Privacy Policy
Your privacy is important to us. This policy explains how Xtottel collects, uses, and protects your personal information in compliance with Ghana's Data Protection Act.
1. Introduction
At Xtottel, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services.
We comply with Ghana's Data Protection Act, 2012 (Act 843) and other applicable data protection laws. By using our services, you consent to the practices described in this policy.
Your Privacy Matters
We are transparent about our data practices and committed to protecting your fundamental rights and freedoms regarding your personal data.
2. Definitions
- "Personal Data" means any information relating to an identified or identifiable natural person.
- "Processing" means any operation performed on personal data, including collection, storage, and use.
- "Data Controller" means Xtottel, which determines the purposes and means of processing personal data.
- "Data Subject" means the individual to whom the personal data relates.
- "Consent" means any freely given, specific, informed, and unambiguous indication of the data subject's wishes.
3. Information We Collect
3.1 Personal Information
We may collect the following types of personal information:
- • Contact Information (name, email, phone number, address)
- • Business Information (company name, job title)
- • Payment Information (billing details, transaction history)
- • Communication Records (emails, chat logs, meeting notes)
- • Project Requirements and Specifications
3.2 Technical Information
When you visit our website, we automatically collect:
- • IP address and browser type
- • Device information and operating system
- • Website usage data and analytics
- • Cookies and similar tracking technologies
3.3 Information from Third Parties
We may receive information about you from third-party services, such as:
- • Social media platforms (when you interact with our content)
- • Business partners and service providers
- • Publicly available sources
4. How We Use Your Information
We use your personal information for the following purposes:
Service Delivery
- • Project development and management
- • Client communication and support
- • Quality assurance and testing
Business Operations
- • Billing and payment processing
- • Contract administration
- • Legal compliance
Marketing & Analytics
- • Website analytics and improvement
- • Marketing communications (with consent)
- • Service enhancement
Security & Legal
- • Fraud prevention and security
- • Legal obligations and disputes
- • Policy enforcement
Legal Basis for Processing
We process your personal data based on: (1) your consent, (2) performance of a contract, (3) legal obligations, or (4) legitimate interests that are not overridden by your rights.
5. Data Sharing and Disclosure
We may share your personal information in the following circumstances:
5.1 Service Providers
We may share information with trusted third-party service providers who assist us in operating our business, such as:
- • Cloud hosting providers (AWS, Google Cloud)
- • Payment processors (Stripe, PayPal, Hubtel, Paystack)
- • Analytics and marketing tools
- • Customer support platforms
5.2 Legal Requirements
We may disclose your information when required by law or to:
- • Comply with legal processes or government requests
- • Protect our rights, property, or safety
- • Prevent fraud or security issues
- • Enforce our terms and conditions
5.3 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.
6. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.
Technical Measures
- • Encryption of data in transit and at rest
- • Secure socket layer (SSL) technology
- • Regular security assessments
- • Access controls and authentication
Organizational Measures
- • Employee training on data protection
- • Confidentiality agreements
- • Regular policy reviews
- • Incident response planning
Security Notice
While we implement robust security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but we continuously work to protect your data.
7. Data Retention
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Our retention periods are based on:
- • The nature of the personal data
- • The purpose for processing
- • Legal and contractual requirements
- • Business needs and legitimate interests
When personal data is no longer needed, we securely delete or anonymize it.
8. Your Rights
Under Ghana's Data Protection Act, you have the following rights regarding your personal data:
Access & Information
- • Right to access your personal data
- • Right to know how we use your data
- • Right to request data portability
Control & Objection
- • Right to rectify inaccurate data
- • Right to object to processing
- • Right to restrict processing
Deletion & Withdrawal
- • Right to erasure ("right to be forgotten")
- • Right to withdraw consent
- • Right to lodge complaints
Automated Decisions
- • Right to human intervention
- • Right to challenge decisions
- • Right to express your point of view
To exercise any of these rights, please contact us using the information provided in the "Contact Us" section.
10. International Data Transfers
As a digital service provider, we may transfer and process your personal information outside of Ghana, primarily to countries with adequate data protection laws or under appropriate safeguards.
We ensure that any international transfers comply with Ghana's Data Protection Act and that your data receives adequate protection through:
- • Standard contractual clauses
- • Adequacy decisions
- • Binding corporate rules
- • Other approved transfer mechanisms
11. Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children.
If we become aware that we have collected personal information from a child without parental consent, we will take steps to remove that information from our servers.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.
We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date. We encourage you to review this policy periodically.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:
- Email: privacy@xtottel.com
- Phone: +233 (0) 551 196 764
- Website: www.xtottel.com
- Response Time: Within 30 days for data subject requests
You also have the right to lodge a complaint with the Data Protection Commission of Ghana if you believe our processing of your personal data violates applicable law.
Have Privacy Concerns?
Our Data Protection Officer is here to address your privacy questions and help you exercise your data rights.