Privacy policy

Effective Date: November 4, 2025
Last Updated: October 23, 2026

1. Introduction

Welcome to HangaVision Ltd. ("HangaVision", "we", "our", or "us"). We engineer clean, off-grid cooling technologies—including our flagship product, FreshKeep™—to eliminate post-harvest produce loss across agricultural value chains and local retail markets.

We are committed to protecting the privacy, confidentiality, and security of personal data in compliance with the Law Nº 058/2021 of 13/10/2021 Relating to the Protection of Personal Data and Privacy of the Republic of Rwanda. This Privacy Policy outlines how we collect, use, process, disclose, and safeguard personal information when you visit our website (www.hangavision.com), participate in our field trials or cooperative programs, interact with FreshKeep™ cooling lockers, or use our services.

2. Information We Collect

We collect only the personal information necessary to deliver, maintain, and evaluate our hardware and service operations:

• Contact & Identification Data: Names, phone numbers, email addresses, cooperative or vendor stall identifiers (such as stall numbers at Ziniya Market), and organization names provided when submitting inquiries, requesting pilot participation, or entering trial agreements.

• Transaction & Payment Data: Mobile Money (MTN MoMo or Airtel Money) transaction references, timestamp records, and payment amounts for Pay-As-You-Keep daily subscriptions. We do not store financial account passwords, PINs, or mobile wallet credentials.

• Telemetry & Operational Data: Sensor logs collected from FreshKeep™ hardware, including chamber temperatures, humidity levels, locker door access timestamps, battery voltage, and telemetry status via embedded microcontrollers (ESP32). These technical logs are linked to locker units rather than individual consumer identities.

• Field Survey & Pilot Feedback: Voluntary feedback on produce shelf-life, daily produce sales, spoilage reduction metrics, and user experience submitted through cooperative surveys or field interviews.

• Website & Technical Data: IP addresses, browser types, device information, and standard session analytics collected via strictly necessary and functional cookies when visiting our web portal.

3. Legal Grounds & Purposes of Data Processing

In accordance with Law Nº 058/2021, we process your personal data under the following lawful bases:

• Contractual Necessity & Service Delivery: Operating and managing FreshKeep™ locker access, validating digital micropayments, and managing cooperative vendor accounts.

• Legitimate Interests & R&D: Benchmarking cooling efficiency, evaluating post-harvest economic impact, improving embedded hardware reliability, and generating anonymized pilot impact reports for academic incubation programs (such as RP Kigali / BIIH and ACES Rubilizi).

• Consent: Sending organizational updates, technical newsletters, or partnership opportunities (consent may be withdrawn at any time).

• Legal Compliance: Fulfilling statutory accounting, tax, and regulatory record-keeping obligations in Rwanda.

4. Sharing & Disclosure of Information

HangaVision does not sell, lease, or monetize your personal data. We disclose personal data only under strict confidentiality standards to:

• Authorized Service Providers: Telecommunications carriers, Mobile Money gateway operators, and cloud infrastructure providers assisting in payment processing, SMS notifications, or telemetry storage under compliant data processing agreements.

• Institutional Pilot Partners & Cooperatives: Market cooperative management for verifying vendor subscriptions and locker allocations. All published academic research, grant reports, or public showcases present aggregated, anonymized data only.

• Legal & Regulatory Authorities: When disclosure is required by Rwandan law, judicial order, or lawful administrative directive to protect public safety or legal rights.

5. Data Security & Storage

• Technical Safeguards: We employ industry-standard administrative, physical, and technical safeguards, including encrypted data transmission (HTTPS/SSL), secure API authentication for IoT telemetry, and restricted internal access permissions.

• Data Retention: Personal data is retained only for as long as necessary to fulfill the purposes for which it was gathered, conduct pilot evaluations, or satisfy legal audit requirements, after which it is securely deleted or anonymized.

6. Your Data Rights

Under Law Nº 058/2021, you have the following rights regarding your personal information:

• Right of Access & Rectification: Request confirmation of the data we hold about you and correct inaccurate or incomplete information.

• Right to Erasure ("Right to be Forgotten"): Request the deletion of your personal data where retention is no longer necessary or legally required.

• Right to Object or Restrict Processing: Object to direct marketing communications or request that we restrict processing in specific circumstances.

• Right to Data Portability: Request a copy of your personal data in a structured, commonly used digital format.

• Right to Lodge a Complaint: If you believe your data has been handled contrary to Rwandan law, you have the right to lodge a complaint with the National Cyber Security Authority (NCSA) via www.ncsa.gov.rw.

7. Contact Us

For any inquiries, requests to exercise your data rights, or questions regarding this Privacy Policy, please contact our team:

• Data Inquiries: hangavision@gmail.com

• Official Website: www.hangavision.com

• Physical Base: HangaVision, Business Incubation & Innovation Hub, Rwanda Polytechnic (RP Kigali Campus), KK 15 Rd / NR5, Kicukiro, Kigali, Rwanda