Privacy Policy

This Privacy Policy explains how BookOn, operated by Graktung Group and its affiliates ("BookOn", "we", "us", or "our"), collects, uses, shares, stores, and protects personal information when you access our websites, mobile applications, APIs, and related services (collectively, the "Platform"). We are committed to handling personal data responsibly and in accordance with applicable data protection laws, including the Law No. 058/2021 of 13 October 2021 relating to the protection of personal data and privacy in Rwanda and other laws that may apply to you.

By using the Platform, you acknowledge that you have read this Privacy Policy. If you do not agree with our practices, please do not use the Platform. This Policy should be read together with our Terms & Conditions, which govern your contractual relationship with BookOn.

1. Who we are and how to contact us

BookOn is an event booking and ticketing platform that connects Tenants (event organizers, venues, and businesses) with Customers (attendees and purchasers). The Platform is operated by Graktung Group.

For privacy-related questions, requests to exercise your rights, or complaints about our handling of personal data, contact:

• Data Protection / Privacy Team — BookOn / Graktung Group
• Email: privacy@bookon.rw
• General support: support@bookon.rw
• Website: https://bookon.rw

We will respond to verified requests within timeframes required by applicable law, typically within thirty (30) days, unless an extension is permitted and communicated to you.

2. Scope of this policy

This Privacy Policy applies to personal information we process when you:

• Visit BookOn websites or use our applications.
• Create or manage an Account as a Tenant, Customer, staff user, or administrator.
• Browse Listings, make Bookings, or process payments through the Platform.
• Communicate with our support team or receive marketing communications from us.
• Interact with cookies, analytics, and similar technologies on our sites.

This Policy does not apply to:

• Tenant-controlled pages and communications where the Tenant is the data controller for Customer data collected outside BookOn's core processing (for example, on-site registration forms managed solely by the Tenant), except where BookOn processes that data on the Tenant's behalf through the Platform.
• Third-party websites or services linked from the Platform, including Paypack's own portals, social networks, or venue websites. Those services have their own privacy policies.

When we process personal data on behalf of a Tenant in connection with Bookings and Events, the Tenant is typically the data controller for Customer attendee data, and BookOn acts as a data processor under the Tenant's instructions and our agreements with Tenants. This Policy describes BookOn's practices in both controller and processor roles where relevant.

3. Personal information we collect

We collect personal information in several categories depending on how you use the Platform. Not all categories apply to every user.

3.1 Information you provide directly

• Account and profile data: name, email address, phone number, password (stored in hashed form), profile photo, organization name, job title, and preferences.
• Tenant business data: business registration details, tax identifiers where collected, payout bank or mobile money account information, Event descriptions, venue addresses, and staff user invitations.
• Customer booking data: name, email, phone number, billing details, attendee names, responses to custom registration questions, and special requirements you choose to share (for example, accessibility needs or dietary information if requested by the Tenant).
• Communications: messages you send to support, feedback, survey responses, and records of phone or chat interactions where permitted.
• Marketing preferences: opt-in or opt-out choices for promotional emails or SMS.

3.2 Information collected automatically

When you use the Platform, we may automatically collect:

• Device and usage data: IP address, browser type, operating system, device identifiers, pages viewed, referring URLs, session duration, clickstream data, and crash logs.
• Location data: approximate location derived from IP address; precise location only if you grant permission through your device or browser for features that require it (such as map-based venue discovery).
• Authentication and security logs: login timestamps, failed login attempts, and fraud-prevention signals.

3.3 Information from third parties

We may receive information from:

• Paypack and payment partners: transaction status, partial card or mobile money identifiers, payment method type, and fraud risk scores. We do not store full payment card numbers on BookOn servers when processing is handled by Paypack.
• Tenants: attendee lists, import files, or CRM data uploaded by Tenants where you have a relationship with that Tenant.
• Service providers: identity verification, email delivery, analytics, and cloud hosting partners acting under contract.
• Public sources: publicly available business registry or social profile information where relevant to verify Tenants.

3.4 Sensitive data

We generally do not require sensitive categories of personal data (such as health data, biometric data, or government ID numbers) unless necessary for a specific feature, legal obligation, or Tenant-configured registration question. Where Tenants collect sensitive information through custom forms, they are responsible for lawful basis and transparency to Customers, and BookOn processes such data only as instructed.

4. How we use personal information

We use personal information for the following purposes:

• Providing the Platform: creating Accounts, authenticating users, displaying Listings, processing Bookings, generating tickets and QR codes, and enabling check-in.
• Payments and settlements: initiating charges through Paypack, calculating Platform Service Fees, issuing payouts to Tenants, handling refunds and chargebacks, and maintaining financial records.
• Communication: sending booking confirmations, Event reminders, schedule changes, security alerts, and service announcements.
• Support and dispute handling: responding to inquiries, investigating issues, and facilitating communication between Tenants and Customers where appropriate.
• Safety and integrity: detecting fraud, abuse, unauthorized access, and violations of our Terms.
• Improvement and analytics: understanding usage patterns, debugging, developing new features, and measuring performance. Where feasible, we use aggregated or de-identified data for analytics.
• Marketing: sending promotional content about BookOn features, webinars, or partner offers where you have opted in or where permitted by law. You may opt out at any time.
• Legal compliance: satisfying tax, accounting, anti-money-laundering, and regulatory obligations, and responding to lawful requests from authorities.

Our legal bases for processing under Rwandan and applicable law may include contract performance, legitimate interests (such as fraud prevention and product improvement), consent (for certain marketing and cookies), and legal obligation.

5. Bookings and event-related data

Bookings are central to the Platform, and processing booking-related data is essential to our service.

5.1 What booking data includes

When you make or manage a Booking, we process information such as:

• Event and ticket type selected.
• Quantity, price, discounts, and promo codes applied.
• Attendee names and contact details.
• Answers to custom questions configured by the Tenant.
• Booking status (confirmed, cancelled, checked in, refunded).
• Timestamp and source of the Booking (web, mobile, box office integration).

5.2 How Tenants access booking data

Tenants can access Customer and attendee data for Events they operate through the Tenant dashboard, exports, API integrations, and reporting tools. Tenants must use this data only for Event management, customer service, and purposes disclosed to Customers, in compliance with applicable privacy law and their own policies.

BookOn provides role-based access controls for Tenant staff accounts. Tenants are responsible for managing permissions and removing access for former employees or contractors.

5.3 Check-in and on-site use

If a Tenant uses BookOn check-in tools, we process scan events, device identifiers of scanning staff, and attendance status. This helps prevent duplicate entry and generate attendance reports for the Tenant.

5.4 Post-Event retention by Tenants

After an Event, Tenants may retain attendee lists for legitimate purposes such as accounting, loyalty programs, or future marketing only if they have a valid legal basis and have provided appropriate notice to Customers. BookOn's retention of booking records is described in Section 11; Tenants may have separate retention practices for data they export.

6. Payments and Paypack

Payment processing involves both BookOn and Paypack, our integrated payment service provider.

6.1 Data shared with Paypack

When you pay for a Booking or when a Tenant receives a payout, we share necessary information with Paypack, such as:

• Transaction amount and currency.
• Customer name and contact details required for receipts and fraud checks.
• Payment method selection (card, mobile money, or other supported methods).
• Tenant identifier and Event reference for reconciliation.
• IP address and device signals for risk assessment.

Paypack processes payments according to its own privacy policy and applicable financial regulations. BookOn does not store full primary account numbers (PAN) or CVV codes on our systems when Paypack tokenization or hosted fields are used.

6.2 Records we retain for payments

We retain transaction records including amounts, fees, refund status, payout batches, and correlation IDs linking BookOn, Paypack, and Tenant accounts. These records support Settlement, tax reporting, dispute resolution, and audit requirements.

6.3 Fraud and compliance

We and Paypack may use automated systems to evaluate transaction risk. Suspicious activity may lead to additional verification steps, delayed payouts, or Account suspension to protect users and the Platform.

6.4 Tenant payout information

Tenants provide bank account or mobile money details for Settlement. We encrypt and restrict access to payout credentials and share them only with payment partners as needed to execute transfers.

7. Cookies and similar technologies

We use cookies, local storage, pixels, and similar technologies to operate and improve the Platform.

7.1 Types of cookies we use

• Strictly necessary cookies: required for login sessions, security, load balancing, and checkout functionality. These cannot be disabled without breaking core features.
• Functional cookies: remember preferences such as language, timezone, or recently viewed Events.
• Analytics cookies: help us understand how users navigate the Platform, which pages perform well, and where errors occur. We may use first-party or third-party analytics tools with configured data minimization where possible.
• Marketing cookies: used to measure advertising effectiveness or deliver relevant BookOn promotions on third-party sites, where you have consented where required.

7.2 Your choices

On first visit where required by law, we display a cookie consent banner allowing you to accept, reject non-essential cookies, or customize preferences. You can also manage cookies through browser settings. Blocking certain cookies may limit Platform functionality.

7.3 Do Not Track

Some browsers transmit "Do Not Track" signals. There is no uniform industry standard for responding to these signals; we currently do not alter our practices solely in response to DNT signals, but we honor applicable cookie consent requirements.

8. Tenant and customer roles

Understanding who is responsible for your data depends on your relationship with the Platform.

8.1 Customers

If you are a Customer, BookOn typically acts as a data controller for Account information you provide directly to us and for Platform operation data (such as logs and cookie data). For attendee details collected solely to fulfill a Tenant's Event, the Tenant is generally the data controller, and BookOn processes that data as a processor to facilitate the Booking.

Customers should:

• Review the Tenant's privacy notice or Event terms for how the Tenant will use attendee data after the Event.
• Contact the Tenant first for requests related to marketing or retention of data the Tenant exported from BookOn.
• Contact BookOn for requests related to your BookOn Account, Platform-wide processing, or where we act as controller.

8.2 Tenants

If you are a Tenant, you are the data controller for personal information about your Customers and attendees that you collect and manage through your Events. You must:

• Provide a lawful basis and transparent notice to Customers.
• Configure registration questions appropriately and avoid collecting unnecessary sensitive data.
• Respond to Customer rights requests for data you control, using BookOn tools where available.
• Ensure staff and subprocessors with access to attendee data are bound by confidentiality and security obligations.

BookOn acts as a processor when handling Customer attendee data on your behalf, subject to our Terms, this Policy, and any data processing terms we provide to Tenants.

8.3 BookOn as controller

BookOn acts as controller for Account administration, billing with Tenants, Platform security, product analytics, direct marketing to Account holders, and compliance records related to our own business operations.

8.4 Joint scenarios

In limited cases, such as co-branded Events or BookOn-organized promotions, responsibilities may be shared. We will clarify roles in event-specific notices where applicable.

9. How we share personal information

We do not sell your personal information. We share data only as described below:

• With Tenants: Customer booking and attendee data for Events they operate.
• With Paypack and banking partners: to process payments and payouts.
• With service providers: cloud hosting, email and SMS delivery, customer support tools, analytics, and security vendors under contracts requiring appropriate safeguards.
• With other users: only as you direct (for example, displaying your name on a guest list to a Tenant) or as necessary to complete a Booking.
• For legal reasons: when required by law, court order, or governmental request, or to protect rights, safety, and integrity of BookOn, users, or the public.
• Business transfers: in connection with a merger, acquisition, or asset sale, with notice where required by law.

We may share aggregated or de-identified information that cannot reasonably identify you for research, marketing, or statistical purposes.

International transfers of data may occur where our service providers host systems outside Rwanda. We implement appropriate safeguards such as contractual clauses and security assessments consistent with applicable law.

10. Data retention

We retain personal information only as long as necessary for the purposes described in this Policy, unless a longer period is required or permitted by law.

10.1 General retention periods

• Account data: retained while your Account is active and for a reasonable period afterward to handle reactivation, disputes, or legal claims.
• Booking and transaction records: typically retained for seven (7) years or longer where required for tax, accounting, and financial regulations.
• Support communications: retained for the period needed to resolve issues and improve service, generally up to three (3) years.
• Marketing consent records: retained as long as needed to demonstrate compliance with opt-in and opt-out preferences.
• Security and access logs: retained for a limited period appropriate for fraud investigation and system integrity, often twelve (12) to twenty-four (24) months, unless extended for incident investigation.

10.2 Deletion and anonymization

When retention periods expire, we delete or anonymize personal information in accordance with our data lifecycle procedures. Backups may persist for a limited time before being overwritten. Deleted Accounts may not be recoverable.

10.3 Tenant-initiated deletion

Tenants may request deletion of certain Event or attendee data through dashboard tools or support requests, subject to legal holds, open disputes, or financial record obligations that require continued retention.

10.4 Legal holds

We may retain data longer when litigation, regulatory inquiry, or chargeback investigation requires preservation.

11. Security

We implement technical and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption in transit using TLS for web and API communications.
• Encryption at rest for sensitive fields where supported by our infrastructure.
• Role-based access controls and least-privilege principles for employees and contractors.
• Multi-factor authentication options for administrative and Tenant accounts.
• Regular monitoring, logging, and vulnerability management processes.
• Vendor security reviews for subprocessors handling personal data.
• Incident response procedures to assess, contain, and notify affected parties of data breaches where required by law.

No method of transmission or storage is completely secure. You are responsible for maintaining strong passwords and safeguarding your Account credentials. Report suspected unauthorized access to security@bookon.rw promptly.

Payment card data is handled by Paypack according to applicable payment industry standards. BookOn minimizes exposure to raw card data on our systems.

12. Your rights and choices

Depending on your location and applicable law, you may have the following rights regarding your personal information:

• Access: request confirmation of whether we process your data and obtain a copy of personal information we hold about you.
• Rectification: request correction of inaccurate or incomplete data.
• Erasure: request deletion of personal information, subject to legal exceptions (for example, completed transactions that must be retained for accounting).
• Restriction: request limited processing in certain circumstances.
• Objection: object to processing based on legitimate interests or direct marketing.
• Portability: receive personal information you provided in a structured, commonly used, machine-readable format where technically feasible.
• Withdraw consent: where processing is based on consent, withdraw consent without affecting prior lawful processing.
• Complaint: lodge a complaint with the National Cyber Security Authority (NCSA) or other competent supervisory authority in Rwanda, or your local authority where applicable.

12.1 How to exercise your rights

Submit requests to privacy@bookon.rw with sufficient information to verify your identity. We may request additional documentation to prevent unauthorized disclosure. We do not charge a fee for most requests unless permitted by law for repetitive or excessive requests.

12.2 Customer requests involving Tenants

If your request relates to data controlled by a Tenant (for example, post-Event marketing using an attendee list the Tenant exported), we may direct you to the Tenant or facilitate forwarding your request where we act as processor.

12.3 Marketing opt-out

You may unsubscribe from promotional emails using the link in each message or by updating preferences in your Account. Transactional messages related to Bookings, security, and legal notices may still be sent.

13. Children

The Platform is not directed to children under 18, and we do not knowingly collect personal information from children under 18 without appropriate parental or guardian consent where required by law.

• Customers must be at least 18 to create an Account and make Bookings, unless permitted under a Tenant's family Event policy with guardian supervision and lawful basis.
• Tenants must not use the Platform to collect personal information from children in violation of applicable child protection laws.
• If you believe we have collected information from a child without proper authorization, contact privacy@bookon.rw and we will take appropriate steps to delete the information.

Some Events may be intended for younger audiences when purchased by an adult guardian; in those cases, the adult's information is processed as the Account holder and payer.

14. Automated decision-making

We may use automated tools to detect fraud, assign risk scores to transactions, or flag suspicious Account activity. These processes may affect whether a payment succeeds or a payout is delayed. You may contact us to request human review of significant decisions that adversely affect you, where required by law.

We do not use solely automated decision-making that produces legal or similarly significant effects without appropriate safeguards where prohibited by applicable law.

15. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will notify you by posting the updated Policy on the Platform, updating the effective date, and, where appropriate, sending email notice or displaying an in-app alert.

We encourage you to review this Policy periodically. Continued use of the Platform after the effective date of changes constitutes acknowledgment of the updated Policy, except where explicit consent is required.

Previous versions may be available upon request to privacy@bookon.rw.

16. Contact and data protection inquiries

For any questions, concerns, or requests related to this Privacy Policy or our handling of personal information:

• Email: privacy@bookon.rw
• Support: support@bookon.rw
• Security incidents: security@bookon.rw
• Postal / registered address: Available upon request through privacy@bookon.rw for users who require formal written correspondence under local law.

When contacting us, please include:

• Your full name and registered email address.
• Your role (Customer, Tenant, or other).
• A clear description of your request or concern.
• Any relevant Booking ID, Event name, or transaction reference.

We are committed to working with you to address privacy questions promptly and transparently. Thank you for trusting BookOn and Graktung Group with your information.