1. Introduction

Unused Ink Group ("we," "our," or "us") is committed to protecting your privacy and personal data in accordance with the Law N° 058/2021 of 13/10/2021 Relating to the Protection of Personal Data and Privacy of the Republic of Rwanda, and other applicable data protection regulations.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website, use our services, or interact with our AI assistant (Inky).

2. Data Controller

Unused Ink Group
Part of Gewape Technologies Ecosystem
Kigali Heights, 4th Floor
KG 7 Ave, Kigali, Rwanda
Email: hello[at]unusedink.com
Phone: +250 796 163 398

3. Personal Data We Collect

We may collect and process the following categories of personal data:

Identity Data: Name, job title, company name
Contact Data: Email address, phone number, postal address
Technical Data: IP address, browser type, device information, cookies
Usage Data: Information about how you use our website and services
Communication Data: Messages sent through our contact form or Inky chat
Project Data: Information you provide about your business needs and requirements

4. Legal Basis for Processing

In accordance with Rwanda's Data Protection Law, we process your personal data based on:

Consent: When you submit a contact form or interact with Inky
Contract Performance: To provide services you have requested
Legitimate Interest: To improve our services and communicate with you
Legal Obligation: To comply with applicable laws and regulations

5. How We Use Your Data

We use your personal data to:

Respond to your inquiries and provide customer support
Deliver the services you have requested
Send you relevant information about our services (with your consent)
Improve our website and services
Comply with legal obligations
Protect against fraud and unauthorized access

6. AI Assistant (Inky)

Our AI assistant, Inky, processes your messages to provide helpful responses. When you share contact information with Inky, this data is:

Processed by OpenAI's API to generate responses
Stored in our CRM system to enable our team to follow up
Used only for the purpose of addressing your inquiry

Conversations with Inky are not used to train AI models. You can request deletion of your conversation data at any time.

7. Data Sharing and Transfers

We may share your personal data with:

Service Providers: Third-party vendors who assist in our operations (hosting, email, CRM)
Gewape Technologies: Our parent company within the ecosystem
Legal Authorities: When required by law or to protect our rights

For international data transfers, we ensure appropriate safeguards are in place as required by Rwanda's Data Protection Law.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Typically:

Contact form submissions: 3 years
Client project data: Duration of engagement plus 7 years
Marketing communications: Until you unsubscribe
Website analytics: 26 months

9. Your Rights

Under Rwanda's Data Protection Law, you have the right to:

Access: Request a copy of your personal data
Rectification: Request correction of inaccurate data
Erasure: Request deletion of your personal data
Restriction: Request limitation of processing
Portability: Request transfer of your data
Objection: Object to processing based on legitimate interest
Withdraw Consent: Withdraw consent at any time

To exercise these rights, contact us at hello[at]unusedink.com. We will respond within 30 days as required by law.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

SSL/TLS encryption for data in transit
Secure hosting infrastructure
Access controls and authentication
Regular security assessments

11. Cookies

Our website uses cookies and similar technologies to enhance your experience. These include:

Essential Cookies: Required for website functionality
Analytics Cookies: Help us understand website usage
Preference Cookies: Remember your settings

You can manage cookie preferences through your browser settings.

12. Children's Privacy

Our services are not directed at individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.

13. Complaints

If you have concerns about how we handle your personal data, please contact us first. You also have the right to lodge a complaint with the National Cyber Security Authority (NCSA) of Rwanda, the supervisory authority for data protection matters.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting a notice on our website. Your continued use of our services after changes constitutes acceptance of the updated policy.

15. Contact Us

For any questions about this Privacy Policy or our data practices, contact us at:

Unused Ink Group
Kigali Heights, 4th Floor
KG 7 Ave, Kigali, Rwanda
Email: hello[at]unusedink.com
Phone: +250 796 163 398