Privacy Policy

Date: 21/08/2024
Updated Date : 06/09/2024

PRIVACY POLICY

This Privacy Policy for Asheba Company Ltd., outlines how we collect, store, use, share and process your information when you interact with our services, including when you:

  • Use the Asheba Company Ltd. mobile application
  • Engage with us through our website, social media, sales, marketing, or events

Questions or concerns? 

Reading this Privacy Policy will help you understand your privacy rights and how we manage your data. If you do not agree with our policies and practices, please refrain from using our services. If you have any questions or concerns, feel free to contact us at +233(0)24200974 

Summary of Key Points

This summary highlights key points from our Privacy Policy. For more detailed information, please refer to the relevant sections in the full Privacy Policy below.

1. What Personal Information Do We Process?
We may collect and process personal information based on how you interact with our services, the choices you make, and the products and features you use. This includes information you provide directly to us. [Learn more]

2. Do We Process Any Sensitive Personal Information?
We may process sensitive personal information with your consent or as permitted by applicable law, but only when necessary. [Learn more]

3. Do We Receive Information from Third Parties?
We may receive information from public databases, marketing partners, social media platforms, and other external sources. [Learn more]

4. How Do We Process Your Information?
We use your information to provide, improve, and manage our Services, communicate with you, ensure security and fraud prevention, and comply with legal obligations. We only process your information when we have a valid legal reason to do so. [Learn more]

5. In What Situations and with Whom Do We Share Personal Information?
We may share your information with specific third parties in certain situations. [Learn more]

6. How Do We Keep Your Information Safe?
We implement organizational and technical measures to protect your personal information. However, please note that no method of electronic transmission or storage is 100% secure. [Learn more]

7. What Are Your Rights?
Depending on your location, you may have certain rights regarding your personal information under applicable privacy laws. [Learn more]

8. How Can You Exercise Your Rights?
You can exercise your rights by submitting a data subject access request or contacting us directly. We will respond in accordance with applicable laws. [Learn more]

Want to Learn More About Asheba Company Ltd.'s Data Practices?
Please review the full Privacy Policy for a detailed explanation of how we handle your information.

TABLE OF CONTENTS

  1. What information do we collect?
  2. How do we process your information?
  3. What legal bases do we rely on to process your personal information?
  4. When and with whom do we share your personal information?
  5. Do we use cookies and other tracking technologies?
  6. How do we handle your social logins?
  7. Is your information transferred internationally?
  8. How long do we keep your information?
  9. How do we keep your information safe?
  10. Do we collect information from minors?
  11. What are your privacy rights?
  12. Controls for do-not-track features
  13. Do we make updates to this notice?
  14. How can you contact us about this notice?
  15. How can you review, update, or delete the data we collect from you?

 

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us:

In Short: We collect personal information that you provide directly to us.

We collect personal information that you voluntarily provide when you register on our Services, express interest in our products, participate in activities, or contact us directly.

Personal Information Provided by You: The personal information we collect depends on your interactions with us and may include:

  • Names
  • Phone numbers
  • Email addresses
  • Mailing addresses
  • Job titles
  • Usernames
  • Passwords
  • Contact preferences
  • Contact or authentication data
  • Company TIN (Ghana Jurisdiction)
  • Business location

Sensitive Information: When necessary, with your consent or as permitted by law, we may process the following categories of sensitive information:

  • Social Media Login Data: If you register using your social media account details (e.g., Facebook, Twitter), we will collect relevant information as described in the "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" section.

All personal information you provide must be true, complete, and accurate. Please notify us of any changes to your information.

Information Automatically Collected

In Short: We automatically collect certain information when you visit our services.

Some information, such as your IP address and browser/device characteristics, is collected automatically when you interact with our Services. This information does not reveal your specific identity but may include:

  • Log and Usage Data: Service-related, diagnostic, usage, and performance information, such as IP address, browser type, and information about your activity (e.g., date/time stamps, pages viewed, search actions).
  • Device Data: Information about your computer, phone, tablet, or other device used to access our Services, such as IP address, device/application IDs, location, browser type, and system configuration.

Information Collected from Other Sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other external sources.

To enhance our marketing, offers, and services, we may obtain information about you from other sources, such as:

  • Public databases
  • Joint marketing partners
  • Affiliate programs
  • Data providers
  • Social media platforms

This information may include mailing addresses, job titles, email addresses, phone numbers, intent data, IP addresses, social media profiles, and custom profiles for targeted advertising and event promotion. If you interact with us on a social media platform using your account (e.g., Facebook, Twitter), we receive personal information such as your name, email address, and gender, depending on your account's privacy settings.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to deliver, enhance, and manage our services, communicate with you, ensure security and fraud prevention, and comply with legal requirements. With your consent, we may also process your information for other specified purposes.

We process your personal information for various reasons based on your interactions with our Services, including:

  • Account Creation and Management: We process your information to enable account creation, authentication, and account management, ensuring your account functions properly.
  • Service Delivery: We process your information to deliver the services you request and ensure a seamless experience.
  • Customer Support: We process your information to respond to inquiries, provide support, and resolve any issues you may encounter with our Services.
  • Administrative Communications: We process your information to send important details about our products, services, terms, policies, and other relevant updates.
  • Order Fulfillment: We process your information to manage and fulfill orders, including handling payments, returns, and exchanges.
  • User-to-User Communications: We process your information to facilitate interactions between users, where applicable.
  • Feedback Requests: We process your information to request feedback and gather insights on your use of our Services.
  • Marketing and Promotional Communications: With your consent, we process your information to send you marketing and promotional content. You can opt out at any time (see "WHAT ARE YOUR PRIVACY RIGHTS?").
  • Targeted Advertising: We process your information to create and display personalized content and advertisements tailored to your interests and location.
  • Security and Fraud Prevention: We process your information to protect our Services, including monitoring for fraud and ensuring security.
  • Usage Trends Identification: We process information about how you use our Services to better understand usage patterns and improve our offerings.
  • Marketing Effectiveness: We process your information to evaluate and enhance the effectiveness of our marketing and promotional campaigns.
  • Protection of Vital Interests: We process your information when necessary to protect vital interests, such as preventing harm.

 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we have a valid legal basis to do so under applicable law. This includes obtaining your consent, fulfilling contractual obligations, complying with legal requirements, protecting your rights, or pursuing legitimate business interests.

If You Are Located in Ghana:

We collect personal data directly from you unless:

  • The data is publicly available.
  • You have made the data public.
  • You have consented to collection from another source.
  • Collection from another source does not prejudice your legitimate interests.
  • Compliance would harm a lawful purpose of collection.
  • Compliance is impracticable.

If You Are Located in the EU or UK:

Under the General Data Protection Regulation (GDPR), we may rely on the following legal bases to process your personal information:

  • Consent: We may process your information with your permission for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract: We process your information to fulfill our contractual obligations or at your request before entering into a contract.
  • Legitimate Interests: We process your information to pursue legitimate business interests, provided they do not override your rights and freedoms. Examples include:
    • Sending information about special offers and discounts.
    • Developing and displaying relevant advertising content.
    • Analyzing service usage to improve engagement and retention.
    • Supporting marketing activities.
    • Diagnosing and preventing fraudulent activities.
    • Improving user experience.
  • Legal Obligations: We process your information to comply with legal requirements, such as cooperating with law enforcement or regulatory agencies, or disclosing information as evidence in litigation.
  • Vital Interests: We process your information to protect your vital interests or those of others, such as in situations involving potential threats to safety.

If You Are Located in Canada:

We may process your information with your explicit or implied consent. You can withdraw your consent at any time. In some cases, we may process your information without consent if:

  • Collection is clearly in an individual's interest and consent cannot be obtained promptly.
  • It is necessary for fraud detection, prevention, or business transactions.
  • It is part of an insurance claim, witness statement, or necessary to communicate with next of kin.
  • It is related to investigating a breach of agreement or law.
  • It is required to comply with a subpoena, warrant, or court order.
  • It was produced in the course of employment or business and is consistent with the purposes for which it was produced.
  • It is for journalistic, artistic, or literary purposes.
  • The information is publicly available as specified by regulations.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share your personal information in specific situations described in this section and/or with the following third parties.

We may share your personal information in the following circumstances:

  • Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
  • Use of Google Maps Platform APIs: We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API) to provide location-based services.
  • Affiliates: We may share your information with our affiliates. In such cases, we require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: Yes, we may use cookies and other tracking technologies to collect and store your information.

We use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our [Cookie Notice].

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may access certain information about you.

Our services allow you to register or log in using third-party social media account details, such as your Facebook or Twitter logins. When you do this, we may receive certain profile information from your social media provider. This information may include your name, email address, friends list, profile picture, and other details you choose to make public.

We will use this information only for the purposes described in this privacy notice or as otherwise disclosed to you on the relevant Services. Please note that we do not control, and are not responsible for, how your third-party social media provider uses your personal information. We recommend reviewing their privacy notice to understand how they collect, use, and share your information and how you can set your privacy preferences on their platforms.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States and other countries by us and the third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above).

If you are a resident of the European Economic Area (EEA) or the United Kingdom (UK), please note that these countries may not have data protection or other laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will retain your personal information only for as long as necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements). No purpose in this notice will require us to retain your personal information for longer than the period during which you have an account with us.

When we no longer have an ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If deletion or anonymization is not possible (for example, because your personal information is stored in backup archives), we will securely store your personal information and isolate it from further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational measures to safeguard the security of any personal information we process. However, despite our efforts to protect your information, no electronic transmission over the Internet or storage technology can be guaranteed to be 100% secure. Therefore, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security measures and improperly collect, access, steal, or modify your information.

Although we strive to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access our Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of a minor who is using the Services with your consent. If we learn that personal information has been collected from users under 18 years of age, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under 18, please contact us +233(0)24200974

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In certain regions (like the EEA, UK, and Canada), you have specific rights under applicable data protection laws. These may include the right to:

  • Request access to and obtain a copy of your personal information
  • Request rectification or erasure of your personal information
  • Restrict the processing of your personal information
  • Data portability (if applicable)
  • Object to the processing of your personal information in certain circumstances

To exercise any of these rights, please contact us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to file a complaint with your local data protection authority. If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing Your Consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can do so by contacting us using the contact details provided below or by updating your preferences in your account settings. However, withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal.

Opting Out of Marketing and Promotional Communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, replying "STOP" or "UNSUBSCRIBE" to SMS messages, or by contacting us directly. You will be removed from our marketing lists but may still receive service-related communications necessary for your account or other non-marketing purposes.

Account Information: If you would like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account
  • Contact us using the contact information provided

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and comply with applicable legal requirements.

Cookies and Similar Technologies: Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject cookies. If you do so, this could affect certain features or services of our Services. You may also opt out of interest-based advertising through settings in your browser or on your device.

If you have questions or comments about your privacy rights, please email us at +233(0)24200974. 

12. CONTROLS FOR DO-NOT-TRACK FEATURES

In Short: We do not currently respond to DNT signals as there is no uniform standard for online tracking.

Most web browsers and some mobile operating systems and applications include a Do-Not-Track ("DNT") feature that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. However, since no uniform technology standard for recognizing and implementing DNT signals has been finalized, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

What categories of personal information do we collect?

We have collected the following categories of personal information within the past twelve (12) months:

CategoryExamplesCollectedA. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

 

YES

B. Personal information categories listed in the California Customer Records statuteName, contact information, education, employment, employment history, and financial information

 

YES

C. Protected classification characteristics under California or federal lawGender and date of birth

 

YES

D. Commercial informationTransaction information, purchase history, financial details, and payment information

 

YES

E. Biometric informationFingerprints and voiceprints

 

YES

F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

 

YES

G. Geolocation dataDevice location

 

YES

H. Audio, electronic, visual, thermal, olfactory, or similar informationImages and audio, video or call recordings created in connection with our business activities

 

YES

I. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

 

YES

J. Education InformationStudent records and directory information

 

YES

K. Inferences drawn from other personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

 

YES

L. Sensitive Personal InformationAccount login information, biometric data, contents of email or text messages, debit or credit card numbers, drivers' licenses, genetic data, health data, passport numbers, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, social security numbers, state id card numbers and union membership
YES

We will use and retain the collected personal information as needed to provide the Services or for the following categories:

  • Category A: As long as the user has an account with us
  • Category B: As long as the user has an account with us
  • Category C: As long as the user has an account with us
  • Category D: As long as the user has an account with us
  • Category E: As long as the user has an account with us
  • Category F: As long as the user has an account with us
  • Category G: As long as the user has an account with us
  • Category H: As long as the user has an account with us
  • Category I: As long as the user has an account with us
  • Category J: As long as the user has an account with us
  • Category K: As long as the user has an account with us
  • Category L: As long as the user has an account with us

Note: Category L may be used or disclosed to a service provider or contractor for additional specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

Other Personal Information

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail, including but not limited to:

  • Receiving help through our customer support channels
  • Participation in customer surveys or contests
  • Facilitation in the delivery of our Services and responding to your inquiries

The information we collect, use, and disclose about you will vary depending on how you interact with Asheba Company Ltd. and our Services. 

For more information, please visit the following links:

  • [Personal Data We Collect]
  • [How We Use Your Personal Data]
  • [When and With Whom We Share Your Personal Data]

Your Rights with Respect to Your Personal Data: 

As a Virginia resident, you have the following rights:

  • Right to be informed about whether we are processing your personal data.
  • Right to access your personal data.
  • Right to correct inaccuracies in your personal data.
  • Right to request deletion of your personal data.
  • Right to obtain a copy of the personal data you previously shared with us.
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

Asheba Company Ltd. does not sell personal data to third parties for business or commercial purposes and will not do so in the future for website visitors, users, or other consumers.

Verification Process

To protect your privacy, we may request additional information to verify your identity before fulfilling your request. If an authorized agent is submitting the request on your behalf, we may need further verification to confirm your identity.

Response Timeframe

Upon receiving your request, we will respond without undue delay, within forty-five (45) days of receipt. If necessary, we may extend the response period by an additional forty-five (45) days, and we will inform you of the extension within the initial 45-day period.

Right to Appeal

If we decline to take action on your request, we will inform you of our decision and provide the reasoning. If you wish to appeal our decision, please email us at +233(0)24200974. We will respond to your appeal within sixty (60) days of receipt, explaining our actions or lack thereof. If your appeal is denied, you may contact the Attorney General to submit a complaint.

How Do We Use and Share Your Personal Information?

You may contact us by email at +233(0)24200974 or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will Your Information Be Shared with Anyone Else?

We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

Asheba Company Ltd. has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Asheba Company Ltd. will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights with Respect to Your Personal Data

Right to Request Deletion of Data — Request to Delete

You have the right to request the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of their right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to Be Informed — Request to Know

Depending on the circumstances, you have the right to know:

  • Whether we collect and use your personal information;
  • The categories of personal information that we collect;
  • The purposes for which the collected personal information is used;
  • Whether we sell or share personal information to third parties;
  • The categories of personal information that we sold, shared, or disclosed for a business purpose;
  • The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
  • The business or commercial purpose for collecting, selling, or sharing personal information; and
  • The specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

If the business collects any of the following:

  • Social security information, driver’s licenses, state ID cards, passport numbers
  • Account login information
  • Credit card numbers, financial account information, or credentials allowing access to such accounts
  • Precise geolocation
  • Racial or ethnic origin, religious or philosophical beliefs, union membership
  • The contents of email and text, unless the business is the intended recipient of the communication
  • Genetic data, biometric data, and health data
  • Data concerning sexual orientation and sex life

You have the right to direct that business to limit its use of your sensitive personal information to that which is necessary to perform the Services.

Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for additional purposes.

Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as publicly available information.

To exercise your right to limit use and disclosure of sensitive personal information, please email  +233(0)24200974.

Verification Process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match it with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for verification purposes. However, if we cannot verify your identity from the information already maintained by us, we may request additional information for verification and security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other Privacy Rights

  • You may object to the processing of your personal information.
  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
  • You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us at +233(0)24200974 or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

13. Do We Make Updates to This Notice?

In Short: Yes, we update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by a revised "Effective Date" and will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you by prominently posting a notice of such changes or by sending you a direct notification. We encourage you to review this privacy notice regularly to stay informed about how we protect your information.

14. How Can You Contact Us About This Notice?

If you have any questions or comments about this notice, contact us at +233(0)24200974.

15. How Can You Review, Update, or Delete the Data We Collect from You?

Depending on the applicable laws of your country, you may have the right to request access to, change, or delete the personal information we collect from you. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

 

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