Last Updated: 7 May 2025

This Privacy & Cookies Policy (“Policy”) describes how Bugesera Special Economic Zone Ltd (“BSEZ”, “we”, “our”, or “us”) collects, uses, discloses, and protects your Personal Data when you interact with our website, services, and platforms (collectively, the “Services”).

This Policy has been prepared in accordance with Law No. 058/2021 of 13/10/2021 Relating to the Protection of Personal Data and Privacy in the Republic of Rwanda (the “Rwandan Data Protection Law”).

By accessing or using our Services, you acknowledge that you have read and understood this Policy and agree to the collection and use of your Personal Data in accordance with this Policy.

1. Definitions

Unless otherwise defined in this Policy, the terms used herein shall have the same meaning as set forth in the Rwandan Data Protection Law.

1. Personal Data means any information relating to an identified or identifiable natural person.
2. Data Subject means the individual to whom the Personal Data relates.
3. Data Controller means the natural or legal person who determines the purposes and means of the processing of Personal Data.
4. Data Processor means any person who processes Personal Data on behalf of the Data Controller.
5. Processing means any operation performed on Personal Data, whether or not by automated means.

2. Legal Basis for Processing

We process your Personal Data in accordance with the legal basis provided under the Rwandan Data Protection Law:

1. Consent: When you explicitly consent to the processing of your data (e.g., when subscribing to newsletters).
2. Contractual Necessity: When processing is necessary for the performance of a contract to which you are party.
3. Legal Obligation: When required to comply with legal or regulatory obligations.
4. Legitimate Interest: When processing is necessary for our legitimate interests, provided such interests do not override your rights and freedoms.
5. Vital Interests or Public Interest: When processing is necessary to protect your vital interests or to perform a task carried out in the public interest.

3. Personal Data We Collect

We may collect the following categories of Personal Data:

1. Identification Data: name, email address, telephone number, national ID or passport number.
2. Contact Information: physical address, business address.
3. Usage Data: IP address, browser type and version, pages visited, time spent, clickstream data.
4. Technical Data: device information, operating system, network data.
5. Cookies and Tracking Data: cookies, web beacons, tracking pixels.

4. Use of Personal Data

We use your Personal Data for the following purposes:

1. To operate and maintain our website and services.
2. To communicate with you, including for marketing and customer support.
3. To fulfill contractual or legal obligations.
4. To improve our website, services, and user experience.
5. To ensure information security and prevent fraud.

5. Sharing and Disclosure of Personal Data

We may share your Personal Data:

1. With our affiliated companies and service providers for the purposes described in this Policy.
2. With regulatory or government authorities as required by law.
3. With third parties with your consent.
4. In connection with business transfers, such as mergers or acquisitions, provided adequate safeguards are in place.

6. International Data Transfers

Where we transfer Personal Data outside Rwanda, we ensure appropriate safeguards are in place, including:

1. The recipient country has adequate data protection legislation.
2. Standard contractual clauses are in place.
3. You have explicitly consented to the transfer.

7. Data Retention

We retain your Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by applicable laws.

8. Your Rights as a Data Subject

Under the Rwandan Data Protection Law, you have the right to:

1. Access your Personal Data.
2. Request correction or erasure of inaccurate or incomplete data.
3. Withdraw consent at any time.
4. Object to or restrict certain types of processing.
5. Request portability of your data.
6. Lodge a complaint with the National Cyber Security Authority (NCSA).

You may exercise these rights by contacting us at the email provided below.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our website. These include:

1. Necessary Cookies: to enable basic functions of the site.
2. Functionality Cookies: to remember user preferences.
3. Performance Cookies: to collect analytics on site usage.
4. Marketing Cookies: to provide targeted advertising.

You can control or disable cookies through your browser settings. For more information, refer to our separate Cookies Policy.

10. Security of Your Data

We implement appropriate technical and organizational measures to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet is 100% secure.

11. Children’s Privacy

Our services are not directed at children under the age of 18. We do not knowingly collect Personal Data from individuals under 18 years old without verifiable parental consent.

12. Third-Party Links

Our website may contain links to external websites not operated by us. We are not responsible for the content or privacy practices of those websites. We encourage you to read their privacy policies.

13. Changes to this Policy

We may update this Policy from time to time. We will notify you of any material changes by updating the “Last Updated” date at the top of this page. You are advised to review this Policy periodically.

14. Contact Us

If you have any questions or concerns about this Policy or wish to exercise your rights, you may contact us at:

Bugesera Special Economic Zone Ltd
E-mail: bsez@arisenet.com