Privacy Policy

Welcome to BoraSpace.

• BoraSpace is a mobile application provided by Mulinga Labs Ltd. Your privacy matters deeply to us. We are committed to protecting your personal information and being transparent about how and why we collect it.

This Privacy Policy explains:

• What personal data we collect
• How we use and share it
• Your rights and choices
• How we keep your data safe
• How we comply with key laws
• By using the BoraSpace mobile application and related services ("Service"), you agree to this Privacy Policy.

Personal Information You Provide

We only collect information necessary for account creation, communication, and use of our core features.

This includes:

Full name

Used to create your profile, personalize your experience, and help therapists identify you when appointments are booked.

Email address

Used for account verification, login, password resets, and important notifications.

Phone number

Used for identity verification and optional SMS notifications or appointment alerts.

Profile information (optional)

Such as profile photo — used strictly for personalization and account identity.

We do not collect sensitive medical records unless you voluntarily provide certain information during interactions.

Automatically Collected Data (Usage Data)

This information helps us improve BoraSpace, diagnose issues, and ensure the Service operates reliably.

We may collect:

Device and operating system information

Helps us optimize the app for different devices.

App activity

Such as screens visited, buttons clicked, and features used. This helps us understand what is working well and what needs improvement.

Technical logs, crash reports, and performance data

Collected automatically through secure analytics to keep the app stable and error-free.

Mobile network information

Ensures proper functioning on different networks.

None of this data is used to personally profile users.

Permissions We Request

BoraSpace only requests permissions necessary for app functionality, and always with your explicit consent.

Camera & Photos

For uploading a profile picture (optional).

Notifications

To send reminders for appointments or important updates.

Microphone

Will be used for audio calls with therapists.

You can revoke any permission at any time through your device settings.

• Your data is used exclusively to provide, improve, and secure the BoraSpace platform. We do not sell your information.

To Provide the Core Service

We use your information to:

• Create and manage your account
• Enable booking with verified therapists
• Ensure smooth authentication and session continuity
• Send notifications about upcoming appointments or updates
• This is essential for you to use BoraSpace as intended.

To Improve the App & User Experience

We analyze usage patterns to:

• Understand which features users rely on most
• Identify issues or app crashes
• Improve reliability and performance
• Make design changes based on real usage data
• All analytics are processed in aggregated or anonymized form where possible.

To Communicate With You

We may contact you to:

• Send reminders
• Notify you of changes to appointments
• Respond to customer support requests
• Share product updates or new features
• Inform you of policy or security updates
• You can opt out of non-essential communications at any time.

To Keep BoraSpace Safe

We use technical and organizational safeguards to:

• Detect and prevent fraud
• Monitor unauthorized access attempts
• Ensure platform integrity
• Maintain compliance with legal and ethical standards

For Analytics and Insights (Non-Personal)

We analyze aggregated data to:

• Improve system performance
• Monitor growth
• Understand user flow
• Evaluate new features
• This data cannot identify individual users.

• BoraSpace does not sell your personal data. We may share information only in the following cases:

With Service Providers

• We work with trusted third parties (e.g., cloud hosting, analytics). They only receive the minimum data needed, and must follow strict confidentiality and security rules.

Examples include:

• Cloud hosting platforms
• Email delivery providers
• Analytics tools
• Customer support tools

With Therapists (Limited Information Only)

• When you book or interact with a therapist on the platform, they may see:
• Your name
• Your contact information
• Appointment details
• Therapists cannot access information beyond what is necessary for providing services.

For Legal Reasons

We may disclose information if required to:

• Follow law enforcement requests
• Respond to legal obligations
• Protect rights, property, and safety of BoraSpace users

During Business Transfers

• If BoraSpace is acquired or merged in the future, your information may be transferred under strict privacy conditions.

With Your Consent

• Any other sharing requires your clear permission.

• We keep your information only as long as necessary to:
• Provide BoraSpace services
• Meet legal requirements
• Resolve disputes
• Maintain security and fraud prevention
• If you request deletion, your data is permanently erased except where retention is required by law.

• Depending on your location, you may have rights to:
• Access your personal data
• Request corrections
• Request deletion ("right to be forgotten")
• Withdraw consent
• Request a copy of your data
• Restrict certain types of processing
• Opt out of non-essential notifications
• You can manage most of these via app settings or by contacting us.

• You may request full deletion of your account and stored data at any time by contacting support.

We will:

• Authenticate your identity
• Delete your data securely
• Confirm the deletion
• Legal exceptions (e.g., fraud prevention) may require limited retention.

• Your data may be processed outside your home country.

We ensure that all transfers follow:

• Adequate protection measures
• Standard contractual clauses
• Strong encryption
• Privacy-by-design principles

• We apply multiple layers of security, including:
• Encrypted data transmission
• Secure cloud infrastructure
• Access controls and authentication
• Intrusion detection
• Regular audits
• While no digital system is 100% risk-free, BoraSpace uses industry-standard protections.

BoraSpace is not intended for children under 13.

If we learn that a child's data was collected without parental consent, we delete it promptly.

Our app may link to external websites or resources.

We are not responsible for their practices or policies.

• We may update this Privacy Policy periodically.
• Changes will be communicated through:
• This page
• App notifications
• Email (for significant updates)

For privacy concerns, requests, or questions:

• Email: info@mulingalabs.com
• Website: https://mulingalabs.com/contact
• Phone: +250 782 251 664

This section explains how BoraSpace aligns with major privacy laws.

Rwanda – Data Protection & Privacy Law (Law No. 058/2021)

We comply with key principles such as:

Lawful and Fair Processing

We only process personal data to provide services, improve the app, and meet legal obligations.

Explicit Consent

Permissions and sensitive operations require clear user approval.

Transparency

Users are informed of all data practices.

Data Minimization

We collect only what is needed — nothing more.

Users' Rights

Rwanda DPA supports rights to access, correct, or request deletion of data.

Security and Safeguards

We implement organizational and technical security controls to protect data.

Regulated Data Transfers

Cross-border transfers follow required safeguards and legal basis.

GDPR (EU)

BoraSpace aligns with major GDPR requirements including:

Lawful Basis for Processing

Most processing is based on consent and legitimate interest.

Right to Access & Portability

Users may request a copy of their data.

Right to Erasure

Deletion can be requested at any time when no legal retention applies.

Data Protection by Design

Security and privacy safeguards exist throughout the system.

Transparency & Control

Clear privacy explanations, easy settings, and consent management.

Processor & Sub-processor Controls

All partners follow strict GDPR-compliant contracts.

CCPA (California)

For California residents, BoraSpace supports:

Right to Know

Users may request details about what data is collected and how it is used.

Right to Delete

Users may request deletion of their personal data.

Right to Opt Out of Data Sale

We do not sell personal information.

Right to Equal Service

Users exercising privacy rights will not be discriminated against.

Clear Disclosures

We provide visible, easy-to-understand privacy notices.