Privacy Policy
Effective Date: 20 May 2024
This Privacy Policy describes how Impulsejunction (“we”, “our”, “us”) collects, uses, and protects personal data when you interact with impulsejunction.com, participate in our services, or engage with our team. We comply with Ghana’s Data Protection Act 2012 (Act 843) and related regulations.
1. Data Controller
Impulsejunction is the data controller for personal data collected through our website and service engagement. Contact information:
- Address: 14 Independence Avenue, Accra, Ghana
- Email: [email protected]
- Phone: +233 24 911 8224
2. Personal Data We Collect
We collect personal data directly from you and through analytics tools. Categories include:
- Contact Information: Name, phone number, email address, organisation details.
- Engagement Data: Notes from consultations, questionnaires, and financial habit assessments.
- Technical Data: IP address, browser type, device information, and pages visited.
- Communications: Emails, feedback forms, and phone call summaries.
3. Lawful Basis for Processing
We process personal data on the following bases:
- Consent: When you submit forms or opt into receiving materials.
- Contract: To deliver services you request and manage related activities.
- Legal Obligation: To comply with Ghanaian laws and regulatory requirements.
- Legitimate Interest: To improve services, secure our systems, and respond to inquiries.
4. Use of Personal Data
We use personal data to:
- Respond to inquiries and schedule consultations.
- Deliver budgeting and financial habit services tailored to your needs.
- Send administrative updates, session summaries, and resource materials.
- Analyse website usage to improve content and navigation.
- Ensure compliance with legal and regulatory obligations.
5. Data Sharing
We do not sell personal data. We may share data with:
- Service providers assisting with website hosting, analytics, or communication tools.
- Professional advisors such as legal or compliance consultants when necessary.
- Authorities when required by law or to protect our rights.
All third parties are bound by confidentiality and data protection obligations.
6. International Transfers
We primarily store data in Ghana. If data is transferred outside Ghana, we ensure adequate safeguards such as contractual clauses or reliance on service providers with appropriate certifications.
7. Data Retention
We retain personal data only as long as needed for the purposes described or as required by law:
- Inquiry records: Up to 24 months.
- Client engagement records: Up to 7 years after service completion.
- Technical logs: Typically 12 months, unless required longer for security analysis.
8. Your Rights
Under Ghanaian law, you have the right to:
- Access personal data we hold about you.
- Request corrections for inaccuracies.
- Withdraw consent where processing is based on consent.
- Request deletion of data subject to legal obligations.
- Object to processing for direct marketing or where legitimate interests are cited.
To exercise these rights, contact us at [email protected]. We respond within 30 days.
9. Security Measures
We implement technical and organisational safeguards, including encrypted storage, access controls, staff confidentiality agreements, and regular security reviews.
10. Cookies
Our website uses essential, performance, and analytics cookies. Details are provided in our Cookie Policy. You can manage preferences via browser settings or the cookie banner.
11. Children’s Privacy
We do not knowingly collect personal data from individuals under 16 without guardian consent. If you believe data about a child has been provided without consent, contact us to remove it.
12. Changes to This Policy
We may update this policy to reflect operational or legal changes. Updates will be posted on this page with a revised effective date.
13. Complaints
If you have concerns, contact us first. You may also lodge a complaint with the Data Protection Commission of Ghana.