Draft publication date: 23 October 2026. Data storage locations, registration status, retention schedule and privacy contact require operational approval.
1. Who is responsible
Empire Ventures operates the Empire Suites & Villas website and determines why the information described here is used. The exact registered legal entity name and contact details for privacy requests must be confirmed before publication. Until then, contact concierge@empire.rw and identify your message as a privacy request.
2. Information we handle
- Booking and account information: name, email, phone number when provided, account credentials handled by the reservation service, guest count, residence, dates, booking reference, request notes and reservation status.
- Concierge requests: contact information, selected service, residence, preferred date and time, party size, reservation reference and details you choose to provide.
- Property partnership inquiries: services requested, property type and approximate location, size and condition, rental status, preferred model and timeline, photos you choose to upload, contact details, preferred contact method and any notes. Submitted applications are stored in Regent for authorized Empire Ventures property administrators to review; uploaded property photos are stored in private file storage. The exact storage region and retention period are still subject to operational approval.
- Website and security information: technical request information such as IP address, browser and device information, and server security logs where generated by hosting or service providers.
- Display preferences: your chosen currency and cached exchange rates stored in your browser’s local storage.
Please do not include identity documents, payment-card details, health information or other sensitive personal information in free-text fields unless we specifically ask for it through an approved secure channel. When Functional preferences are enabled, early answers in the Work With Us questionnaire may be kept in this browser tab's session storage to restore your draft after refresh. Contact details and uploaded photos are not included; the tab-scoped draft is removed when Functional permission is withdrawn or the inquiry succeeds.
3. Why we use it
We use information to respond to your questions, check requested stay dates and rates, create and manage reservation requests, provide account and booking functions, coordinate concierge requests, maintain site security, and meet applicable legal obligations. We rely on steps requested before a contract, performance of a reservation relationship, legal obligations, legitimate interests in operating and securing the site, or consent where consent is the appropriate basis. Optional cookies are not currently used.
4. Where information goes
Booking, account and property partnership inquiry details are sent to the Regent API used by this site. Partnership photos are kept in private storage and made available only to authorized Empire Ventures property administrators. The API and storage are hosted under Supabase’s service domain; the deployment and storage regions and applicable transfer safeguards must be verified. The website is hosted on Netlify, which may process technical request data. Concierge request details are sent to the configured concierge endpoint and its authorized recipients; that destination and provider must be confirmed. Contact links that open your email application are handled by your chosen email provider.
The currency conversion request sends only the Rwandan franc base and requested currency codes to Frankfurter; it does not include booking details or account information. No payment-card data is collected by the website’s booking form.
5. Storage and international transfers
Information may be processed by service providers involved in hosting and reservation operations. Before publication, Empire Ventures must verify where each provider stores and accesses personal information, the transfer mechanism and safeguards, required authorizations or registration, and the written processor/transfer agreements. We do not claim that all data remains in Rwanda.
6. Retention
We retain information only for as long as necessary for the purpose for which it was collected, to administer reservations and accounts, meet legal or accounting obligations, resolve disputes, and protect the service. Specific retention periods for account, inquiry, reservation and security records have not been confirmed for this website and must be approved in a written retention schedule before publication.
7. Your choices and rights
Subject to applicable law, you may ask us for information about processing and a copy of your data, request correction, erasure or restriction, object to processing, request portability where applicable, and withdraw consent where processing relies on consent. Withdrawal does not affect processing already lawfully carried out. Contact concierge@empire.rw with “Privacy request” in the subject. We may need to verify your identity before responding.
You may also contact Rwanda’s Data Protection and Privacy Office (DPO) through dpo.gov.rw or use its published complaint process. This policy does not restrict any right available under Law No. 058/2021.
8. Security
We use technical and organizational safeguards appropriate to the information processed. Account session cookies are HttpOnly, SameSite=Lax and Secure in production. No online payment is taken by the current booking form. No internet transmission or storage method is completely secure.
9. Children
This website is intended for adults arranging accommodation. A parent or guardian should contact us where a request concerns a child’s personal information.
10. Updates and contact
We may update this policy to reflect changes in our operations or legal requirements. The date at the top identifies this draft’s latest revision. For privacy questions, write to concierge@empire.rw.
11. Legal framework
This policy is drafted with reference to Rwanda’s Law No. 058/2021 of 13 October 2021 relating to the Protection of Personal Data and Privacy. It is an operational draft and is not a substitute for review by qualified Rwandan counsel and the designated privacy officer.