Effective date: 14 Feb 2024

Updated: 23 April 2025

Updated: 15 Dec 2025

Last Updated: 29 April 2026

1. Introduction

Welcome to Swavelink.

Startboom Digital (U) Ltd (“us”, “we”, or “our”) operates Swavelink.com (hereinafter referred to as “Service”). Our Privacy Policy governs your visit to Swavelink.com and explains how we collect, safeguard, and disclose information that results from using this Startboom Digital (U) Ltd product Swavelink.com.

We use your data to provide and improve the application. By using the application, you agree to the collection and use of information / Data by The Data Protection and Privacy Act of 2019 of The Republic of Uganda. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of our application and together with the Privacy Policy constitute your agreement with us (“Agreement”).

2. Definitions

SERVICE means the Swavelink.com website/application operated by SwaveLink a product of Startboom Digital (U) Ltd.

PERSONAL DATA means data about a living individual who can be identified from that data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of service or from the Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual or entity using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

4. Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

Email address
First name and last name

III. Phone number

Address, Country, State, Province, ZIP/Postal code, City
Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through any device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Session Cookies: We use Session Cookies to operate our Service.
Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

III. Security Cookies: We use Security Cookies for security purposes.

Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Other Data

While using our Service, we may also collect the following information: sex, age, date of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile) and other data.

5. Use of Data

Swavelink uses the collected data for various purposes:

To provide and maintain our Service;
To notify you about changes to our Service;
To allow you to participate in interactive features of our Service when you choose to do so;
To provide customer support;
To gather analysis or valuable information so that we can improve our Service;
To monitor the usage of our Service;
To detect, prevent and address technical issues;
To fulfill any other purpose for which you provide it;
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
To provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc.;
To provide you with news, special offers and general information about other goods, services and events that we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
In any other way we may describe when you provide the information;
For any other purpose with your consent.

6. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

7. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers outside Uganda where the data protection laws are similar to Uganda.

If you are located outside Uganda and choose to provide information to us, please note that we transfer the data, including Personal Data, to Uganda and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Swavelink will take all the steps reasonably necessary to ensure that your data is treated securely and by this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

8. Disclosure of Data

We may disclose personal information that we collect, or you provide:

8.1. Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

8.2. Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

8.3. Other cases. We may disclose your information also:

8.3.1. To our subsidiaries and affiliates;

8.3.2. To contractors, service providers, and other third parties we use to support our business;

8.3.3. To fulfill the purpose for which you provide it;

8.3.4. For the purpose of including your company’s logo on our website;

8.3.5. For any other purpose disclosed by us when you provide the information;

8.3.6. With your consent in any other cases;

8.3.7. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

9. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

10. Your Data Protection Rights under the Uganda Data Protection & Privacy Act 2019

Users under the age of 16 shall require guidance’s approval to use the application from guardians.
Anyone can ask for their data to be deleted, destroyed, rectified, erased, blocked, stopped processing it, or collected.
All user data will be stored and processed by Swavelink and third parties in Uganda.
We will publish information about data breaches and also provide contact persons for any assistance for those affected.
Data will be collected and stored out of Uganda in the French servers however processed by Swavelink in Uganda.
Data owners will be able to request and download their personal data after verifying their identity by Swavelink.

11. Your Data Protection Rights under the Data Protection and

Privacy Regulations, 2021 (under section 39 of the Data Protection and Privacy Act, 2019, Act 9 of 2019)

Section 39 of the Data Protection and Privacy Act, 2019, Act 9 of 2019 of the Ugandan Constitution requires commercial websites and online services to post a privacy policy. The law requires a person or company in Uganda (and conceivable the world) that operates websites collecting personally identifiable information from consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

According to The Data Protection and Privacy Regulations, 2021 we agree to the following:

0.1. users can request to correct or delete personal data any time.

0.2. Delete personal data that we no longer have the authority to retain.

0.3. our Privacy Policy link includes the word “Privacy”, and can easily be found on the personal profile page of our website/ app;

0.4. users will be notified of any privacy policy changes on our Privacy Policy Page;

0.5. users can change their personal information by emailing us at helpdesk@Swavelink.com, or info@startboomdigital.com.

12. Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at helpdesk@swavelink.com.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you;

2. The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;

The right to object. You have the right to object to our processing of your Data; 4. The right of restriction. You have the right to request that we restrict the processing of your personal information;
The right to data portability. You have the right to be provided with a copy of your Personal

Data in a structured, machine-readable, and commonly used format;

The right to withdraw consent. You also have the right to withdraw your consent at any time when we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests. Please note, that we may not be able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

13. Service Providers

We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

16. Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

17. Behavioral Remarketing

We may use remarketing services to advertise on third-party websites to you after you visit our Service. We and our third-party vendors use cookies to inform, optimize, and serve ads based on your past visits to our Service.

18. Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

19. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third-party’s 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, privacy policies, or practices of any third-party sites or services.

20. Children’s Privacy

Our Services are not intended for use by children under the age of 16 (“Child” or “Children”).

We do not knowingly collect personally identifiable information from children under 16. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

21. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, before the change becomes effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

22. Disclaimer Regarding User-Generated Content

Swavelink is an open platform where users can post content, share information, and engage in trade. While we work diligently to regulate the content shared on our platform, we do not have full control over everything that users post. The content generated by users is their sole responsibility, and we strongly encourage you to report any inappropriate, misleading, or harmful material.

We have a strict policy prohibiting the following types of content, including but not limited to:

Abusive or offensive language, including hate speech, racism, or any form of discrimination.
Misinformation, including false claims designed to deceive or mislead others.
Bullying or harassment of any kind.
Incitement to violence, terrorism, war, or any action that may harm individuals or groups.
Illegal activities include human trafficking, child exploitation, and drug trafficking.
Pornography or sexually explicit content of any kind.
Content promoting self-harm or harm to others.
Any form of content that glorifies or promotes violence, hate, or illegal acts.

E-Commerce Terms and Conditions

These Terms and Conditions (“Terms”) govern your use of the Swavelink e-commerce platform, a service operated and managed by StartBoom Digital Ltd, and apply exclusively to the e-commerce functionality of the Swavelink Application. By using the e-commerce services of Swavelink, you agree to comply with and be bound by these Terms.

Access and Eligibility

1.1. Account Access
Every registered Swavelink account will have access to the shop feature.
1.2. Seller Eligibility
Only Swavelink Pages accounts are authorized to post and sell products. Individual accounts cannot list items for sale directly.

All pages shall be able to post products and services, however for those that want to sell beyond there home country, there products and pages will have to under go a quality assurance and their products shall be tagged with an African symbol, and this will make them visible beyond there home country. Its upon the seller to ensure that they sell quality products.

Listings and Prohibited Items

2.1. Permitted Products
Sellers may only list legal and non-haram (permissible) products.
2.2. Prohibited Products
The sale of haram, illegal, or otherwise prohibited items (including but not limited to narcotics, firearms, counterfeit goods, and other items restricted by law or ethics) is strictly forbidden. Violations will result in permanent suspension and closure of the seller’s page.

Payments and Settlements

3.1. Payment Processing
All e-commerce payments will be processed and settled by StartBoom Digital Ltd.
3.2. Seller Payment Schedule
Payments to sellers will be settled with in (1) weeks and not beyond. Sellers may request settlement by contacting Startboom Digital ltd and submitting a formal payment request and invoice within the designated period, if not the payment will be settled automatically.
3.3. Platform Commission

Swavelink operates on a straightforward model. When users discover products or services through our platform and complete a purchase from a listed merchant, that merchant pays Swavelink a commission on the transaction. A portion of this commission is then returned to users in the form of rewards or cash back.

In practical terms, merchants partner with Swavelink because we drive traffic and sales to their businesses, whether online or physical. Beyond commissions, merchants may also invest in promotional opportunities on the platform to increase visibility, strengthen their brand, and attract new customers. This can include featured listings, targeted campaigns, and in-platform advertising.

The result is a balanced ecosystem: merchants gain access to a wider market and increased sales, while users benefit from savings, rewards, and access to competitive offers across Africa.

Swavelink will retain a 5% commission or more on every listed product sold, calculated after taxes are deducted. This constitutes the platform’s primary revenue from e-commerce.

Logistics and Fulfillment

4.1. Local Deliveries
For transactions within the same country, Startboom Digital shall handle logistics and product delivery.
4.2. Cross-Border Deliveries
For intercontinental transactions (cross-border sales), StartBoom Digital Ltd will manage logistics and product delivery.
4.3. Transport Fares
For products sold outside a seller’s country or locally, Startboom digital transport fees shall be added on the product price and shown clearly on the product before shipping.

Buyer Terms

5.1. Order Placement
Buyers are responsible for ensuring accuracy in the product selection, quantity, and delivery details at the time of checkout.
5.2. Dispute Resolution
If a product is defective, not as described, or not delivered, buyers should raise a dispute through the Swavelink support team within 72 hours of receiving or expecting the product.
5.3. Refund Policy
Refunds will be handled on a case-by-case basis and will depend on the outcome of the dispute investigation.

Seller Terms

6.1. Product Accuracy
Sellers must provide accurate product descriptions, images, and pricing. Misrepresentation may result in account penalties or closure.
6.2. Order Fulfillment
Sellers are required to fulfill orders promptly and communicate clearly with Startboom Digital and deliver products to Startboom Digital’s warehouse for shipping to the clients. Startboom Digital will contact the buyer, communicate delivery timelines, and logistical costs.
6.3. Responsibility for Local Delivery
Sellers are fully responsible for local logistics, including packaging and timely handover to the buyer or local courier service.

Taxation

7.1. Compliance
All sellers are responsible for complying with their local tax laws and must ensure that all required taxes on sales are appropriately declared and remitted.
7.2. Withholding
Swavelink may withhold taxes where legally required and provide appropriate documentation.

Platform Rights and Enforcement

8.1. Monitoring
Swavelink reserves the right to monitor all product listings and transactions to ensure compliance with these Terms.
8.2. Penalties
Violations of any terms, especially regarding prohibited products, may result in the immediate suspension or permanent ban from the platform, including forfeiture of pending settlements.
8.3. Modifications to Terms
StartBoom Digital Ltd reserves the right to amend these Terms at any time. Continued use of the platform implies acceptance of any updated terms.

Limitation of Liability

Swavelink and StartBoom Digital Ltd shall not be liable for:

Delays or failures caused by third-party delivery services
Disputes between buyer and seller were not reported within the dispute window
Any loss incurred due to user error or negligence

Governing Law

These Terms shall be governed by and construed by the laws of the Republic of Uganda, without regard to its conflict of law principles.

By using Swavelink’s e-commerce services, you acknowledge that you have read, understood, and agree to be bound by these Terms and Conditions.

By using Swavelink, you agree to comply with these guidelines. Any violation of these policies may result in removing content, account suspension, or legal action when necessary. Our goal is to maintain a safe, respectful, and positive community, and we rely on users to report any content that breaches these guidelines.

SWAVELINK REFUND, CANCELLATION AND TRANSACTION PROTECTION POLICY

PURPOSE

This Refund, Cancellation and Transaction Protection Policy governs all purchases, sales, payments, subscriptions, bookings, service engagements, digital transactions, transfers, and commercial activities conducted through Swavelink.

The purpose of this Policy is to:

Establish clear refund and cancellation procedures.
Protect buyers and sellers.
Promote trust and transparency.
Limit financial risks and liability exposure.
Provide a fair dispute resolution process.
Ensure compliance with applicable laws and payment industry standards.

By using Swavelink, all users agree to be bound by this Policy.

NATURE OF THE PLATFORM

Swavelink is primarily a technology platform that facilitates connections and transactions between users.

Except where expressly stated otherwise, Swavelink:

Is not the buyer.
Is not the seller.
Does not manufacture products.
Does not own inventory listed by users.
Is not responsible for the quality, legality, authenticity, safety, delivery, or suitability of products or services offered by third parties.

Swavelink acts solely as an intermediary marketplace and transaction facilitation platform.

GENERAL REFUND PRINCIPLES

Refund eligibility depends on:

Product category
Service category
Delivery status
Transaction status
Applicable laws
Evidence submitted by parties

Refunds are not automatic and may be subject to review.

Swavelink reserves the right to investigate all refund requests before making a determination.

ELIGIBLE REFUND CIRCUMSTANCES

A refund may be approved where:

Non-Delivery

The purchased item or service was not delivered within the agreed period.

Incorrect Item

The item received materially differs from the item purchased.

Damaged Goods

Products arrive damaged due to shipping or handling.

Duplicate Charges

A user is charged multiple times for the same transaction.

Unauthorized Transactions

A transaction is proven to have occurred without authorization.

Technical Processing Errors

Payment system failures result in incorrect deductions.

Seller Non-Performance

The seller fails to fulfill contractual obligations.

NON-REFUNDABLE TRANSACTIONS

Unless required by law, the following are generally non-refundable:

Digital Products

Audio downloads
E-books
Digital licenses
Online courses
Digital memberships
Downloadable content

Completed Services

Consulting
Professional services
Advertising services
Marketing services
Design services
Development services

Subscription Fees Already Consumed

Subscription periods already utilized are non-refundable.

User Error

Refunds may not be granted where:

Incorrect payment information was provided.
Wrong recipient details were entered.
User negligence caused the loss.

ORDER CANCELLATION POLICY

Before Acceptance

Orders may generally be cancelled without penalty before acceptance by the seller.

After Acceptance

Once accepted by the seller, cancellation may be subject to:

Seller approval
Restocking fees
Processing fees
Shipping costs already incurred

During Shipment

Orders already dispatched may not be cancellable but may qualify for return procedures.

SERVICE CANCELLATION POLICY

For service bookings:

More Than 48 Hours Before Service

Full refund may be available.

24–48 Hours Before Service

Partial refund may be available.

Less Than 24 Hours Before Service

Refund may be denied unless exceptional circumstances exist.

SUBSCRIPTION CANCELLATION POLICY

Users may cancel subscriptions at any time.

Cancellation prevents future billing.

Unless otherwise stated:

Current billing periods remain active.
No partial refunds are issued for unused portions of a billing cycle.

PAYMENT REVERSALS AND CHARGEBACKS

Users are encouraged to contact Swavelink before initiating chargebacks.

Fraudulent chargebacks may result in:

Account suspension
Account termination
Recovery proceedings
Legal action

Swavelink reserves the right to provide transaction records to financial institutions during chargeback investigations.

DISPUTE RESOLUTION PROCESS

Where disputes arise:

Step 1: Direct Resolution

Buyer and seller should first attempt resolution directly.

Step 2: Swavelink Mediation

If unresolved, Swavelink may review:

Transaction records
Communications
Delivery evidence
Payment records
Supporting documentation

Step 3: Determination

Swavelink may:

Release funds
Hold funds
Issue refunds
Reject claims

The platform’s determination shall be based on available evidence.

ESCROW AND HELD PAYMENTS

For designated transactions, Swavelink may hold funds temporarily.

Funds may be released when:

Delivery is confirmed.
Service completion is verified.
Dispute periods expire.

Swavelink reserves sole discretion regarding escrow release procedures.

TRANSACTION DATA AND RECORD RETENTION

Swavelink maintains commercially reasonable security measures to protect transaction data.

However:

Users are responsible for maintaining their own transaction records.
Users should download receipts and confirmations when provided.
Users should maintain backups of important records.

While Swavelink strives to preserve transaction information, uninterrupted retention cannot be guaranteed indefinitely.

Accordingly:

StartBoom Digital Ltd and Swavelink shall not be liable for losses arising from:

User deletion of records.
Device loss or damage.
Email loss.
Third-party service failures.
Expired retention periods.
Events beyond reasonable control.

CYBER SECURITY AND SECURITY DISCLAIMER

Swavelink employs industry-standard safeguards including:

Encryption technologies
Authentication controls
Fraud detection systems
Secure payment integrations
Access monitoring mechanisms

However, no digital system can guarantee absolute security.

To the fullest extent permitted by law:

Swavelink does not warrant that:

The platform will be free from cyber attacks.
Data transmission will be completely secure.
Unauthorized access can never occur.

Users agree to use the platform at their own risk while following recommended security practices.

FRAUD PREVENTION

Swavelink reserves the right to:

Delay transactions.
Request identity verification.
Suspend suspicious accounts.
Freeze disputed transactions.
Report fraudulent activities to authorities.

Any attempt to manipulate the refund process may result in permanent account termination.

FORCE MAJEURE

Swavelink shall not be liable for delays, failures, losses, interruptions, or refund obligations resulting from events beyond its reasonable control, including:

Natural disasters
Government actions
Internet outages
Telecommunications failures
Payment processor disruptions
Cyber incidents
Civil unrest
War
Epidemics or pandemics

LIMITATION OF LIABILITY

To the maximum extent permitted by law:

StartBoom Digital Ltd, Swavelink, its officers, directors, employees, affiliates, agents, and partners shall not be liable for:

Indirect losses
Consequential losses
Lost profits
Lost opportunities
Reputational damage
Data loss
Third-party misconduct
Seller defaults
Buyer misconduct

Any liability of Swavelink shall be limited to the amount of fees paid to Swavelink in connection with the disputed transaction.

POLICY AMENDMENTS

Swavelink reserves the right to amend this Policy at any time.

Updated versions shall become effective upon publication on the platform.

Continued use of the platform constitutes acceptance of revised terms.

CONTACT

Refund and dispute requests may be submitted through official Swavelink customer support channels.

Users are encouraged to provide complete documentation to facilitate timely review and resolution.

Email: helpdesk@swavelink.com or call +256703123180

23.Anti–Money Laundering (AML) and Counter‑Terrorism Financing (CTF) Policy
Applies to: All Swavelink users, partners, merchants, agents, and service providers

Purpose of This Policy

This Anti–Money Laundering and Counter‑Terrorism Financing Policy establishes mandatory rules and controls to prevent Swavelink from being used for money laundering, terrorist financing, fraud, sanctions evasion, or any other financial crime.

This policy is designed to:

Protect StartBoom Digital Ltd, its directors, employees, and partners from legal, regulatory, and reputational risk.
Ensure compliance with applicable Ugandan laws, regional regulations, and internationally accepted AML/CTF standards.
Set clear, enforceable obligations for all Swavelink users and businesses.

Compliance with this policy is a strict condition for accessing or using Swavelink.

Scope and Legal Standing

This policy applies to:

All individual users
All business accounts
Merchants, traders, logistics partners, payment partners, and agents
All transactions conducted on or facilitated through Swavelink

By registering, accessing, or using Swavelink, users legally acknowledge, accept, and agree to comply with this policy in full.

StartBoom Digital reserves the unrestricted right to update, amend, or enforce this policy at any time without prior notice.

Zero‑Tolerance Position

StartBoom Digital maintains a zero‑tolerance policy toward:

Money laundering
Terrorist financing
Fraud and financial deception
Trade‑based money laundering
Sanctions violations
False identity or misrepresentation

Any suspected or confirmed violation will result in immediate enforcement action, without an obligation to provide a warning, explanation, or an opportunity to cure.

User Identification and Verification (KYC)

4.1 Mandatory Identity Verification

All users must successfully complete identity verification before accessing transactional features.

Individual users must provide:

Valid government‑issued identification
Accurate personal information
Proof of address or location when requested

Business users must provide:

Legal business registration documents
Ownership and control information
Identification of directors and beneficial owners
Tax identification where applicable

Failure to provide accurate or verifiable information will result in denial, suspension, or termination of access.

4.2 Beneficial Ownership

Swavelink strictly prohibits anonymous or undisclosed beneficial ownership. Any attempt to conceal the true owner or controller of an account constitutes a material violation.

Prohibited Activities

The following activities are strictly prohibited:

Use of Swavelink for illegal trade or prohibited goods
Structuring transactions to avoid reporting thresholds
Use of false, misleading, or third‑party identities
Acting as a nominee, proxy, or front for another party
Trade misinvoicing or over/under‑valuation of goods
Use of Swavelink to move funds unrelated to legitimate trade
Transactions involving sanctioned individuals, entities, or regions

Any involvement, direct or indirect, constitutes grounds for immediate enforcement.

Transaction Monitoring and Controls

StartBoom Digital employs automated and manual monitoring systems to:

Review transaction behavior
Detect unusual, suspicious, or high‑risk activity
Identify patterns inconsistent with stated business purpose

StartBoom Digital may:

Delay, block, reverse, or freeze transactions
Place accounts under review without notice
Request additional documentation at any time

Users have no entitlement to uninterrupted service or transaction completion.

High‑Risk and Enhanced Due Diligence

Enhanced Due Diligence (EDD) applies to:

High‑value or high‑frequency traders
Cross‑border transactions in high‑risk regions
Politically Exposed Persons (PEPs)
New or unusual trade patterns

EDD may include:

Source of funds verification
Trade documentation review
Ongoing account scrutiny

Failure to cooperate results in immediate restriction or termination.

Reporting and Disclosure

StartBoom Digital reserves the right to:

Report any transaction or user to regulators, law enforcement, or financial intelligence authorities
Share user data where legally required or deemed necessary to protect the platform

Users expressly waive any claim against StartBoom Digital arising from such disclosures.

Account Suspension, Termination, and Asset Freezing

StartBoom Digital may, at its sole discretion:

Suspend or terminate accounts
Freeze balances or pending transactions
Withhold funds pending investigation

These actions may be taken without notice and without liability to the user.

Termination does not release users from legal or financial obligations.

Limitation of Liability and Legal Protection

To the maximum extent permitted by law:

StartBoom Digital is not liable for losses arising from AML enforcement actions
Users bear full responsibility for the legality of their activities
StartBoom Digital does not guarantee transaction approval, continuity, or completion

Users agree to indemnify and hold harmless StartBoom Digital, its officers, employees, and partners from any claims, losses, penalties, or damages arising from user misconduct or policy violations.

Record Keeping

StartBoom Digital retains:

User identification records
Transaction data
Investigation and compliance records

Records may be retained beyond account closure where legally or operationally required.

Cooperation Obligation

Users must fully cooperate with:

Compliance reviews
Requests for information
Investigations by StartBoom Digital or authorities

Non‑cooperation constitutes a material breach of this policy.

Policy Supremacy

This AML & CTF Policy supersedes any conflicting user understanding, representation, or expectation.

Continued use of Swavelink constitutes ongoing acceptance.

14. SWAVELINK COPYRIGHT POLICY, DMCA FRAMEWORK & USER GUIDELINES

1. INTRODUCTION

Swavelink, a digital trade and social platform developed by StartBoom Digital Ltd, is committed to protecting intellectual property rights while enabling innovation and content sharing across Africa.

This policy establishes:

Copyright compliance standards
Content moderation and enforcement systems
Legal protections for the platform
User responsibilities

It aligns with:

The Berne Convention for the Protection of Literary and Artistic Works
The WIPO Copyright Treaty
Uganda’s Copyright and Neighbouring Rights Act, 2006 (Cap 222) and 2025/2026 amendments

2. LEGAL FOUNDATION

2.1 International Framework

Under global copyright law:

Copyright protection is automatic upon creation
Owners have exclusive rights to:
- reproduce
- distribute
- perform
- communicate to the public

There is no minimum duration of use that is automatically allowed without permission.

2.2 Ugandan Copyright Law

Copyright protects literary, musical, audiovisual, and artistic works
Protection applies once a work is original and fixed in material form
Authors hold:
- Economic rights (use, distribution, reproduction)
- Moral rights (authorship and integrity)

The law also recognizes:

Neighbouring rights for performers, producers, and broadcasters

Recent reforms (2026):

Introduce stronger digital enforcement mechanisms
Increase penalties up to:
- UGX 50 million fines
- Up to 10 years imprisonment

2.3 Fair Use / Fair Dealing (Uganda)

Section 15 of the Act allows limited use for:

Research
Private use
Library/archive purposes

Important:

This is not automatic protection for users
It is interpreted case-by-case

3. PLATFORM COPYRIGHT POLICY

3.1 Core Rule

Users may only upload, share, or distribute content if they:

Own the rights
Have a valid license
Use content in compliance with applicable copyright exceptions

3.2 Prohibited Content

Users may NOT upload:

Copyrighted music, videos, or media without authorization
Full or partial songs, including short clips
Content intended to replicate or substitute original works
Pirated or leaked content

3.3 No “Safe Length” Rule

Swavelink does not recognize any minimum duration (e.g., 5–30 seconds) as safe.

Even short clips:

May be infringing
May trigger enforcement action

3.4 Permitted Content Categories

Allowed uploads include:

Original content created by the user
Licensed or royalty-free content
Public domain works
Content covered under valid legal exceptions

4. DMCA-STYLE NOTICE AND TAKEDOWN FRAMEWORK

Swavelink adopts a DMCA-inspired compliance model, adapted for global and Ugandan enforcement.

4.1 Notice of Infringement

Rights holders may submit a notice including:

Identification of copyrighted work
Location of infringing content
Proof of ownership
Contact details

4.2 Takedown Procedure

Upon valid notice:

Content is promptly removed or disabled
User is notified
Record is logged for compliance

4.3 Counter-Notification

Users may dispute claims by providing:

Evidence of ownership or license
Legal justification (e.g., fair use)

Swavelink may restore content if justified.

4.4 Repeat Infringer Policy

Accounts with repeated violations may be:
- Suspended
- Permanently banned

4.5 Safe Harbour Protection

This framework is designed to protect Swavelink from liability as an intermediary platform, provided it:

Acts on notices
Does not knowingly facilitate infringement

5. CONTENT MONITORING & TECHNOLOGY

To align with global standards (e.g., YouTube Content ID), Swavelink will implement:

5.1 Automated Detection

Audio fingerprinting
AI-based content recognition

5.2 Rights Management Options

Blocking infringing content
Monetization sharing (future feature)
Usage tracking

6. LICENSING STRATEGY (INVESTOR NOTE)

To reduce legal exposure and unlock revenue:

Swavelink may:

Partner with music licensing bodies
Integrate licensed music libraries
Work with African collective management organizations

This enables:

Legal music usage
Monetization opportunities
Creator compensation

7. USER GUIDELINES (PLAIN LANGUAGE)

Users must:

Only post content they have rights to
Avoid uploading music, movies, or clips they do not own
Respect artists, creators, and businesses

Users should understand:

Even a few seconds of a song can be illegal
“Everyone else is using it” is not a defense
Violations may lead to account removal

8. ENFORCEMENT & PENALTIES

Swavelink enforces:

Content removal
Account suspension
Legal cooperation with authorities

Under Ugandan law, infringement may lead to:

Fines
Imprisonment
Civil damages

9. COMPLIANCE & GOVERNANCE STRUCTURE

Swavelink will maintain:

A dedicated Copyright Compliance Officer
Legal partnerships for IP enforcement
Regular policy updates aligned with law reforms

10. INVESTOR ASSURANCE

This framework ensures:

Reduced legal risk
Scalable compliance across jurisdictions
Alignment with global platform standards
Readiness for partnerships with content owners

It positions Swavelink as:

A compliant digital marketplace
A responsible content platform
A scalable African tech infrastructure

11. CONCLUSION

Swavelink adopts a strict rights-based model, not a time-based model, ensuring:

Legal clarity
Platform protection
Creator respect

15. Governing Law

This policy is governed by the laws of the Republic of Uganda. Any dispute shall be subject to the exclusive jurisdiction of the Ugandan courts.

Issued by:
StartBoom Digital Ltd
Operator of Swavelink Platform

Contact Us

For concerns or reports regarding inappropriate content, please contact us at helpdesk@swavelink.com, or call +256763080035

If you have any questions about this Privacy Policy, please contact us by emailing: helpdesk@swavelink.com.