Privacy Policy
Version 1 · in effect since 1 September 2026
SAMPLE TEXT — NOT BINDING
This is placeholder content seeded for development and staging. It has not been reviewed by counsel, it does not bind Ubuhanzi or its users, and it must not be published to production. Sections marked OPEN QUESTION are facts that must be established before any of this becomes real policy.
1. What this covers
This policy describes the personal data Ubuhanzi holds about artists, producers, studio clients and visitors to artist websites.
OPEN QUESTION — Ubuhanzi's registered Data Protection Officer under Law No. 058/2021, and their contact address.
OPEN QUESTION — whether Ubuhanzi is registered with the NCSA as a data controller, and its registration number.
2. What we collect
| Data | Why we hold it |
|---|---|
| Name, email, phone | Account identity and contact |
| Artist profile, bio, photos | To build and publish your artist website |
| Payout details | To pay you money we collect on your behalf |
| Bookings and invoices | To run the studio and account for revenue |
| Product analytics | To understand how the platform is used |
3. Payout details
Mobile-money numbers, bank account numbers, IBANs and SWIFT codes are encrypted at rest. They are used only to pay you.
OPEN QUESTION — the retention period for payout details after an account closes, and whether a DPIA has been completed for this processing.
4. Where your data is stored
Law No. 058/2021 requires personal data about people in Rwanda to be stored in Rwanda, or to be covered by an NCSA certificate permitting storage abroad.
The platform currently uses these processors:
- Cloudinary — images and artwork
- Mux — audio and video
- Resend — transactional email
- PostHog — product analytics and error tracking
- the PostgreSQL database host
OPEN QUESTION — the hosting jurisdiction of each processor above, and whether an NCSA certificate covers any personal data held outside Rwanda. This section cannot be published until each answer is established: an inaccurate statement here is a documented false claim, not a typo.
5. Analytics
Ubuhanzi uses PostHog for product analytics and error tracking. Events identify accounts by an opaque internal id — no names, emails or phone numbers are sent to analytics. See the Cookie & Tracking Notice.
6. How long we keep things
- Email delivery logs: 90 days, then deleted automatically.
- Administrative audit records: kept indefinitely, identifying actors by id only.
OPEN QUESTION — retention periods for account records, uploaded masters and booking history. These must match what the code actually does.
7. Your rights
You can ask what we hold about you, ask us to correct it, and ask us to delete it.
OPEN QUESTION — how a deletion request interacts with the record that you accepted these terms. Erasure and evidence of consent pull in opposite directions and this needs a stated policy.