Privacy Policy

1. Introduction & Overview

At SafeRent ("we", "our", or "us"), your privacy and security are fundamental principles. This Privacy Policy governs the manner in which SafeRent collects, uses, maintains, protects, and discloses personal information collected from users (each, a "User") of the SafeRent mobile iOS application, Android application, and web platform at thesaferent.com.

By downloading, accessing, or using SafeRent, you acknowledge the practices described in this policy. If you have any questions or wish to exercise your data rights, our dedicated Data Protection Officer is reachable at saferentrwanda@gmail.com.

2. Information We Collect & Optional Identity Information

2.1 Account & Basic Profile Information

To provide our rental discovery and tenancy services, we collect basic registration data:

• Basic Account Details: Full legal name, email address, and phone number for account authentication, password recovery, and communication with property owners or renters.
• Role Selection: Intended role on the platform (Tenant, Landlord, Broker, or Car Rental Provider).
• Transactional Records: Rental bookings, reservation history, contract agreements, and payment confirmations processed securely through regulated payment processors.

2.2 Optional Nature of Government ID / Passport Photo 100% Optional

Compliance with App Store Guideline 5.1.1(v): SafeRent does not require users to provide a Government ID, National ID, Passport photograph, or Face Data to access the core functionality of the app.

• Core App Features Remain Accessible Without ID: You can create an account, search properties, browse rental listings, view photo galleries, calculate rental costs, use loan/mortgage estimators, and message landlords or agents without uploading a Government ID, Passport photo, or Face Data.
• Voluntary Verification Workflow: Submitting a Government ID or Passport photo is strictly voluntary and optional. Users who choose to complete optional verification receive a "Verified Badge" on their profile to foster mutual trust in high-value lease transactions.
• Skip Option: Users can tap "Skip for Now / Complete Later" during registration to immediately bypass identity verification and proceed into the app. Verification may be completed later at any time from Account Settings, or omitted altogether.

3. Face Data & Biometric Information Policy (Apple Guideline 5.1.1(i) Compliance)

This section provides full transparency regarding our collection, use, disclosure, sharing, retention, deletion, and consent revocation practices regarding Face Data, specifically satisfying all requirements of Apple App Store Review Guideline 5.1.1(i) and Sections 3.3.3(C) and 3.3.3(K) of the Apple Developer Program License Agreement.

3.1 Collection of Face Data

SafeRent collects face data only when a user voluntarily and explicitly opts into the optional Identity Verification (KYC) feature:

• On-Device Face Alignment (Transient Processing): With user camera permission, the mobile app uses Google ML Kit Face Detection running locally on your device. ML Kit detects face presence, lighting quality, and head orientation (front, left profile, and right profile angles) to guide you during the photo capture. This orientation check occurs strictly in transient device RAM; no mathematical biometric face vectors, biometric templates, facial landmark meshes, or facial recognition embeddings are calculated, stored, or extracted.
• Verification Photographs Captured: If the user proceeds with optional verification, the app captures four still photographs:
  1. One front-facing portrait photograph;
  2. One left-angled profile photograph (approx. 45°);
  3. One right-angled profile photograph (approx. 45°);
  4. One photograph of the user holding their physical government-issued National ID or Passport.

3.2 All Intended Uses of Face Data

Captured facial verification photographs are used strictly, narrowly, and exclusively for:

• Voluntary Identity Verification (KYC): Confirming that the physical individual registering the account is the rightful owner of the voluntary identification document presented.
• Fraud Prevention & Community Safety: Preventing impersonation, duplicate fraudulent host accounts, rental scams, fake listings, and unauthorized property subletting.
• Strict Prohibition on Secondary Uses: SafeRent will never use face data for:
  • Targeted advertising, marketing, or behavioral tracking;
  • Commercial profiling or sale to data brokers;
  • Automated public surveillance or cross-app user tracking;
  • Training generative artificial intelligence or general machine learning facial models.

3.3 Disclosures of Face Data

Access to facial verification photos is restricted solely to authorized, background-checked SafeRent compliance officers responsible for manual verification review. SafeRent does not disclose facial data to any third party except when strictly compelled under enforceable court order or statutory legal process under Rwandan Law Nº 058/2021 relating to the protection of personal data and privacy.

4. Third-Party Sharing & Equal Protection Guarantee

4.1 No Selling or Commercial Sharing

SafeRent does NOT sell, rent, lease, trade, or share face data with any third parties for commercial, promotional, advertising, or marketing purposes. Face data is never shared with third-party advertising SDKs, data aggregators, or social media platforms.

5. Data Retention, Security & Cryptographic Storage

5.1 Cryptographic Storage & Security Measures

All captured facial verification images and personal identification records are transmitted across networks using industry-standard TLS 1.3 encryption and stored in secure, private, AES-256 encrypted server repositories. Storage access is safeguarded by strict Role-Based Access Controls (RBAC), multi-factor administrative authentication, and immutable access audit logs.

5.2 Retention Policy for Face Data

SafeRent enforces strict data lifecycle schedules for face data:

• Active Verified Accounts: Face verification photos are retained only for the duration that the user maintains an active verified account on SafeRent, in accordance with applicable tenancy verification records.
• Incomplete / Abandoned Verification: If a user initiates verification but does not complete or submit it, unsubmitted temporary photos are automatically discarded and deleted within 24 hours. If an application is rejected, records are purged within 14 calendar days.
• Revocation or Deletion: Upon consent revocation or account deletion, all face verification records are permanently and irreversibly purged within thirty (30) calendar days.

6. Deletion Policies & How to Revoke Consent

6.1 How Users Can Revoke Consent for Face Data

Consent for the collection and use of face data is completely voluntary and can be revoked at any time through multiple accessible methods:

• Method 1: Revoke Camera Permissions (iOS Settings): You can revoke the app's camera access at any time by navigating on your iOS device to: Settings → SafeRent → Camera and toggling the switch to OFF. Once disabled, SafeRent cannot access the device camera.
• Method 2: In-App Verification Consent Revocation: In the SafeRent mobile app, navigate to Profile → Account Settings → Privacy & Security. Tap "Revoke Face Verification Consent". This immediately removes your verified badge and permanently dispatches a purge request to delete all stored face verification photos.
• Method 3: Skip During Registration: You can refuse consent before any data is collected by simply tapping "Skip for Now / Complete Later" during the registration process.
• Method 4: Direct Email Notice: Email our Data Protection team at saferentrwanda@gmail.com with the subject line "Revoke Face Data Consent". Your consent will be revoked and face data purged within 48 business hours.

6.2 How Users Can Delete Their Face Data & Account

SafeRent provides complete self-service deletion rights:

• In-App Self-Service Account Deletion: Navigate in the app to Profile → Account Settings → Delete Account. Confirming account deletion permanently purges your user profile, active listings, rental history, Government ID photos, and all associated facial verification images.
• Standalone Face Data Deletion Request: If you wish to delete your face verification data while retaining your standard user account to browse and rent properties, you can submit a request via Profile → Account Settings → Privacy & Security → Delete Face Data or email saferentrwanda@gmail.com.
• Permanent Purge Timeline: Following an account deletion or face data deletion request, all facial verification photos, ID documents, and associated records are permanently, irreversibly deleted and purged from all active databases and secondary backup systems within thirty (30) calendar days.

7. User Rights under Rwandan Data Law Nº 058/2021

Under Law Nº 058/2021 of 13/10/2021 relating to the protection of personal data and privacy in Rwanda, users possess statutory rights regarding their personal and biometric data, including:

• Right of Access: The right to obtain confirmation and a copy of all personal data held about you.
• Right to Rectification: The right to request correction of inaccurate, incomplete, or outdated personal information.
• Right to Erasure ("Right to be Forgotten"): The right to have personal and facial data deleted when no longer necessary.
• Right to Restriction of Processing: The right to limit the processing of your personal data under specific conditions.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used machine-readable format.
• Right to Object: The right to object at any time to the processing of your data for legitimate reasons.

8. Contact Our Data Protection Team

For any questions, requests, or concerns regarding this Privacy Policy, your face data, or our privacy practices, please contact our Data Protection Officer: