1. SCOPE

This Privacy Policy explains information we collect from users of the Propartners site. It also has information on how we store, use, transfer and delete information collected from users, as well as the rights of the data subject. As a matter of transparency, we aim, not only to comply with the provisions of the Data Protection Act, 2012 (Act 843), but to earn your trust as a brand in partnership with you.

2. LEGAL BASIS FOR DATA PROCESSING

To the extent that we obtain consent from the data subject for the processing of personal data within the remits of the law, as enshrined in Article 18 of the 1992 Constitution of Ghana as the right to privacy, and under Section 17 of Act 843, which states that the processing of a subject’s data must be done within the tenets of accountability, lawfulness of processing, specification of purpose, compatibility of further processing with purpose of collection, openness, data safeguards, data subject participation etc., and Section 20 of same Act which also provides, among others, that a subject’s data shall only be processed when such data is necessary for the purpose of contract to which the subject is party, to protect legitimate interest of data subject.

3. INFORMATION OBTAINED WITH SUBJECT’S CONSENT

As a matter of principle, whenever you sign up to access the Propartners site, you give us certain information voluntarily. This information includes your name, email address, primary phone number, location and any such information you give us the permission to obtain. An exception applies in cases where it is not possible to obtain prior consent for factual reasons and where the processing of data is within the ambits of the law.

In this regard, we may obtain certain personal information to enable us identify an individual, but which does not include information that is encoded, or any publicly available information that has not been combined with non-public information. Or, certain sensitive personal information that extends from mere personal information level to issues like a data subject’s race, ethnic origin, political opinions, religious beliefs, health and sex life (in some cases) and some other rather ‘sensitive’ personal information.

4. INFORMATION COLLECTION AND USE

ProPartners does not collect data to advertise to users of its site. Rather, to help us serve you better, we gather these information from your interaction with our sites. Besides the information you willingly give us, we may obtain other information as already stated in Point 3 (information obtained with your consent), based on actions you take while on the ProPartners website such as what pages you access and to which of our products and services you react. These information are a combination of your Internet Protocol (IP) address, your interactions on the site, your location, information about your personal device (and/or browser type), your internet service provider, and your referral information.

We use this information for the following reasons:

• To provide, test, improve, promote and personalize Propartners services to you because we are committed to showing you only content that is interesting, relevant and personal to you
• To fight spam and other forms of cyber abuse
• Generate non-identifying information about how users engage with Propartners products and services.

5. STORAGE OF INFORMATION

Personal data of data subject shall be deleted or blocked as soon as the purpose for storing such data no longer applies. Storage beyond such a period can be effected, though, if such storage is prescribed by the Data Protection Act, 2012, as provided under Section 24 of the Act, or to the provisions of any other relevant legislation(s) which the data subject is subject to.

The temporary storage of the IP address by the system is necessary to facilitate delivery of the website to the computer of the user. To do so, the IP address of the user must remain stored for the duration of the session. Storing of log-files is effected to ensure the functionality of the website. In addition, such data helps us to optimize the website and to ensure the security of our information technology systems. An analysis of such data for marketing purposes will not be carried out in this context.

• DURATION OF STORAGE AND DELETION OR BLOCKING OF DATA SUBJECT’S DATA

The data will be deleted as soon as they are not needed any more for the purpose that they have been gathered for.

When the storage of the data is in log-files this storage may take up to a maximum of seven days. A longer storage is possible, however. In this case the IP-addresses of the user will be deleted or anonymized so it is no longer possible to assign such data to the user.

Blocking or deletion of data is also effected if a storage period expires that is prescribed by the cited industry standards and relevant legislations, unless there is a requirement for further storage of such data to enter into a contract or to execute a contract, as stated under Section 24(1)(c) of Act 843.

6. OPTION FOR OBJECTION TO DATA COLLECTION

Collection of data for the provisioning of the website and storage of same in log-files, is required for the operation of the web page. Consequently, a user has no right to object to their personal information being taken, once they sign up to access the ProPartners site.

7. USAGE OF COOKIES

We use cookies to make our website more user-friendly. Some elements of our web page require that the accessing browser can also be identified when the user moves from one page to the next. No personal data is collected in the process.

To help us track our users’ interactions on the site, the following files are stored and transmitted in the cookies:

fonts = standard cookie variable used by ProPartners to reload the fonts in the browser after a page refresh.

fullcss = standard cookie variable used by us to reload the CSS file in the browser after a page refresh.

Maximum cookie lifetime: 730 days.

Furthermore, we use cookies on our website which enable the analysis of surfing behavior of the user. This way the following data can be transmitted:

_ga = one-time identifier of Google Analytics to identify the user (consists of ClientID + time stamp) | standard expiration time 2 years

_gat = parameter which makes Google Analytics to reduce the polling rate

_gid = one-time identifier of Google Analytics to identify the user (consists of ClientID + time stamp) | standard expiration time 24 hours

The data that is collected this way is anonymized through technical precautions. Therefore, the data cannot be matched to the user anymore. When opening the website, the user will be informed by an info banner about the usage of cookies for analytical purposes and will be referred to the data protection regulation. In this context there is also the indication how the storage of cookies can be prevented by changing the browser settings. In case you wish to not be tracked, you can deactivate this function in the paragraph Google Analytics in this privacy policy (see below).

• DURATION OF STORAGE AND OPTION FOR REMOVAL AND OBJECTION

Cookies are stored by the computer of the user and then are transmitted from this computer to our end. Therefore a user has full control over the use and processing of cookies. By changing the settings in their internet browser, they can deactivate or limit the transmission of cookies. Cookies that have already been saved can be deleted again at any time. This can also be done automatically. If cookies have been deactivated for our website, it is possible that not all features of our website can be used to their full extent.

8. SOCIAL MEDIA SHARE BUTTON

Social media plugins usually cause every visitor of a page to be immediately tracked by these services with their IP address and their other browsing behavior logged. This can be done even if you do not press the button. To prevent this, we use the Shariff method. In doing so, the direct contact between the social network and you will not be established by our social media buttons until you click on the respective share button. If you are already logged in to a social network, this will be done on Facebook and Google+ without another window. On Twitter, a pop-up window appears where you can still edit the tweets text. You can publish our content on social networks without them being able to create complete surf profiles.

9. RIGHTS OF DATA SUBJECT
10. Under the Data Protection Act, 2012, a subject user has the following rights:
11. A data subject has the right to know that their information is being taken.

1. Also, a data subject has the right to obtain information about the data stored about them. Again, if incorrect personal information are processed, the data subject is entitled to a correction for the collector of the information. If the legal prerequisites exist, subject may request the deletion or limitation of the processing and appeal against such information processing.
2. Subject data has the right to be communicated to in an intelligible form with regards to the information being taken and the reasoning and logic behind the processing of such personal information.
3. All other rights of the data subject enshrined in Section 35 of Act 843.

CONTACT

For any further enquiries, please do contact us at our office, ProPartners Exchange Limited, Venees House, Kpakpo Wulu Street, Accra, Ghana.

Or, find us on our digital address GZ-0245257,

Or reach out to us through our postal address, P.O. Box CT 9625, Cantonments, Accra.

Also, you may find us on Facebook, Instagram, Twitter and YouTube @ProPartners Ghana.