookies, server logs, and analytics tools when you browse our websites (see Section 5) 

• From third parties - from payment processors (transaction confirmations), logistics partners (delivery status), and fraud-prevention services 

• From publicly available sources - only where relevant and lawful (e.g. verifying a business address) 

4. How and Why We Use Your Personal Data

We process your personal data only where we have a clear, lawful basis under the Data Protection and Privacy Act, 2019. The table below sets out our processing purposes and corresponding lawful bases:

We will never use your personal data for purposes incompatible with those listed above without obtaining fresh consent or establishing a new lawful basis.

Direct Marketing: If you have opted in to marketing communications, you may opt out at any time by clicking "Unsubscribe" in any marketing email, or by contacting us at the address in Section 11. Opting out of marketing does not affect transactional communications related to your orders.

5. Cookies Policy

What Are Cookies?

Cookies are small text files placed on your device when you visit our website. They help us recognise you, remember your preferences, and understand how you use our Services.

Types of Cookies We Use

Managing Your Cookie Preferences

You can control or delete cookies at any time through your browser settings. Most browsers allow you to:

• View cookies currently stored 

• Block all or selected cookies 

• Delete cookies on exit 

Disabling non-essential cookies will not prevent you from using our core Services, but some features (such as saved preferences or a persistent shopping cart) may not function as expected.

Our website displays a cookie consent banner on your first visit. You may withdraw or update cookie consent at any time. Third-party cookie providers (e.g. Google Analytics) are bound by their own privacy policies, links to which are available upon request.

6. Sharing and Disclosure of Personal Data

We do not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes.

We may share your personal data only in the following limited circumstances:

6.1 Service Providers (Data Processors)

We engage carefully vetted third-party companies to perform services on our behalf. These include:

• Payment processors - mobile money aggregators (MTN MoMo, Airtel Money), card payment gateways, and bank transfer facilitators 

• Delivery and logistics partners - courier and dispatch companies to fulfil and track your orders 

• Cloud hosting and IT infrastructure providers - to store and operate our platform securely 

• Email and communication platforms - for transactional emails, SMS notifications, and (with consent) marketing 

• Analytics providers - to help us understand platform performance and user experience 

• Fraud prevention services - to detect and prevent unauthorised transactions 

All service providers are contractually bound to:

• Process your data only as we instruct 

• Maintain appropriate security measures 

• Not use your data for their own purposes 

• Delete or return your data when the service relationship ends 

6.2 Legal Obligations

We may disclose personal data where required by Ugandan law, a court order, or the lawful request of a government authority or regulatory body - including the Uganda Revenue Authority, Uganda Communications Commission, or law enforcement agencies.

6.3 Business Transfers

If Enjoy Tech Group Ltd undergoes a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the successor entity. We will notify you at least 30 days in advance via email or a prominent site notice, and we will ensure your data remains protected under equivalent or stronger terms.

6.4 Protecting Rights and Safety

We may disclose personal data where necessary to detect, prevent, or address fraud, security breaches, abuse, or violations of our Terms of Service - or to protect the rights, property, or safety of our users, staff, or the public.

6.5 With Your Explicit Consent

For any sharing not described above, we will ask for your explicit, informed consent before disclosure.

7. International Data Transfers

Our primary servers are located in Uganda and/or within hosting jurisdictions with adequate data protection standards (such as the EEA). Where personal data is transferred outside Uganda, we ensure that adequate safeguards are in place, consistent with Part VI of the Data Protection and Privacy Act, 2019, including:

• Contractual protections (standard data transfer clauses) 

• Adequacy decisions or equivalent national standards 

• Binding corporate rules where applicable 

Your data will receive at least the same level of protection outside Uganda as it does within.

8. Data Storage and Retention

We retain personal data only for as long as is necessary for the stated purpose, or as required by applicable Ugandan law.

When personal data is no longer required, we will securely delete or anonymise it so it can no longer be linked to any identifiable individual.

9. Security Measures

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or unlawful disclosure. Our measures include:

• Encryption - all data in transit is protected via TLS/HTTPS encryption; sensitive stored data is encrypted at rest using industry-standard algorithms 

• Access controls - role-based access ensures only authorised personnel can access personal data, on a strict need-to-know basis, with audit logging 

• Password security - user passwords are stored using one-way hashing (e.g. bcrypt) and are never stored in plain text 

• Payment security - payment processing is handled entirely by PCI-DSS-certified third-party processors; we hold no raw card or mobile money credentials 

• System monitoring - our infrastructure is monitored continuously for suspicious activity, anomalies, and known vulnerabilities 

• Employee training - all staff with access to personal data receive training on data protection obligations and handling procedures 

• Incident response plan - we maintain a documented data breach response plan; in the event of a breach likely to result in harm to data subjects, we will notify the Personal Data Protection Office (PDPO) and affected users within the timeframes required by the Act 

No method of internet transmission is 100% secure. While we take all reasonable steps to protect your data, we cannot guarantee absolute security. We encourage you to use a strong, unique password and to notify us immediately if you suspect unauthorised activity on your account.

10. Your Rights as a Data Subject

Under the Data Protection and Privacy Act, Cap. 97 (2019), you have the following rights:

How to Exercise Your Rights

Send a written request to enjoytechgroupltd@gmail.com  with the subject line "Data Rights Request" and a description of your request. We will:

• Acknowledge your request within 5 business days 

• Respond fully within 21 days (or notify you if additional time is required) 

• Verify your identity before processing sensitive requests 

We will not charge a fee for reasonable, first-time requests. For manifestly unfounded, excessive, or repetitive requests, we reserve the right to charge a reasonable administrative fee or to decline the request, with written explanation.

11. Contact Information

Data Controller:

Enjoy Tech Group Ltd

Uganda

Privacy & Data Protection Contact:

📧 enjoytechgroupltd@gmail.com 

🌐 www.enjoytechgroup.com

Personal Data Protection Office of Uganda (PDPO):

If you are dissatisfied with our handling of your personal data or our response to a rights request, you may contact the PDPO:

🌐 www.pdpo.go.ug

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our Services, practices, or legal obligations. When we make material changes, we will:

• Post the updated policy with a revised "Last Updated" date 

• Notify registered users by email at least 14 days before significant changes take effect 

Continued use of our Services after the effective date of any revised policy constitutes your acceptance of the updated terms.

PART B - REFUND POLICY & RETURNS TERMS

13. Overview

At Enjoy Tech Group Ltd, we want you to be fully satisfied with every purchase. This Refund Policy and Returns Terms ("Returns Policy") sets out your rights and our obligations when a product or service does not meet your expectations or arrives in an unsatisfactory condition.

This Policy applies to all purchases made through our websites: www.enjoytechgroup.com and enjoytechgroupltd@gmail.com

This Policy is consistent with Uganda's consumer protection principles and applicable e-commerce best practices.

14. Eligibility for Refunds and Returns

You may be eligible for a refund or return in the following circumstances:

15. Return Window (Timeframes)

All return or refund requests must be initiated within the following timeframes from the date of delivery (or the expected delivery date if goods were not received):

Requests submitted outside these windows will not be accepted, except where required by law or at our sole discretion in exceptional circumstances.

16. Condition of Returned Goods

To qualify for a return, items must be:

• Unused and in their original condition - not worn, washed, assembled, or altered 

• In original packaging - with all tags, labels, accessories, manuals, and inserts intact 

• Accompanied by proof of purchase - your order confirmation number, receipt, or invoice 

• Free from signs of damage caused after delivery 

We reserve the right to refuse a return or adjust the refund amount if the item is returned in a condition that does not meet the above criteria.

17. How to Initiate a Return or Refund Request

Follow these steps to request a return or refund:

Step 1 - Contact Us

Email enjoytechgroupltd@gmail.com or use the "Help" section in your account portal within the return window. Include:

• Your full name and order number 

• A clear description of the issue 

• Photographic evidence (where the item is damaged, defective, or incorrect) 

Step 2 - Receive Authorisation

We will review your request and respond within 2-3 business days with either:

• A Return Merchandise Authorisation (RMA) number and return instructions, or 

• A request for additional information, or 

• A decision declining the request with a clear reason 

Do not send items back without first receiving an RMA number - unauthorised returns may not be processed.

Step 3 - Ship the Item Back

Once authorised:

• Pack the item securely in its original packaging 

• Write your RMA number clearly on the outside of the parcel 

• Ship to the return address provided in your authorisation email 

• Use a trackable shipping method and retain your receipt 

Step 4 - Inspection and Decision

Upon receipt, we will inspect the returned item within 3–5 business days and notify you of our decision by email.

18. Return Shipping Costs

Where we are responsible for return shipping, we will either arrange a courier collection at no cost to you or reimburse reasonable shipping costs upon submission of a receipt (up to a stated maximum, communicated at the time of authorization).

19. Refund Processing

Once your return has been received and inspected:

• Approved refunds will be processed within 7 business days of our inspection decision 

• Refunds will be issued via the original payment method used at checkout: 

Refund timelines reflect our internal processing time. Actual receipt of funds may depend on your bank or mobile money provider's processing schedules.

Refunds will be for the product value paid. Original delivery/shipping charges are non-refundable unless the return is due to our error (wrong, damaged, or defective item).

20. Exchanges

If you would prefer an exchange rather than a refund (e.g. a different size, colour, or replacement unit):

• Follow the return initiation process in Section 17 

• Indicate in your request that you prefer an exchange and specify the desired replacement 

• Exchanges are subject to stock availability 

• If the replacement item is of a higher value, you will be charged the difference; if lower, we will refund the difference 

21. Partial Refunds

We may issue a partial refund in the following circumstances:

• The returned item shows signs of use, wear, or damage not present at the time of delivery 

• Only part of the order is being returned 

• The item is returned without its original accessories, packaging, or documentation 

The partial refund amount will be communicated to you before processing.

22. Non-Returnable & Non-Refundable Items

The following cannot be returned or refunded, except where the item is proven to be defective or materially misdescribed:

• Digital goods, software licences, or downloadable content (once accessed or activated) 

• Gift cards and vouchers (once redeemed) 

• Perishable or consumable goods (food, beverages, health/hygiene products once opened) 

• Customised, personalised, or made-to-order products 

• Items explicitly marked "Final Sale" or "No Returns" at the point of purchase 

• Subscription service fees for periods already consumed 

23. Goods Damaged in Transit

If your order arrives visibly damaged:

1. Do not sign the delivery receipt without noting the damage - write "received damaged" on the courier's paperwork if possible 

2. Take clear photographs of the damaged packaging and item immediately upon receipt 

3. Contact us within 48 hours of delivery at enjoytechgroupltd@gmail.com with your photos and order number 

4. We will arrange either a replacement shipment or a full refund at no additional cost to you 

24. Fraudulent or Abusive Return Claims

We reserve the right to refuse returns or suspend account access where we identify evidence of fraudulent, abusive, or manipulative return behaviour - including, but not limited to:

• Returning an item other than the one delivered 

• Falsely claiming damage or non-delivery 

• Repeated high-volume returns inconsistent with normal consumer behaviour 

Suspected fraud may be reported to the relevant Ugandan authorities in accordance with the Computer Misuse Act, Cap. 96.

25. Dispute Resolution

If you are dissatisfied with our handling of a refund or return request:

1. First contact our Customer Support team at enjoytechgroupltd@gmail.com to escalate the matter for senior review 

2. If unresolved, you may refer the dispute to the Uganda Consumer Protection Unit under the Uganda National Bureau of Standards (UNBS) or relevant regulatory authority 

3. You also retain the right to pursue resolution through competent Ugandan courts 

We are committed to resolving all disputes fairly and promptly.

26. Policy Updates

We may update this Returns Policy from time to time to reflect changes in our operations or legal obligations. Material changes will be communicated via our website and/or by email to registered customers at least 14 days before taking effect.

27. Contact Us

For all privacy, refund, returns, or general enquiries:

Enjoy Tech Group Ltd

Uganda, Kampala

🌐 enjoytechgroupltd@gmail.com | www.enjoytechgroup.com

© 2026 Enjoy Tech Group Ltd. All rights reserved.