Privacy Policy
This Privacy Policy explains how Lumenkernel (“we”, “our”, “us”) collects, uses, stores, and protects personal information in line with the Data Protection Act, 2012 (Act 843) of Ghana. It applies to visitors, clients, and prospective clients engaging with our website, communication channels, and services.
1. Data controller
Lumenkernel operates from 88 Takoradi Loop, Takoradi, Ghana and can be reached via [email protected] or +233 27 661 1044. We determine how and why personal data is processed.
2. Information we collect
- Identification data: names, job titles, and organisation names provided via forms or consultations.
- Contact data: phone numbers, email addresses, and postal addresses.
- Financial context data: non-sensitive financial details voluntarily shared to receive guidance, such as income ranges, spending categories, and savings goals.
- Usage data: anonymised analytics about site interactions (pages visited, time on page) collected through cookies.
- Communication records: notes from consultations, email exchanges, or support requests.
3. Legal basis for processing
We process personal data when:
- The processing is necessary to perform a contract or provide pre-contractual support.
- You have provided explicit consent (for example, opting into follow-up communication).
- Processing is required to comply with statutory obligations in Ghana.
- We pursue legitimate interests, such as improving our services, without overriding your rights.
4. How we use your information
- Delivering personalised financial guidance, including preparation of reports and recommendations.
- Managing enquiries, scheduling consultations, and providing support.
- Sending relevant updates about engagements, timelines, or resources you requested.
- Monitoring and improving website performance and user experience.
- Maintaining records for compliance with Ghanaian regulatory requirements.
5. Data retention
We retain personal data only as long as necessary to fulfil the purposes described above. Typically, client files are stored for up to five years after the conclusion of an engagement unless law requires a longer period. When data is no longer needed, we securely delete or anonymise it.
6. Data sharing and transfers
We do not sell or rent personal data. Sharing occurs only when:
- We engage vetted service providers (e.g., cloud storage providers) who operate under confidentiality and data protection agreements.
- We must respond to lawful requests from regulatory bodies or courts in Ghana.
- You request collaboration with a trusted third party and provide written consent.
We store data on secure servers located in Ghana or in jurisdictions that provide adequate protection levels. When data leaves Ghana, we implement safeguards such as standard contractual clauses.
7. Cookies
Our website uses essential cookies for core functionality and analytical cookies to understand aggregate usage. Details of cookie categories, retention periods, and management options are provided in our Cookie Notice.
8. Security measures
We employ administrative, technical, and physical safeguards, including encrypted storage, access controls, secure transmission protocols, and regular staff training. While we take reasonable precautions, no method of transmission over the internet is completely secure. We encourage clients to use secure channels when sharing sensitive information.
9. Your rights
Under Ghanaian law, you have the right to:
- Request access to the personal data we hold about you.
- Rectify inaccurate or incomplete information.
- Request deletion of personal data when processing is no longer necessary.
- Restrict processing in certain circumstances.
- Object to processing based on legitimate interests.
- Withdraw consent at any time where consent is the legal basis for processing.
To exercise these rights, contact us via [email protected]. We respond within 30 days, subject to identity verification requirements.
10. Children’s privacy
Our services are directed at adults and organisational representatives. We do not knowingly collect personal data from individuals under 18 without appropriate guardian consent.
11. Updates to this policy
We review this policy periodically to align with legal developments and service enhancements. Changes take effect upon publication. We encourage you to revisit this policy regularly.
12. Contact
Questions regarding this policy or our data practices should be directed to:
Lumenkernel
88 Takoradi Loop, Takoradi, Ghana
[email protected]
+233 27 661 1044
If you believe we have not handled your data appropriately, you may lodge a complaint with the Data Protection Commission of Ghana.