Privacy Notice

Effective Date: 5 April 2024

Gridlumen (“we”, “our”, “us”) respects your privacy and is committed to protecting the personal data we handle while guiding you through financial planning frameworks. This notice describes how we collect, use, disclose, and safeguard personal information in line with the Ghana Data Protection Act, 2012 (Act 843) and other applicable regulations.

1. Data Controller and Contact

Gridlumen operates from 12 Adabraka Street, Accra, Ghana. We act as the Data Controller for information processed through this website and during service engagements.

2. Information We Collect

We collect personal data only when it is necessary to respond to enquiries, deliver services, or maintain secure online platforms.

  • Contact Data: Name, phone number, email address, and location provided via forms or direct correspondence.
  • Engagement Data: Financial details voluntarily shared during consultations, including income, expenses, goals, and supporting documentation.
  • Technical Data: IP address, browser type, device identifiers, and access logs collected through our hosting stack and Cloudflare to maintain security.
  • Usage Data: Pages visited, time spent, referring URLs, and interaction metrics captured through privacy-conscious analytics.

3. How We Use Personal Data

Personal data is processed for clearly defined purposes:

  • Answering enquiries and scheduling consultations.
  • Preparing financial planning frameworks tailored to client needs.
  • Maintaining secure access to shared dashboards and documentation.
  • Improving our services through aggregated analytics and research.
  • Complying with legal obligations and assisting with tax or regulatory enquiries when lawfully requested.

We rely on consent, performance of a contract, and legitimate interest as our legal bases for processing personal data.

4. Data Sharing and Disclosures

We do not sell your personal data. We share information only when necessary:

  • Service Delivery: With your explicit approval, we may collaborate with accountants or advisors you nominate.
  • Infrastructure Providers: Our website and document portals are protected by Cloudflare, which processes technical logs for security, caching, and performance.
  • Legal Compliance: We may disclose data to regulators or law enforcement agencies if required by Ghanaian law or applicable court orders.

5. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined above:

  • Contact enquiries are retained for up to 12 months for follow-up and audit purposes.
  • Financial engagement data is retained for the duration of the project and securely archived for up to 120 days after completion, unless you request deletion or regulatory requirements dictate otherwise.
  • Technical logs held by Cloudflare may be retained for periods defined in their policies, typically no longer than 12 months.

6. International Transfers

Our website uses hosting and security services that may store data in locations outside Ghana. Whenever data leaves Ghana, we ensure that appropriate safeguards such as contractual clauses and encryption are in place.

7. Data Security

We implement technical and organisational measures to protect personal data:

  • Transport Layer Security (TLS) for all website interactions.
  • Cloudflare firewall, DDoS protection, and bot mitigation.
  • Role-based access controls and multi-factor authentication for internal systems.
  • Regular reviews of storage locations and deletion of redundant files.

8. Your Rights

Under the Ghana Data Protection Act, you have the right to:

  • Request access to the personal data we hold about you.
  • Ask for corrections if your information is inaccurate or incomplete.
  • Request deletion of your data where applicable.
  • Object to or restrict processing in certain circumstances.
  • Withdraw consent at any time where processing is based on consent.
  • Lodge a complaint with the Data Protection Commission of Ghana.

To exercise your rights, contact us at [email protected].

9. Cookies and Tracking Technologies

We use essential cookies for secure navigation and Cloudflare cookies for protection against malicious traffic. Non-essential analytics cookies are only activated with your consent. Refer to our Cookie Policy for detailed information.

10. Updates to This Notice

We may revise this notice to reflect operational or regulatory changes. Updates will be published on this page with a revised effective date. We encourage you to review it regularly.