This privacy notice will inform you as to how we look after your personal data when you interact with us and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This Privacy Statement explains how GNSW may collect, share, use, and protect information when you visit or use any digital services offered by the platform. This Privacy Statement covers the programs’ many, including affiliate websites, online and mobile services, branded social media sites or pages as well as any interactions you may have while viewing content provided through one of the programs’ digital advertising campaigns.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
We reserve the right to modify or affix the Terms, unilaterally, at any time and without prior notice, of which all users of the platform shall be duly informed by means of an appropriate notice on the GNSW Website. You are obliged to review the Terms periodically, in order to check for possible modifications or additions. By using the platform after modifications or additions to these Terms have been made, you fully acknowledge, understand and accept the content thereof. Furthermore, we reserve the right to modify the content, design or location of the site, as well as the services, materials, functionalities and other content available through the Websites, unilaterally, at any time and without prior notice. We cannot be held responsible for any damage caused to users or third parties related to the above described modifications.
Please refer to the contact and address information provided at the bottom of this page.
It is prohibited to publish, transmit, upload or exchange any content or data violating the current laws of the Republic of Ghana and European Union, particularly the content/document that is false, deceptive, offensive, vulgar, threatening, racist or chauvinist, the content violating intellectual property rights, the content considered as unauthorized disclosure of personal data or as violation of the right of privacy of users or third parties, as well as any other content which may cause damage to GNSW, other users or third parties (“Prohibited Content”).
This platform contains web pages and sections intended for interaction with or between users in a manner which enables transmitting, uploading, publishing, exchanging and mutual use of information, comments, reviews, recommendations, opinions, attitudes and other possible content, as well as other ways of participating in the functionalities, services and other content available through the Platform (hereinafter: Interactive Content). Access to some parts of the Interactive Content, their provision or use are granted only to registered users. Interactive content shall be duly marked, whenever this is enabled by the manner of its publication or use.
The publication of Interactive Content on the Platform does not mean that we endorse, approve, recommend, promote or in any other way support the information, statements or facts, attitudes, opinions, or conclusions contained therein.
We reserve the right to supervise Interactive Content that is publicly available, as far as this is possible given the manner of its publication and use. However, we shall not control or consistently supervise all Interactive Content and therefore we cannot guarantee the accuracy, truthfulness, origin, contents or availability thereof.
For any comments or information regarding the Interactive Content, please contact us via the contact information provided at the bottom of this page. We are obligated to remove any illegal Interactive Content immediately upon receipt of the corresponding notice. Furthermore, we reserve the right, but do not assume the obligation, to change, remove or refuse to publish any Interactive Content, completely or partially, without prior notice and without explanation, based on our own assessment or on information received by any user or third party, due to any reason, but primarily due to violation of these Terms.
In consequence of the above, we cannot be held responsible for possible damage caused to users or third parties regarding publishing or failure to publish, removing, using, or relying on any Interactive Content.
Your duty to inform us of changes.It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
For any comments or information regarding the Links please contact us via the contact information provided at the bottom of this page. We are obligated to remove any Link containing or referring to Prohibited Content immediately upon receipt of the corresponding notice. Furthermore, we reserve the right, but do not assume the obligation, to remove any Link, without prior notice and without explanation, based on our own assessment or on information received by any user or third party, for any reason, but primarily due to violation of these Terms.
In consequence of the above, we cannot be held responsible for possible damage caused regarding publishing, removing, or using any Link, or relying on any content available via the Link
2. The data we collect about you
Personal data, or personal information, means any information about an individual or business entity from which that entity can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes Business name, trade name, first name, maiden name, last name, TIN or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes contact address, warehouse address, email address, telephone numbers or any other contact information.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about trade supply chain transactions and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Profile Data includes your username and password, services requested by you, your interests, preferences, and feedback and survey responses.
- Usage Data includes information about how you use our website, tools, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you in accordance with the provisions of the European Union General Data Protection Regulation (EU GDPR) and other regulations in force in the Republic of Ghana (i.e. the Ghana Data Protection Act 2012 (Act 843)) through:
- Direct interactions. You may give us your Identity, Contact, Transaction and Financial Data by filling in forms, by corresponding with us by post, phone, email or otherwise, or during a visit to one of our offices. This includes personal data you provide when you:
- create an account with us;
- apply for a service onsite, online or by any digital means;
- register your financial information or credit card;
- subscribe to our newsletter;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- interact with us on social media; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- Search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and trade supply chain services.
- Identity and Contact Data from data brokers or aggregators.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you have consented for us to do so.
You have the right to withdraw consent to marketing at any time by contacting us via our contact information.
Purposes for which we will use your personal data
We use the information discussed above in a number of ways:
- To register you as a new user
- Processing applications and transactions;
- Verifying your identity (such as when you access your account information);
- Preventing fraud and enhancing the security of your account or our Online Services;
- To manage our relationship with you which will include communicating products or services update to you.
- Responding to your requests and communicating with you;
- Managing your preferences;
- To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- Performing analytics concerning your use of our Online Services, including your responses to our emails and the pages and advertisements you view;
- Providing you tailored content and marketing messages;
- Operating, evaluating and improving our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions);
- Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies; and
- For any other purposes that we may specifically disclose at the time you provide or we collect your information.
Your personal data are processed only on the basis of your approval a free and express consent to process your personal data for the purposes related to the use of the Content available through the Websites. Your consent for the collection and processing of your personal data for a given purpose shall be requested when completing the appropriate form published on the Websites.
All collected data are electronically stored, and appropriate measures and procedures are applied in order to prevent unauthorized access, maintain the level of personal data protection, and use the data collected online in an appropriate manner.
Disclosure of Personal Data
Even though we take all appropriate measures to ensure against unauthorized disclosure of your personal data, we cannot guarantee that some of the collected personal data shall never be disclosed in a manner that is not in accordance with these Terms. Accidental disclosure may be, for example, a consequence of false misrepresentation when accessing websites that contain such data, with the purpose of correcting possible errors in the data. Our liability shall be limited, to the fullest extent permitted by law, for any damage caused to users or third parties relating to accidental disclosure of personal data.
Modifications and deletion of personal data
You are legally entitled to request modification or deletion of your personal data, or deletion from the registered user database at any time. Modification or deletion of data shall be effected on the basis of an appropriate notice addressed to the contact identified on the Websites.
A cookie is a group of data serving as your anonymous individual identifier that is sent to your browser by websites. Cookies are sent when you access a website, they are stored in your computer and they serve to record information about your subsequent online visits. Therefore, after a cookie has been stored on your computer during your first access to a website, every time you return to the website it will look for its cookie in order to read the stored data.
Since a cookie is an anonymous individual identifier, it does not contain or send any personal information to the website that stored it on your computer, but only enables faster and more efficient activation of information, data and settings previously communicated during access and use of the website.
Your browser is set in such a way that each website can only access its own previously sent cookies, but not the cookies of other websites.
The Options or Settings menu of your browser allows you to select an appropriate option for receiving cookies, even to disable them completely. However, disabling cookies completely will reduce the efficiency of some content available on some websites.
You can unsubscribe from any type of GNSW’s email messages by clicking the unsubscribe link in the footer of an email.
Should you believe that any personal data we hold on you is incorrect or incomplete, you have the right to request to see this information, rectify it, or have it deleted. To exercise these rights, please contact our support team.
In the event that you wish to lodge a complaint about how we have handled your personal data, please contact our support team. We will then look into your complaint and work with you to resolve the matter.
If you still feel that your personal data has not been handled appropriately according to the law, you can contact the Ghana National Data Protection Authority and file a complaint with them.
Disclosures of your personal data
We may share the information we collect from and about you with other third parties. For example, we may share your information with:
- Our third-party service providers, but no financial information will be shared in this case;
- Affiliated websites and businesses in an effort to bring you improved service across our family of products and services, when permissible under relevant laws and regulations;
- We may share anonymous or aggregated information with third parties to help deliver products, services, and content that is tailored to the users of our Online Services and for other purposes.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Changes to this Online Privacy Statement
We may change this Online Privacy Statement at any time in the future. When we do, we will let you know by appropriate means such as by posting the revised statement on this page with a new “Last Updated” date. Any changes to this Online Privacy Statement will become effective 30 days after being posted or on such date as is permitted by the relevant authorities. You agree to revisit this page regularly and your continued access to or use of the website will mean that you agree to the changes.
These Terms shall be governed and construed in accordance with the laws of the Republic of Ghana and European Union, without regard to its conflict of law provisions.
Our failure to enforce any right or provision of these Terms will not be considered a waiver of those rights. If any provision of these Terms is held to be invalid or unenforceable by a court, the remaining provisions of these Terms will remain in effect. These Terms constitute the entire agreement between us regarding our Websites and supersede and replace any prior agreements we might have between us regarding the Websites.
Last Updated 08 November 2018