The Huru App Privacy Policy

This Privacy Policy applies to your use of the website and its android application (the “App”) and contains policies regarding the collection, use and disclosure of your data and content when you use the App.


The development and pilot testing of Huru website and App is part of a UNODC project with implementing partner Associazione Casa Famiglia Rosetta (ACFR) on improving the capacity of the system of drug use disorders treatment services to provide ethical, evidence-based and humane treatment to persons with drug use disorders in Tanga, Tanzania under the global programme GLOJ71: TreatNet – Treating drug use disorders and its health consequences.

As part of the above-mentioned project ACFR has partnered with a team of the Muhimbili University of Health and Allied Sciences School of Public Health (MUHAS) and the Tanzanian Ministry of Health, Community Development, Gender, Elderly and Children (MoHCDEC).

In general, all rights in this project belong to UNODC. However, when it comes, specifically regarding the Huru App and website, the UNODC is referring to Article VIII on Intellectual Property Rights in the project cooperation agreement between the UNODC and the ACFR, dated on July 26, 2019. Therefore, UNODC agrees that while for the pilot testing ACFR and MUHAS will hold the intellectual property rights of the Huru App and website, ultimately, the MoHCDEC Tanzania is the owner and will grant UNODC the permanent, royalty free, non- exclusive and non-transferable license.



The Huru App is a mobile and web-based application for two target population, people with substance use disorders and service providers working for people with substance use disorders.

As the development of the Huru website and App has just started, this privacy policy document will refer to the different stages of implementation. The Huru website and App will have the exact same components and only differ in the mode of use. While to access the website users will need a PC or laptop, accessing the App is more practical, as any smartphone with Android function will be sufficient. The development of the Huru website will be launched prior to the Huru App to allow any technical improvements before the official launch. The Huru App and website will have two components. One will focus on information sharing (official IEC materials, science-based articles on treatment of substance use disorders, available services for people with substance use disorders, video testimonials of people affected by SUD who successfully participated in treatment) and the other part will be on information collecting.

For the collection of information and data, the MUHAS has successfully obtained Ethical Clearance, dated on December 7, 2020 which will expire on December 6, 2021. Ethical Clearance was obtained to assess the knowledge, attitude, substance use practices and the potential of deploying mHealth intervention among people with drug use disorders in Tanga Municipality and Muheza District. These two locations will also be the only locations focuse on in this App and website, at least for the piloting phase.

Thus, the privacy policy will change as the App and website develops and any changes will not affect data that was collected under a previous version. All parties involved in this project will ensure the protection of data for the target population who are people with substance use disorders.

However, the ultimate aim is to expand to the whole country and include all available services for people with substance use disorders in Tanzania. Therefore, the App and website will be owned by the MoHCDEC to ensure sustainability.

While the App and website provides a unique opportunity of a platform for a vulnerable population like people who are affected by substance use disorders to be heard, there will be no additional services provided other than information sharing. For the time being this platform does not have any capacity of providing actual services (e.g. counselling) to the users but will provide information on available services in Tanga Municipality and Muheza District. Referral will not be explicitly offered to the user, as the user has to individually decide whether they want to receive any treatment. If any modifications substantially change regarding your rights, the developers will provide notice on the App and the website.


Information Collection and Usage

This app targets two types of users’ interfaces: i) people with substance use disorders (SUDs) and ii) healthcare workers.


i)                                                                                                         For the user interface for the people with SUDs: no registration is required, as the App and website serves as an information site and the visit is entirely anonymous. Both interfaces do not collect data regarding IP addresses. For this type of user, the app and website are used to access Information, Education and Communication (IEC) materials on promoting evidence-based drug treatment and care and also enabling them to know where to access services in Tanga Municipality and Muheza District. There will be a table with available evidence-based treatment services visible that offer access to pharmacological and psychosocial treatment for people with substance use disorders. The IEC materials will be promoting positive behaviour among people with SUDs to improve their quality of life.

ii)                                                                                                   For the user interface for the healthcare workers: there is a special interface for this user group which requires registration using any name as user name and phone number for authentication purposes and validation of user actions. The reason of having a separate interface for healthcare workers is to allow them expanding their knowledge in providing evidence-based drug treatment and other related services to people with SUD. This part is related to another component of the project, which belongs to the capacity building part. Part of the information shared for health workers will be the summary points of the Universal Treatment Curriculum (UTC) Basic Modules and Elements of the Rural Treatment Curriculum used in the UTC trainings, as well as testimonials of trainees who are at the same time also service providers. Using this App and website will be entirely voluntary and the users can stop at any time during the page browsing process.

Handling of Personally Identifiable Information (PII)

As used in this Privacy Policy, “Personally Identifiable Information” means any information that may be used to identify an individual, including, postal address, telephone number, fax number and e-mail address among others.

On the website/App there will be a general contact section and in case the user wish to give any personal feedback or submit and inquiries, the user will be asked to provide PII under those circumstances when using the app or website, so that the website/App team can contact the user. The PII will not be shared with any other party and is only to be used by the team to contact the user.


Anonymous Information

In general, the website and App generates “Anonymous Information” means information that is not Personally Identifiable Information. They do not enable identification of an individual user, such as aggregated information about the use of the App and its services or reports that collect information about numerous users without identifying a particular user.

The Huru Team will not share your data or content with anyone without the user’s consent and only to the extent necessary to provide the user with the products and/or services requested. There will be no information collected about the user from other sources outside of the user’s interaction with the App or when the user calls a phone number of services listed on the Website/App.

The content of the messages provided by the users in the general feedback/inquiry section will be reviewed once in a while by the Huru team and will be worked upon. The messages will be stored and these messages will only be accessible to the Huru team.

The Huru team will not sell or otherwise transfer data or content of users to advertising platforms, data brokers, information resellers, or any other third-party organizations.

Additionally, the team will not use user’s data or content for advertising, marketing or similar services.


How The Huru Team uses User’s Information

The Huru team does not collect any Personally Identifiable Information from the user on the App and website unless the user voluntarily chooses to disclose such information in the feedback/inquiry section. At a later stage of the App/website development there may be a chat function (with the team) available that will ask for PII in order to be able to contact the user. In order to improve the quality of the App/website Anonymous Information may be asked by the users in aggregate from to build the quality and more useful services such as by performing statistical analyses of the collective characteristics and behavior of users to personalize their experience on the website/App. However, the team does not foresee this function to be available for the piloting phase.

Anonymous Information may also be provided to affiliated organizations such as ACFR, UNODC and MoHCDEC. There will be a separate terms of reference provided on this data and such data will not be charged by the team. These parties will agree to process such information in compliance with this privacy policy and the Huru Team will limit their use of

such information and to use other appropriate confidentiality and security measures to ensure the protection of the users who will mainly be part of vulnerable populations such as people who are affected by substance use disorders.

The Huru Website/App is not attempting to provide any type of health advice or analysis to users. The Website/App is simply presenting users with information regarding substance use and and available evidence-based treatment centers. Users should not interpret the App’s display of this data as any type of assessment from it. The Huru Website/App is not responsible for any assessment or decision users make based on the data presented in the Website/App or the services of any provider listed on the Website/App.


Data Users Direct the Huru Website/App to Share

The user can direct the team to share data with other parties when providing feedback. This data may then be governed by third-party privacy policy such as Google analytics.

Some options of the App/Website may allow the user to share information with others, such as leaving comments relating to a blog post. Remember that when the user shares information publicly, it may be indexable by search engines. Do not share information that you do not want to be made public.


Cookies and Other Tracking Technologies

Some of the App’s/Website’s pages may utilize “cookies” and other tracking technologies like pixel tags and web beacons to improve the functionality of the App/website. Cookies are text files that are sent by servers to web browsers and stored on your computer.

They tell the team which parts of the Website the user has visited so they can alert the team to software compatibility issues and save the user’s preferences for future visits to the App.

Web beacons and pixel tags are images embedded in a webpage or e-mail for the purpose of measuring and analyzing usage and activity. The Website, or third-party service providers acting on behalf of the Huru App/Website, may use web beacons and pixel tags to help the team analyze usage and improve the App’s/Webiste’s functionality. Some cookies and other technologies may serve to recall PII previously provided by a user.

The user may be offered a browser that has a “Do Not Track” option, which allows the user to signal to operators of websites and web applications and services (including behavioural advertising services) that the user does not wish such operators to track certain online activities over time and across different websites. At this time, the Huru App/Website will not support Do Not Track requests which means that the App/Website will collect

information about the user’s online activity while the user is using the Huru App/Website. The App/Website does not collect online activities after the user leaves the App/Website.

Third-Party Links

The Huru App/Website may contain links to third-party websites. They will be revised and approved by the Huru Team.

The Huru Team wishes to inform users of the App/Website to use third-part links and websites with caution, as this privacy policy does not apply to such websites. Using these links is at the user’s own risk and the Huru Team reminds all users to review the website’s terms of service and privacy policies when visiting such sites. The Huru Team does not

monitor or have any control over and make no claim or representation regarding third-party websites. To the extent such links are provided by the App/Website these do not imply the Huru Team’s endorsement, adoption or sponsorship of, or affiliation with, such third-party websites. When the user leaves the Huru App/Website to use third-party links and websites, the terms of this privacy policy no longer applies.



The privacy and security of user data is important to us. We maintain physical, electronic, and procedural safeguards that are designed to control and protect your data from unauthorized access. We adhere to accepted industry privacy standards. Our used data protection measures include data encryption, strong user authentication, data backup and data erasure.

In addition, The Huru Team uses encryption and a protocol for transmitting private information via the Internet. Unfortunately, no maintenance of data or transmission over a public network such as the Internet can be guaranteed to be secure. Therefore, while the Huru Team follows accepted industry standards and implement reasonable security practices to protect PII, that are in line with European Union’s standard data protection (GDPR), which are commonly used in Tanzania, its absolute security cannot be fully guaranteed, however, as the protection of all Huru App/Website users are of utmost importance, the Huru App will make sure to inform all users once changes are effective.


Changes to This Privacy Policy

As previously mentioned, the Huru App may update the Privacy Policy in line with the developmental stages of the Huru App/Website. In the event of a change, the Huru Team will notify the user when the new privacy policy is available, directly on the App by using a Push Notification function or a pop up function. The Huru Team advises all users to review this Privacy Policy periodically for any changes.


Online Privacy Policy Only

This Privacy Policy applies only to information collected through the Huru App/Website and does not apply to information collected offline through other communication mediums. This policy does not apply to employment-related information, including information received from job applicants.

Google Analytics

Currently the Huru Team is using Google Analytics to understand the Huru App’s/Website’s audience and how to tailor the content of the App/Website to best serve the user’S needs. No Personally Identifiable Information is collected by Google Analytics. Specifically, Google analytics collects data about how the user uses the app/website which are time of visit, pages visited, and the time spent of each page of the webpage.


Consumer Rights based Tanzania Communications Regulatory Authority (TCRA) Electronic and Postal Communication (Consumer Protection) Regulations, 2018 article 6

As a user of Huru App you have the following rights which are as stipulated in the consumer protection regulations in the Tanzania Communications Regulatory Authority (TCRA) Electronic and Postal Communication Regulations:


(a)  fairly and lawfully collected and processed;

(b)  processed for identified purposes;

(c)  accurate;

(d)  processed in accordance with the consumer’s otherrights;

(e)  protected against improper or accidental disclosure; and

(f)  not transferred to any party except as permitted by any terms and conditions agreed with the consumer, as permitted by any permission or approval of the Authority, or as otherwise permitted or required by other applicable laws.


European Union General Data Protection Regulation (EU GDPR) Principles

The following articles of the EU GDPR are used as basis and guidance in developing data handling strategy and privacy polics of the Huru App/Website:


(a)               The right to be informed which will be through the Privacy Policy (Article 12);

(b)             The right to access which will have subject access request form (Article 15);

(c)               The right to rectification (Article 16 and Article 5 (1) (d));

(d)             The right to be forgotten (Article 17);

(e)               The right to restrict processing (Article 18);

(f)                 The right to data portability (Article 20);

(g)             The right to object (Article 21)