Privacy Policy

We highly prioritize safeguarding your personal information and implement rigorous measures to uphold the highest security standards, processing your data with fairness, transparency, and compliance, as outlined in this privacy notice.

This policy applies to customers, users of our website and products, suppliers, retailers, and other data subjects who share personal data with us.

Key terms

Words “we”, “our” and “us” refer to KTRN and its retailers.

Personal Data, Sensitive personal data, data subject, Data processing, data controller, data processor, and others shall mean as in the data protection and privacy law of Rwanda.

Personal Data Collected

Personal information collected and held by us may include but is not limited to; name, sex, date of birth, addresses, International Mobile Equipment Identity, mobile phone number, email address, occupation, and information contained in supporting documents such as proof of identity and proof of address.

KTRN and its authorized third parties may collect, store, and process the following types of Personal Information: biometric data, financial information, for providing our products, services and for use of our website, information related to your utilization of our services which may include your call patterns, your browsing history on our website, location details and additional information provided while using our services.

Use of Personal Data

KTRN collects your personal information for a variety of business purposes. These include, but are not limited to:

Verifying identity.
Completing transactions and billing effectively.
Responding to service requests.
Conducting market and operational analysis.
Contracting, processing orders, and updating on progress.
Providing, maintaining, and enhancing products/services.
Anticipating and resolving product/service issues.
Promoting relevant products/services.
Preventing fraud and criminal activity.
Logging user activities for analytical purposes.
Allowing users to opt out of sharing browsing information.

Acknowledging that withholding consent may affect product/service provision.

Legal Bases for Processing Personal Data by KTRN:

Consent: KTRN may process your personal data with your consent, which will be obtained separately and can be withdrawn at any time.
Contractual Necessity: Processing may occur when necessary for the performance of a contract or to take pre-contractual steps at your request, such as fulfilling orders or providing services.
Legal Obligation: When processing personal data is necessary to comply with legal obligations imposed by law on KTRN, this legal basis is invoked.
Legitimate Interest: KTRN may process personal data for legitimate business interests, such as direct marketing or service improvement, ensuring that these interests do not override your rights; you may also have the right to object in certain cases.

Is it mandatory to provide KTRN the Personal Data asked for?

It is not mandatory for you to provide any Personal Data to us. However, failing to provide certain Personal Data to us, particularly where that Personal Data has been requested by us may impact our ability to, amongst other things:

Provide our products or services to you;
To support you with and manage our products and services;
Provide you full functionality to all our web pages;
On-board you as a supplier, reseller, contractor, or retailer;
To allow you access to our premises or buildings.

Automated Processing of Personal Data

KTRN does not perform any automated decision-making (including profiling) which results in legal consequences for you and/or which affects you in a similarly significant manner. Should this change in the future, we will notify you and update this privacy notice accordingly.

Retention of your Personal Data

We will not retain your Personal Data for any longer than is necessary for achieving the purpose(s) for which the Personal Data is processed, unless:

Retention of the Personal Data is required or authorized by Local laws;
You have consented to the retention of the Personal Data; or
The Personal Data is required for historical, statistical, or research purposes and provided that we have established appropriate safeguards against the Personal Data being used for any other purposes.

We will ensure that Personal Data that is no longer required, or which we are no longer authorized to retain, is as soon as reasonably practicable, de-identified, or destroyed through secure means, alternatively through permanent erasure by appropriate and effective mechanisms.

Sharing of Personal Data

KTRN may shares Personal Data with affiliated third parties for legitimate business needs, to fulfill requests, and/or as required or permitted by law, including:

Service Providers: Personal Data is transferred to third-party service providers, such as IT systems providers and consultants, under binding agreements with security safeguards.
Business Transfer: Personal Data may be disclosed in the event of a reorganization, sale, or transfer of the business.
Legal Compliance: Disclosure may occur in response to requests from courts, law enforcement, or regulatory bodies to comply with applicable laws or regulations.
Audits: Personal Data may be disclosed to auditors for financial, privacy, or security audits or to investigate complaints or security threats.
Insurers: Personal Data may be shared with insurance market participants for underwriting, claims, and legal compliance purposes.
Other Third Parties: Information may be shared with third parties advertising on KTRN platforms/systems, but Personal Data is anonymized or aggregated before sharing.

Cross Border Transfer of Personal Data

Currently, KTRN do not involve in cross border transferring or processing. However, in the future, if such transfers become necessary for legitimate business purposes in providing services to you, we will ensure that appropriate security measures are taken to protect your data in accordance with Data Protection Principles and Regulations.

Security of your Personal Data

KTRN ensures the integrity and confidentiality of Personal Data through appropriate technical, physical, and organizational measures to prevent accidental loss, unauthorized access, and unlawful processing, regularly assessing and addressing internal and external risks to data security.

Legal Rights

If KTRN Processes Personal Data about you, you have the following rights:

Right to access personal information: You have the right to make a request for a copy of the personal information that KTRN holds about you as permitted by law.
Right to correct personal information: You have the right to correct information held about you to ensure it is accurate, relevant, complete, and not excessive.
Right to object to use of personal information: You have the right to object to KTRN processing your personal information in certain cases permitted by law, although this right may be limited if the processing is based on a legal obligation.
Right to personal data portability: You can request KTRN, in writing or electronically, to provide your personal data in a readable format as it was initially provided, and you may also ask for your data to be transferred to another controller, where technically possible, without obstruction.
Right to restriction of processing of personal data: You can ask KTRN to limit processing of your personal data as allowed by law, but if processing is necessary to fulfill our contractual obligations, objecting may affect our ability to provide services and products.
Right to erasure of personal data: You have the right to request the erasure of your personal data from KTRN, which can be done by contacting us at itsecurity@ktrn.rw and we will make reasonable efforts to comply with your request in accordance with applicable laws and internal policies;

Furthermore, you retain the right to lodge a complaint with the Data Protection Office, whose contact details are:

Address: 21 KG 7 Ave, Kacyiru A&P Building, Ground Floor, Kigali - Rwanda

Email Address: complaint@dpo.gov.rw, databreach@dpo.gov.rw

Telephone number: +250 782 847 756 or 9080

Website: https://dpo.gov.rw/

Changes to privacy policy

KTRN reserves the right to update this Privacy Notice periodically, with any changes communicated to individuals through their preferred communication channel.

For inquiries, concerns, or to contact our Data Protection Officer (DPO) for information on information protection, please email us at itsecurity@ktrn.rw .