Legal

Data Protection.

Last updated 26 September 2026In line with Rwanda’s Law N° 058/2021 on the protection of personal data and privacy

Being recognised and remembered is part of the experience at The Rec. That depends on trust. This policy explains what personal data we collect, why, how we protect it and the rights you have over it.

Who we are

The Rec, Gacuriro, Kigali, Rwanda, is the data controller for the personal data described in this policy. We process personal data in line with Law N° 058/2021 of 13/10/2021 relating to the protection of personal data and privacy, and we are registered with the National Cyber Security Authority (NCSA) as required.

Data Protection OfficerEmail privacy@thereckigali.com or write to The Rec, Gacuriro, Kigali, marked “Data Protection”.

What we collect

CategoryExamples
Identity & contactName, email, phone number and country code, preferred contact method, date of birth
MembershipMembership type, add-ons, family and child profiles, start and renewal dates, freeze requests
Bookings & visitsClasses, sessions, reservations, event tickets, check-ins, attendance and no-shows, activity interests
PaymentsAmounts, payment method and reference, receipts. Card and MoMo details are handled by our payment providers, not stored by us.
Health & wellbeingOnly what you choose to share for your safety, such as injuries or conditions relevant to training or treatments, and wellness assessment results
CommunicationsEnquiries, messages via our website, WhatsApp, email or phone, and feedback
Website & appPages visited, device and browser type, and campaign tags (for example UTM parameters)
SecurityCCTV images in public areas of The Rec

Health information is sensitive personal data. We only process it with your explicit consent, or where it’s needed to protect your vital interests, and access to it is strictly limited.

How and why we use it

PurposeLegal basis
Managing your membership, account, bookings and paymentsPerformance of our contract with you
Replying to enquiries and tour requestsSteps you asked us to take before a contract, or consent
Recognising you on arrival and personalising your experienceOur legitimate interest in delivering genuine hospitality
Safety, security, CCTV and incident recordsLegitimate interest and legal obligation
Health information for safe training and treatmentsYour explicit consent
Newsletters, event invitations and offersYour consent, which you can withdraw at any time
Accounting, tax and legal complianceLegal obligation
Improving our services and websiteLegitimate interest, using aggregated data where possible

We do not sell your personal data, and we do not make decisions about you based solely on automated processing.

Who we share it with

We share personal data only where needed, and only with organisations that protect it to the same standard:

  • Service providers acting on our behalf: our CRM and member app, email and SMS providers, WhatsApp Business, payment providers (MoMo, banks, POS and payment link services) and IT and hosting partners. They are bound by written agreements.
  • Partner experiences, such as off-site MindMotion visits or outdoor climbing, only as needed and with your approval.
  • Authorities, where the law requires it.

International transfers

Some of our service providers may store data outside Rwanda. Where this happens, we only transfer personal data as permitted under Law N° 058/2021, with appropriate safeguards and, where required, authorisation from the supervisory authority.

Children’s data

Children do not create their own accounts. Children aged 0–12 and young adults aged 13–17 are linked to a parent or legal guardian’s family account, and the parent or guardian provides consent on their behalf. We collect only what is needed to register, book and keep them safe: name, age, programme, attendance, emergency contacts and any relevant health or learning-support information. We never use children’s data for marketing, and we never publish identifiable photos of children without a parent’s consent.

How long we keep it

  • Member records: for the duration of your membership, plus up to five years for accounting, legal and dispute purposes.
  • Enquiries from non-members: up to 24 months after our last contact, unless you become a member.
  • Payment and tax records: as long as the law requires.
  • CCTV footage: up to 30 days, unless needed for an investigation.
  • Marketing preferences: until you unsubscribe or withdraw consent.

How we protect it

We use appropriate technical and organisational measures, including encrypted connections, access controls by staff role (for example Gym, Memberships & Events, and Superadmin), secure payment processing, staff confidentiality and training, and regular reviews. If a personal data breach is likely to put your rights at risk, we will notify the supervisory authority and, where required, you, within the timeframes set by law.

Your rights

Under Rwandan law, you have the right to:

  • Be informed about how your data is used
  • Access the personal data we hold about you
  • Correct inaccurate or incomplete data
  • Erase your data, where there is no longer a valid reason to keep it
  • Object to processing, including direct marketing
  • Restrict processing in certain circumstances
  • Data portability: receive your data in a commonly used format
  • Withdraw consent at any time, without affecting earlier processing
  • Not be subject to decisions based solely on automated processing

To exercise any of these rights, email privacy@thereckigali.com. We may need to verify your identity, and we will respond within the time the law allows. You can also lodge a complaint with the National Cyber Security Authority (NCSA).

Marketing & communications

We will only send newsletters, invitations and offers if you have opted in. You choose your preferred contact method (WhatsApp, phone or email) and can unsubscribe at any time using the link in our emails, by replying STOP, or through your member account. Service messages about your bookings, payments and membership will still be sent.

Cookies & website data

Our website uses essential storage to make forms and bookings work, and may use analytics to understand how the site is used. Where non-essential cookies are used, we will ask for your consent first, and you can change your choice at any time.

Changes to this policy

We may update this policy to reflect changes in our services or the law. We will notify members of significant changes by email or through the member app. The date at the top shows when it was last updated.

Questions about your data?

Contact our Data Protection Officer at privacy@thereckigali.com