Privacy Policy

(Last Updated: September, 2022)

Petra Securities Limited (“PSL”, “we”, “us” or “our”) is committed to protecting the privacy of personal information (i.e. any information relating to an identified or identifiable natural person) who accesses the https://theachieveproject.com website and Achieve mobile software application (collectively, the “Site”). Amendments to this Privacy Policy will be posted to the Site and will be effective when posted. Your continued use of the services on the Site following the posting of any amendment to this Privacy Policy shall constitute your acceptance of such amendment.

This Privacy Policy shall be read in conjunction with the Data Protection Act, 2012 (Act 843) and where there is any inconsistency between this Privacy Policy and the Data Protection Act, 2012 (Act 843), the Data Protection Act, 2012 (Act 843) shall prevail.

Consent and Information Collection and Use

When you register as a user of our Site, we ask for personal information that will be used to activate your account, provide the services on the Site to you, communicate with you about the status of your account, and for other purposes set out in this Privacy Policy. Your name, address, mobile number, email address, mobile money account information, personal image files for the purposes of identity verification as required by law, and other information about you may be required by us or may be disclosed by you during your use of the Site. You may be required to enable access to your contact list or phone address book when performing certain activities on the Site. E.g. When withdrawing from your investment account to pay to a third-party. You will also be required to add an email address as a user name and a private password, which will become part of your account information.

By providing personal information to us and by retaining us to provide you with the services on the Site, you voluntarily consent to the collection, use, and disclosure of such personal information as specified in this Privacy Policy. The legal bases for our processing of your personal information is primarily to provide you access to the services of the Site and that the processing is carried out in our legitimate interests, which are further explained below. Without limiting the foregoing, we may on occasion ask you to consent when we collect, use, or disclose your personal information in specific circumstances.

We shall take steps designed to ensure that only our employees and agents who need access to your personal information to fulfil their employment duties will have access to it. We may use and disclose your personal or account information for but not limited to the following purposes:

  • To provide you with services on the Site
  • To improve the quality of the services of the Site through polls, surveys and other similar feedback gathering activities conducted by Petra and/or third parties;
  • To a third-party for further processing for purposes incidental to the use of the Site or the Terms and Conditions;
  • To create, manage and control your account information, and to verify access rights to the Site;
  • To communicate with you (subject to your opt-out rights set forth in this Privacy Policy), including without limitation for the purpose of providing you with information about the services of the Site, or informing you of changes or additions to the services of the Site or of the availability of any other services or features we provide;
  • To assess service levels, monitor traffic patterns and gauge popularity of different features and options of the Site
  • To enforce this Privacy Policy or our Terms and Conditions;
  • To protect against fraud or error, and to respond to claims of any violation of our rights or those of any third parties;
  • To respond to your requests for customer service;
  • To protect the rights, property or personal safety of you, us, our users and the public; and
  • As required to comply with applicable laws or as authorized by applicable laws.

In order to process payments, Achieve utilizes third-party payment gateways who will utilize your mobile money account and other payment information in accordance with their respective privacy policies. Petra shall not be liable to you or any other person for any damages that might result from unauthorized use, publication, disclosure, or any other misuse of such payment information, including mobile money account information.

Petra may share your personal information with product providers/owners via third-party integrations. We invite you to review their applicable data protection policies.

When we disclose your personal information to third parties, we take reasonable measures to ensure that the rules set forth in this Privacy Policy are complied with and these third parties provide sufficient guarantees to implement appropriate technical and organizational measures.

Your personal information may be stored and processed in any country where we have facilities or in which we engage third-party service providers. By using the Site, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of Ghana, it is subject to the laws of the country in which it is held and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Policy and, where applicable, we will comply with the Data Protection Act, 2012 (Act 843) requirements providing adequate protection for the transfer of personal information from Ghana to third countries.

We may occasionally communicate with you regarding our products, services, news, and events. You have the option to not receive this information. We provide an opt-out function within all email communications of this nature, or will cease to communicate with you for this purpose if you contact us and tell us not to communicate this information to you. The only kind of these communications that you may not “opt-out” of are those required to communicate announcements related to the services of the Site, including information specific to your Account, planned services suspensions and outages. We will attempt to minimize this type of communication to you.

Age of Consent

We do not knowingly provide the services of the Site to and will not knowingly collect the personal information from anyone under the age of consent. If you are 18 years or less and not eligible to use the Site, your parent or guardian must agree to our Privacy Policy on your behalf. If you have any concerns about your child’s personal information, please contact us at [email protected].

The Site is intended for people over 18 years of age, and no one under age 18 may provide any personal information to, on or through the Site. We do not knowingly collect personal information from people under 18 and we will not be held responsible for the use of the Site by a person below 18 years. If you are under 18, do not use or provide any information to, on or through the Site, make any purchases through the Site, use any of the interactive or public comment features, or provide any information about yourself to us, including your name, address, telephone number or email address. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at [email protected]

Rights to Your Information

You have the right to access and edit your information at any time through the web interface provided as part of the services of the Site. On written request and subject to proof of identity, you may access the personal information that we hold, used or communicated and ask that any necessary corrections be made, where applicable, as authorized or required by law. However, to make sure that the personal information we maintain about you is accurate and up to date, please inform us immediately of any change in your personal information by mail or e-mail.

Under the Data Protection Act, 2012 (Act 843), you may be entitled to additional rights, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your personal information and certain other supplementary information, once you have provided a proof of identity; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to erasure of personal information about you, under certain conditions; (v) the right to demand that we restrict processing of your personal information, under certain conditions. if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your personal information is inaccurate; (vi) the right to prevent processing of personal data for direct marketing purpose without prior consent from you; (vii) the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the Data Protection Act,2012 you can visit the Data Protection Agency website.

Aggregated Data

We may also use your personal information to generate Aggregated Data for internal use and for sharing with others on a selective basis. “Aggregated Data” means records which have been stripped of information potentially identifying users, and which have been manipulated or combined to provide generalized, anonymous information. Your identity and personal information will be kept anonymous in Aggregated Data.

Links

The Site may contain links to other sites, and we are not responsible for the privacy practices or the content of such sites. We encourage you to read the privacy policy of linked sites. Their privacy policies and practices may differ from our policies and practices.

Cookies and Log Files

We use cookies and log files to track user information. Cookies are small amounts of data that are transferred to your web browser by a web server and are stored on your phone, desktop, or tablet storage. We use cookies to track which page variant a visitor has seen, to track if a visitor has clicked on a page variant, to monitor traffic patterns, and to gauge the popularity of service options. We will use this information to deliver relevant content and services to you.

Change of Ownership or Business Transition

In the event of a change of ownership or other business transition, such as a merger, acquisition or sale of our assets, your information may be transferred in accordance with applicable privacy laws. You shall be notified in the event of any such change.

Security and Retention

We will strive to prevent unauthorized access to your personal information, however, no data transmission over the Internet, by wireless device or over the air is guaranteed to be 100% secure. We have implemented and maintain reasonable security procedures and practices (based on the nature of the information we collect) to protect that information from unauthorized disclosure. We will continue to enhance security procedures as new technologies and procedures become available.

We strongly recommend that you do not disclose your password to anyone.

Please remember that you control what personal information you provide while using the Site. Ultimately, you are responsible for maintaining the secrecy of your identification, passwords, and/or any personal information in your possession for the use of the Site. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the personal information you provide to others through the Site. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through the Site, and you release us from any and all liability in connection with the contents of any personal information or other information which you may receive using the Site. We cannot guarantee or assume any responsibility for verifying the accuracy of the personal information, or other information provided by any third-party. You release us from any and all liability in connection with the use of such personal information or other information of others.

We will maintain your personal information for as long as they are needed, or as required by applicable laws namely the Data Protection Act, 2012 (Act 843), regulations, or government orders.

Changes to this Policy

We may update this Privacy Policy from time to time. If we do so, we will send an email to users subscribed to the App’s News list or provide a prompt in-app. If the change materially affects the treatment of your personal data, and we have your email, but you are not subscribed to our news list, we will send you an email. (You are responsible for ensuring that we have an up-to-date email for this purpose.) Your continued use of the Site shall mean you accept any change or update in the Privacy Policy.

Contact Us

If you have any questions or comments about this Privacy Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside Ghana, we can be reached by email at [email protected].