Proland Ltd – Privacy Policy

This Privacy Policy explains how Proland Ltd (“Proland Ltd”, “we”, “our” or “us”) collects, uses, discloses and protects personal data when you interact with us online or offline.

Last updated: 20 February 2026

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1. Introduction

We are committed to respecting your privacy and ensuring appropriate protection and management of personal data that we process as part of our interactions with you.

“Personal Data” means any information, alone or in combination with other information, that relates to an identified or identifiable natural person. This may include “Health Information” and “Special Category Information” (for example: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, sexual orientation, or criminal records), where applicable laws recognise such categories.

We may collect Personal Data from you directly, indirectly through documents and information you provide via our websites (the “Sites”), or through third parties. In some circumstances you may choose whether or not to provide Personal Data. However, if you choose not to provide certain information, you may still visit and use parts of our Sites but may be unable to access specific features or services. For safety and security reasons, refusal to provide certain data may also affect your ability to access our physical locations or impact our ability to do business with you.

Our Sites may contain links to other websites, products, services and advertisements that are not owned or controlled by us. We are not responsible for the privacy practices or content of those third-party sites, and you access them at your own risk.

This Privacy Policy applies, without limitation, to:

• Visitors to our Sites;
• Visitors to our property locations and other physical locations;
• Representatives of past, current and prospective customers;
• Representatives of past, current and prospective business partners, suppliers and contractors;
• Our shareholders and/or their representatives; and
• Representatives of our joint venture partners and other stakeholders.

2. Categories of Personal Data We May Collect

Depending on how you interact with us, we may process the following categories of Personal Data:

• Personal and business details such as name, address, date of birth, nationality or citizenship status;
• Contact details such as phone number, email address and postal address;
• Professional information such as employer, job title, role, qualifications, education or training;
• Information related to visits to our property locations, including identification details, visitor logs and (where appropriate) access credentials;
• Financial and payment information, such as bank account details, billing information and information required for tax, accounting and invoicing purposes;
• Information related to workplace safety, including training records, accident and incident reports, investigations, first-aid and other medical records, and information linked to workers’ compensation claims or exposure monitoring;
• Information collected via machinery or equipment you may operate while on our site (for example, operational or safety monitoring data);
• Biometric data, such as photographs or other identifiers used for security credentials or safety monitoring (where permitted by law).

In some situations, and only to the extent permitted or required by applicable laws, we may process Health Information or other Special Category Information. We will only do so where it is necessary and where we have your consent or another lawful basis.

We may process Health Information for purposes such as:

• Providing medical assistance and treatment in the event of an accident or emergency; and
• Complying with our health and safety obligations and other legal requirements.

a) Business and Operations

In connection with our business and operations, we may collect information including: name, age, gender, job title, photo identification, email address, physical/home/business address, telephone number, communication records (including notes from meetings and call recordings), feedback or survey responses, and financial/payment details.

If you provide Personal Data relating to another person, you must ensure that you have their consent or that the disclosure is otherwise lawful under applicable data privacy laws.

b) Personal Data Collected by Third Parties

We may engage third-party service providers to assist with certain business functions. These providers may collect Personal Data about you in the course of performing services for us. They are required to handle such data in accordance with contractual obligations and applicable privacy laws.

c) Information Collected Automatically via Our Sites

When you use our Sites, we automatically collect certain technical information through software tools and cookies. This may include:

• IP (Internet Protocol) address;
• Browser type and version;
• Device identifiers and operating system;
• Internet Service Provider (ISP);
• Date and time of access;
• Referring/exit pages and URLs;
• Pages viewed and clickstream data.

Do Not Track

Our Sites currently do not respond to “Do Not Track” signals. We also do not track users across third-party websites for targeted advertising purposes.

Analytics Services and Cookies

We may use cookies and similar technologies (for example, Google Analytics) to understand how visitors use our Sites, to improve performance and user experience, and to provide certain functionality. You can usually control cookies through your browser settings, but disabling some cookies may affect your ability to use parts of the Sites.

3. How We Use Personal Data

If you submit or we collect Personal Data, we may use it for the following purposes:

• To manage and operate our business and property portfolio;
• To manage contracts and relationships with customers, tenants and other partners;
• To manage leases, licences and other real estate arrangements;
• To handle invoices, payments and accounting records;
• To manage suppliers, contractors and other service providers;
• To manage health, safety and security at our locations;
• To provide and improve our Sites and online services;
• To respond to enquiries, requests and feedback;
• To send you information about developments, offers or events (where permitted by law);
• To carry out internal audits, investigations, compliance checks and risk management;
• To comply with legal and regulatory obligations and cooperate with regulators and authorities.

We will only process Personal Data where we have a lawful basis under applicable data protection laws. These legal bases may include: your consent; performance of a contract with you; compliance with a legal obligation; and our legitimate interests (for example, to manage and grow our business, ensure safety and security, prevent fraud and improve our services).

4. How We Share Personal Data

We do not sell, lease or rent your Personal Data. We may share Personal Data in the following situations:

a) Service Providers

We may share Personal Data with third-party service providers that perform services on our behalf, such as IT support, hosting, analytics, payment processing, security, maintenance and customer support. These providers are contractually required to protect Personal Data and use it only for the services they provide to us.

b) Affiliates and Joint Venture Partners

We may share Personal Data with our affiliates and joint venture partners for the purposes described in this Privacy Policy. Those parties must also protect Personal Data and may only use it in accordance with this Policy and applicable laws.

c) Business Transfers

In connection with a merger, acquisition, reorganisation or sale of assets, or in the event of insolvency or similar proceedings, your Personal Data may be transferred to the relevant third party as part of the transaction.

d) Legal and Regulatory Requirements

We may disclose Personal Data where we believe it is necessary or appropriate to:

• Comply with applicable laws, regulations, legal processes or governmental requests;
• Enforce our terms and conditions and other agreements;
• Detect, prevent or address fraud, security or technical issues; or
• Protect the rights, property and safety of Proland Ltd, our users or the public.

e) Aggregate Information

We may compile and share aggregated or de-identified information that does not identify individuals, for example to analyse trends, manage and improve our services or for other lawful purposes.

5. Retention, Accuracy and Deletion of Personal Data

We take reasonable steps to ensure that Personal Data we hold is accurate, complete and kept up to date. We encourage you to notify us if your details change.

We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, or for longer where required or permitted by law (for example, for tax, accounting or legal purposes).

6. Unsolicited Personal Data

If we receive Personal Data that we did not solicit and that is not reasonably required for one of our functions or activities, we will, where lawful and reasonable, destroy or de-identify that information as soon as practicable.

7. Data Security

We use appropriate technical and organisational measures to protect Personal Data from unauthorised access, alteration, disclosure or destruction. However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your Personal Data, we cannot guarantee its absolute security.

8. Children’s Privacy

Our Sites and services are not directed to children under the age of 18. We do not knowingly collect Personal Data from children. If we become aware that we have collected Personal Data from a child, we will take steps to delete it.

9. Email Communications and Marketing

We may send you emails about our services, updates and events where permitted by law. You can opt out of marketing emails at any time by using the unsubscribe link in our messages or by contacting us.

Even if you opt out of marketing communications, we may still send you non-marketing messages relating to your relationship with us (for example, service announcements, booking confirmations or important notices).

10. Your Rights

Depending on your location and applicable law, you may have certain rights in relation to your Personal Data, including:

• Right to access your Personal Data;
• Right to request correction of inaccurate or incomplete data;
• Right to request deletion of your Personal Data, subject to legal exceptions;
• Right to object to or request restriction of processing in certain circumstances;
• Right to data portability, where applicable;
• Right to withdraw consent, where processing is based on consent.

To exercise these rights, please contact us using the details below. We may need to verify your identity before processing your request and may be entitled to refuse certain requests in accordance with applicable laws.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements or other reasons. When we do, we will post the updated version on our Sites and update the “Last updated” date at the top. We encourage you to review this page regularly.

12. Contact Us

If you have any questions, comments or complaints about this Privacy Policy or our handling of Personal Data, you can contact:

The Head of Front Desk Department
Proland Ltd
37 KG 241 ST,
Kicukiro, Kigali, Rwanda
Email: privacy@prolandhomes.com