Privacy notice

Effective date: to be confirmed

Pearl helps people discover, understand, plan and experience Uganda. This policy explains what information Pearl keeps about you, why, who else sees it, and what you can do about it.

The short version

• You can explore, ask and plan without an account. Pearl still keeps your work under a guest session so it isn't lost.
• Pearl asks for the least it needs. It never asks for your passport, home address, payment details or medical information. Nationality, visit experience and trip preferences, including a total budget target, are optional.
• When you send an enquiry, Pearl passes your details to the supplier you chose only after you agree. The supplier then contacts you outside Pearl.
• Questions you ask Pearl are sent to an AI provider to produce an answer. Don't put private or sensitive information in them.
• Pearl uses analytics only if you allow it, and you can change your mind at any time. Pearl does not record your sessions and does not sell your information.

Who is responsible for your information

Pearl is a project of Victoria University, Kampala. The data controller for Pearl is to be confirmed, to be confirmed.

For any privacy question or request, contact to be confirmed. to be confirmed

What Pearl keeps and why

When you use Pearl as a guest

The first time you open Pearl, it creates a guest session for you. This guest session has a random identifier and no name or email. It lets Pearl keep your trips, Saved list, Ask Pearl conversations and enquiries before you sign in.

Pearl also stores a random secret in your browser. If you later sign in or create an account, Pearl uses that secret to move your guest work into your account, so nothing is lost.

If you clear your browser storage before signing in, Pearl can no longer link you to your guest work.

When you create an account or sign in

You can sign in with Google, with an email address and password, or with a passkey. Depending on the method, Pearl keeps:

• your name and email address;
• your profile picture, if you sign in with Google;
• a securely hashed version of your password (Pearl never stores the password itself);
• the public part of any passkey you register (the private part never leaves your device);
• your two-factor settings, if you turn two-factor authentication on.

Pearl uses this to sign you in, keep your account secure, and show you your own work.

Your trips and Saved list

Pearl keeps what you put into a trip: its title, its dates or length, the places and events you add, the days you put them on, times you set, and any notes you write. It also keeps your Saved list. If you choose, Pearl also saves your traveller count, interests and total budget target in USD as private trip preferences. The target is your requested amount, not a cost estimate or quotation.

Trips and notes are private to you. Pearl staff cannot open your trips. When you remove something from a trip, Pearl keeps it for 7 days so you can undo, then deletes it.

Sharing a trip

If you are signed in, you can create a read-only link to a trip. Anyone who has the link can see the trip's title, timing, days, Trip ideas, places, times and map. They cannot see your notes, planning preferences (including your traveller count, interests and budget target), your enquiries, your contact details or your Ask Pearl conversations. You can revoke the link or replace it with a new one at any time.

Ask Pearl

When you ask Pearl a question, Pearl keeps the question, the answer, and the place or trip you were asking about, so you can see the conversation again later.

To answer, Pearl sends your question, earlier messages in the same conversation, and relevant passages from Pearl's reviewed listings to an AI service provider (see "Who else handles your information"). If you ask from a trip, Pearl also sends the current trip title, timing, destinations, places, day assignments and any planning preferences you supplied, including traveller count, interests and total budget target, so it can answer in context and make changes. Private trip notes and checklists are not included. When you explicitly ask Pearl to plan or adjust a trip, it applies its supported changes immediately. The change card offers Undo until the trip changes again.

Please keep in mind:

• Pearl's answers are produced by AI and can be wrong. Check important details before you rely on them.
• Do not include sensitive information in your questions, such as health details, identity or passport numbers, payment details, or other people's personal information.
• Pearl staff cannot read your Ask Pearl conversations through Pearl's staff tools.

Enquiries to suppliers

When you send an enquiry to an accommodation provider, guide or tour company, Pearl asks for:

• your name;
• one way to contact you (email, phone or WhatsApp) and the address or number;
• what you need help with;
• your travel timing, or "Timing undecided";
• your party size, or "Not confirmed";
• if you choose, a short excerpt of a trip: its title, its timing, and only the places you tick, with their kind and day. Nothing is ticked by default. Your notes, times, planning preferences (including the budget target), the rest of the trip, your Saved list and your Ask Pearl conversations are never included in the excerpt. Trip preferences are not automatically copied into enquiry fields; you choose the enquiry content before sending.

Before you send, Pearl shows you exactly what will be shared and asks for your consent. Pearl records when you gave it.

What happens next:

1. Your enquiry goes to Pearl's team first. Pearl staff review it and check that the supplier is who they say they are, has a working contact channel and has agreed to receive enquiries.
2. Pearl staff then pass your enquiry to that supplier by email or WhatsApp. Pearl does not send your enquiry to a different supplier unless you approve it.
3. The supplier contacts you directly, outside Pearl. From that point, the supplier handles your information under its own privacy practices. Pearl does not control what the supplier does with it.

Pearl also keeps a history of your enquiry's status, any messages Pearl staff send you about it, and any replies you send back.

Pearl is not part of any booking. An enquiry is not a booking. Pearl does not take payments, quote prices or confirm availability.

Your private status link. After you send an enquiry, Pearl gives you a private link where you can follow its status. Anyone who has this link can see the enquiry, including your contact details. Keep it private, as you would a password. Pearl stores only a scrambled (hashed) form of the link, keeps the page out of search engines, and removes the link from its analytics. Pearl does not send status updates by email or text message.

To protect its team and suppliers from spam, Pearl limits how many enquiries one person can send in a day.

Usage and technical information

Pearl uses PostHog, an analytics service hosted in the European Union, to understand how people use the app and to find errors. PostHog only runs if you choose Allow in Pearl's analytics banner. If you decline, or make no choice, Pearl sends nothing to PostHog and works exactly the same. You can change your choice at any time from "Cookie and analytics settings" at the bottom of every page.

If you allow analytics, PostHog collects:

• the pages you visit and the actions you take, such as opening a listing or adding it to a trip;
• your browser, device type, screen size and approximate location (worked out from your IP address);
• technical details of errors you run into.

Pearl does not record your sessions (no session replay). Enquiry status links are removed from analytics, and enquiry contact details are excluded.

While you are a guest, PostHog sees only a random identifier. If you sign in, Pearl links your analytics to your account using only Pearl's internal account number. Pearl never sends your name or email address to PostHog.

Maps

Pearl shows maps from Mapbox. When a map loads, your browser contacts Mapbox, which receives your IP address and the area of the map you are viewing. Pearl works out driving times between places on its own servers using Mapbox, and sends only the locations of the listed places, not your location.

If you choose "Open in Google Maps", you leave Pearl and Google's own privacy policy applies.

What Pearl never asks for

Pearl does not ask for your passport or ID details, home address, payment or card details, or medical or health information. Pearl does not track your device's location.

If you type something like this into a free-text box, such as an enquiry or a question to Pearl, Pearl will store it as part of that message. Please don't.

Why Pearl is allowed to use your information

Pearl uses your information:

• to provide what you asked for, such as keeping your trips, answering your questions and handling your enquiries;
• with your consent, such as sharing your enquiry with the supplier you chose. You can withdraw consent before your enquiry is sent to the supplier by contacting Pearl. Withdrawing does not undo a share that has already happened;
• to keep Pearl safe and working, such as preventing spam enquiries, securing accounts and fixing errors;
• to improve Pearl, through analytics, only with your consent. You can withdraw it at any time from "Cookie and analytics settings".
• where the law requires it.

Who else handles your information

Pearl does not sell your personal information or share it for advertising.

Pearl staff. Only authorised staff can see an enquiry, the contact details in it and the trip excerpt you chose to attach. Staff tools do not give access to your private trips or Ask Pearl conversations. Staff accounts must use two-factor authentication, and staff actions on enquiries and listings are recorded in an audit log.

The supplier you chose, as described above, and only with your consent.

Service providers that run parts of Pearl on our behalf:

Authorities, if Ugandan law or a valid legal order requires it, or to protect someone's safety.

A successor, if Pearl's operation moves to another organisation. Pearl would tell you first.

Information sent outside Uganda

Most of Pearl's service providers are based outside Uganda, so your information is stored and processed in other countries, mainly the United States and, for analytics, the European Union. Pearl uses providers that commit to protecting personal data, and relies on to be confirmed as required by section 19 of the Data Protection and Privacy Act, 2019.

How long Pearl keeps your information

Once an enquiry is passed to a supplier, the supplier keeps its own copy under its own practices.

Cookies and browser storage

Pearl stores a small amount of information in your browser:

• a sign-in session, so you stay signed in (needed for Pearl to work);
• the guest secret described above (needed to keep guest work);
• an unfinished enquiry, so a reload doesn't lose what you typed. This is cleared when you close the tab;
• your analytics choice, so Pearl doesn't ask again;
• PostHog's identifier for analytics, only if you allow analytics;
• small display preferences.

Mapbox may also store information in your browser when maps load.

The first time you visit, Pearl asks whether it may use analytics. Allow and Decline are equally easy, and nothing analytics-related is stored or sent until you allow it. You can change your choice at any time from "Cookie and analytics settings" at the bottom of every page.

Your rights

Under Uganda's Data Protection and Privacy Act, 2019, you have the right to:

• ask what information Pearl holds about you and get a copy;
• ask Pearl to correct information that is wrong, incomplete or out of date;
• ask Pearl to delete your information, where Pearl no longer has a lawful reason to keep it;
• object to or ask Pearl to stop using your information, including for analytics (you can turn analytics off yourself from "Cookie and analytics settings");
• withdraw your consent where Pearl relies on it.

To use any of these rights, email to be confirmed from the address on your account, or include your enquiry status link if you were a guest. Pearl may ask you to confirm your identity. Pearl will reply within to be confirmed.

Pearl does not yet offer self-service account deletion or data download. Pearl handles these requests by email.

If you are unhappy with how Pearl has handled your information, you can complain to the Personal Data Protection Office in Uganda (pdpo.go.ug). We would appreciate the chance to fix it first.

If you are in the European Union or United Kingdom

If you use Pearl from the EU or UK, the GDPR or UK GDPR may also apply. You then have the rights above plus the right to data portability and to restrict processing. Pearl relies on performing the service you asked for, your consent, and legitimate interests (keeping Pearl secure and improving it). You can also complain to your local data protection authority. to be confirmed

Children

Pearl is meant for adults planning travel. You must be to be confirmed or older to create an account or send an enquiry. Pearl does not knowingly collect information from children. If you believe a child has given Pearl their information, contact us and we will delete it.

Security

Pearl protects your information with encrypted connections, hashed passwords and links, and strict staff access controls with two-factor authentication. Staff cannot open private trips or Ask Pearl conversations. No system is perfectly secure, so please keep your password, passkeys and enquiry status links safe.

If a breach puts your information at risk, Pearl will notify the Personal Data Protection Office and, where required, you.

Changes to this policy

Pearl will update this policy when its features or practices change. The date at the top shows the latest version. If a change significantly affects how your information is used, Pearl will tell you in the app before it takes effect.

Contact

to be confirmed to be confirmed to be confirmed

Optional traveller profile

During onboarding, you may provide your nationality and whether this is your first visit to Uganda, a return visit, or you live in Uganda. These details are stored in your private account profile. You can skip these questions and later change or remove your answers in Account settings. They are not included automatically in shared itineraries or enquiries.