Privacy policy (Rwanda — draft)
Pending legal review — draft
This page is a working draft for Broadway Creation Ltd. It has not been signed off by Rwanda counsel. Align with Law N° 058/2021 (personal data protection) before treating it as a production policy.
1. Company
This draft describes how Broadway Creation Ltd (“Broadway”, “we”) processes personal data when you use Broadway Property Management at broadwaycreation.rw.
- Operator: Broadway Creation Ltd
- Place of business: Kigali, Rwanda
- Privacy / deletion requests: support@broadwaycreation.rw
A named data protection officer (DPO) contact will be published here after legal review. Until then, use the support address above.
2. Data types we process
Depending on your role (landlord, staff, tenant, or visitor), we may process:
- Account data: name, email, phone, role, workspace membership
- Property records: addresses, Unique Parcel Identifier (UPI), unit and occupancy details
- Lease and contract files, versions, and related workflow status
- Invoices, payment proofs (including MoMo / bank screenshots or pasted messages), and payment status
- Tax obligation notes you enter for Rwanda Revenue Authority (RRA) preparation — not filings
- Support messages and audit-trail events (who viewed, uploaded, or changed a record)
- Technical logs reasonably needed to operate and secure the service
3. Why we process this data
We process data to provide the software: property and tenant records, invoicing, payment-proof review, reminders, and workspace administration. We do not sell personal data. Hosting is in the region configured for your deployment (production is intended for Rwanda infrastructure unless a contract says otherwise).
4. Retention
We keep account and property records for as long as the workspace is active. After an account is closed, we retain data only as needed for legal, tax, dispute, or security obligations, then delete or anonymise it. Payment proofs and invoices may be kept longer where they support rent or tax records you asked us to store. Exact retention periods will be confirmed after legal review.
5. Rwanda Revenue Authority (RRA) disclaimer
Tax figures, VAT helpers, and obligation registers in the product are operational trackers only. They are not RRA filings, assessments, or official receipts. Rates, deadlines, and liabilities are determined by RRA and applicable law. You remain responsible for filing and paying tax through official RRA channels (including EBM / e-invoicing where required).
6. Your rights and deletion requests
Subject to Law N° 058/2021 and any records we must keep for active leases, invoices, or legal duty, you may request access, correction, export, or deletion of personal data we hold about you.
Email support@broadwaycreation.rw with the subject line “Data deletion request”, the email on the account, and whether you want export, correction, or deletion. We may need to verify identity. Workspace owners can also ask us to close a landlord account; tenant users should usually start with their landlord, then contact us if needed.
7. Sharing
We share data with processors who host or send email/SMS/WhatsApp on our behalf, and with payment providers when you start a card checkout. We do not publish tenant or landlord contact details on public listing pages. Public invoice links show only recipient-facing invoice fields (amounts, lines, status, and pay instructions).
Draft for pending legal review. See also terms of service and contact.
