Privacy policy

The following definitions apply throughout this Privacy Policy. Capitalized terms not defined here carry the meanings given to them in the KwiGO Terms and Conditions of Service.

"Platform"

refers to KwiGO and the KwiGO mobile application, website, and all related digital tools and services operated by KwiGO. Throughout this Privacy Policy, the terms "KwiGO" and "Platform" are used interchangeably and carry the same meaning.

"User"

means the buyer; the individual (singular or plural) who registers for and uses the Platform to access relevant Offers. Any reference to "User" includes the plural "Users" and vice versa.

"Merchant"

means the independent seller or service provider (singular or plural) that lists relevant Offers on the Platform pursuant to a Merchant Agreement with KwiGO. Any reference to "Merchant" includes the plural "Merchants" and vice versa.

"Personal Data"

means any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, location, device identifiers, and usage data.

"Processing"

means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.

"Data Controller"

means the entity that determines the purposes and means of Processing Personal Data. KwiGO is the Data Controller in respect of Personal Data collected through the Platform.

"Data Processor"

means any third party that processes Personal Data on behalf of and under the instructions of KwiGO as Data Controller.

"Consent"

means a freely given, specific, informed, and unambiguous indication of agreement by a User to the Processing of their Personal Data for a stated purpose.

"Applicable Law"

(also referred to as "Law" or "Rwandan Law" throughout this Privacy Policy) means the laws and regulations of the Republic of Rwanda such as data protection and privacy, (Law N° 058/2021 of 13/10/2021 Relating to the Protection of Personal Data and Privacy in Rwanda) and any other relevant sector-specific regulations applicable to KwiGO's operations.

"Offer"

means any relevant temporary or permanent discounts, promotion, deal, or value-added service made available to Users by a Merchant through the KwiGO mobile app.

"Redemption"

means the act of a User claiming or utilizing an Offer through the KwiGO mobile app's in-app verification mechanisms, such as QR codes, promotional codes, or such other methods as KwiGO may designate from time to time.

"Account"

means the registered profile created by a User on the KwiGO mobile app, through which the User accesses the Platform and its relevant Offers.

KwiGO ("KwiGO", "we", "us", or "our") is a company incorporated under the laws of the Republic of Rwanda. We operate the KwiGO mobile application and all associated services—a digital lifestyle and discount marketplace connecting Users with independent Merchants. This Privacy Policy explains how KwiGO collects, uses, holds, and protects your Personal Data when you access or use the Platform. It applies to all Users and should be read alongside our Terms and Conditions of Service.

The Platform is the Data Controller in respect of Personal Data collected through the Platform. If you have any questions about this Privacy Policy or how your data is handled, please contact us at the details provided in Section 15.

This Privacy Policy applies to all Personal Data collected by the Platform through:

• The KwiGO mobile app on iOS and Android;
• The KwiGO website at www.kwigo.app;
• Any related digital services, communications, or interactions with KwiGO.

By registering for and using the Platform, you confirm that you are at least 16 years of age. If the Platform becomes aware that it has inadvertently collected Personal Data from a person under the age of 16, KwiGO will take immediate steps to delete that data from its systems. If you believe that a minor has provided Personal Data through the Platform, please contact us immediately at support@kwigo.app. KwiGO may use age-verification technical measures during registration to ensure compliance with this age limit.

The Platform collects Personal Data in the following categories, depending on how you interact with the KwiGO mobile app:

The Platform processes your Personal Data only for specific, legitimate purposes. We do not process your data in any manner incompatible with the purposes for which it was collected. The purposes for which we use your Personal Data are as follows:

The Platform processes your Personal Data on the following legal bases, in accordance with Applicable Law, such as the Law N° 058/2021 of 13/10/2021 Relating to the Protection of Personal Data and Privacy in Rwanda:

• Contract performance: Processing necessary to provide you with access to the Platform and to fulfil our obligations to you as a registered User;
• Legitimate interests: Processing necessary for KwiGO's legitimate business interests, such as Platform security, fraud prevention, service improvement, and analytics, where such interests are not overridden by your rights and interests;
• Consent: Where you have given your express Consent, for example in connection with location access or receiving promotional communications. You may withdraw your Consent at any time without affecting the lawfulness of Processing carried out prior to withdrawal; and
• Legal obligation: Processing required to comply with a legal or regulatory obligation under Applicable Law.

The Platform retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by Applicable Law, such as Rwandan financial regulations. The following general retention principles apply:

• Account data is retained for the duration of your registration on the Platform and for the period required by law, following Account closure, to comply with legal obligations and to resolve any outstanding disputes or claims;
• Transaction and Redemption records are retained for the number of years required in accordance with Rwandan financial record-keeping requirements;
• Technical and usage data collected for analytics and security purposes is retained for as long as necessary for the Platform to fulfil the purposes described in Section 6; and
• Communications and support records are retained for the period required by Applicable Law or for as long as is reasonably necessary to resolve any related disputes.

Where Personal Data is no longer required for any purpose, the Platform will securely delete or anonymize it in accordance with its internal data management procedures.

Subject to Applicable Law, such as the Law N° 058/2021 of 13/10/2021 Relating to the Protection of Personal Data and Privacy in Rwanda, you have the following rights in respect of your Personal Data held by KwiGO:

• Right of access: You have the right to request a copy of the Personal Data the Platform holds about you;
• Right to rectification: You have the right to request that inaccurate or incomplete Personal Data be corrected;
• Right to erasure: You have the right to request the deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to KwiGO's legal retention obligations;
• Right to restriction: You have the right to request that the Platform restricts the Processing of your Personal Data in certain circumstances;
• Right to object: You have the right to object to the Processing of your Personal Data where the Platform relies on legitimate interests as the legal basis for Processing;
• Right to withdraw Consent: Where Processing is based on your Consent, you have the right to withdraw that Consent at any time, without affecting the lawfulness of Processing carried out prior to withdrawal; and
• Right to data portability: In accordance with Rwandan Law, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format.

To exercise any of the above rights, please submit a written request to support@kwigo.app. The Platform will respond to all valid requests within 5 working days of receipt. KwiGO reserves the right to verify your identity before Processing any request and to refuse requests that are manifestly unfounded, excessive, or repetitive.

The Platform implements appropriate technical and organizational measures designed to protect your Personal Data against unauthorized access, loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Encryption of data in transit and at rest;
• Access controls limiting Personal Data access to authorised personnel on a need-to-know basis;
• Secure password storage using industry-standard hashing protocols;
• Regular security assessments and monitoring of the Platform; and
• Contractual security obligations imposed on all third-party service providers.

While the Platform takes reasonable steps to protect your Personal Data, no method of electronic transmission or storage is entirely secure. KwiGO cannot guarantee absolute security and encourages Users to take responsibility for the security of their own Account credentials. In the event of a Personal Data breach that is likely to result in a risk to your rights and freedoms, the Platform will notify you and the relevant Rwandan regulatory authority in accordance with Applicable Law.

The Platform is based in Rwanda and processes your Personal Data primarily within Rwanda. Where KwiGO engages third-party service providers who process Personal Data outside of Rwanda—for example, in connection with cloud infrastructure or analytics services—the Platform ensures that appropriate safeguards are in place to protect your Personal Data in accordance with Applicable Law.

Such safeguards may include contractual clauses requiring the recipient to provide equivalent levels of data protection to those applicable in Rwanda under the Law N° 058/2021 of 13/10/2021. By using the Platform, you acknowledge that your Personal Data may be transferred to and processed in countries outside of Rwanda in connection with the operation of the Platform, subject to the protections described in this Section.

The KwiGO mobile app and associated website may use cookies, pixels, software development kits (SDKs), and similar tracking technologies to support the operation and improvement of the Platform. These technologies may be used to:

• Maintain your session and keep you logged in to the KwiGO mobile app;
• Remember your preferences and settings;
• Analyze how Users interact with the Platform to support performance monitoring and improvement; and
• Support the security and fraud prevention functions of the Platform.

Where required by Applicable Law, the Platform will seek your Consent before placing non-essential cookies or similar technologies on your device. You may manage your cookie preferences through your device or browser settings; however, disabling certain technologies may affect the functionality of the KwiGO mobile app.

The Platform reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, the KwiGO mobile app, or Applicable Law. Where changes are material, KwiGO will notify you by email to the address registered to your Account and/or by an in-app notification through the KwiGO mobile app at the time the update takes effect.

The updated Privacy Policy will also be available at www.kwigo.app. Your continued use of the Platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not accept the updated Privacy Policy, you must cease using the Platform and close your Account prior to the effective date.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way in which the Platform handles your Personal Data, please contact our team at:

Entity

KwiGO Data Privacy

Location

Kigali, Republic of Rwanda

Email

support@kwigo.app

Website

www.kwigo.app

By downloading, registering for, or using the KwiGO platforms, the User certifies having read, understood, and agreed to be bound by this Privacy Policy, and consents to the collection and use of their Personal Data as described herein.