Privacy policy

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Updated: March, 2023


As part of our operations, Activezoon (“Activezoon” or “the Company”) collects and processes certain types of information (such as names, telephone numbers, addresses, etc.) of individuals that make them easily identifiable. These individuals include current, past, and prospective employees, merchants, suppliers/vendors, customers of merchants, and other individuals whom Activezoon communicates or deals with, jointly and/or severally (“Data Subjects”).

Maintaining the Data Subject’s trust and confidence requires that Data Subjects do not suffer negative consequences/effects as a result of providing Activezoon with their Personal Data. To this end, Activezoon is firmly committed to complying with applicable data protection laws, regulations, rules, and principles to ensure the security of Personal Data handled by the Company. This Data Privacy & Protection Policy (“Policy”) describes the minimum standards that must be strictly adhered to regarding the collection, use, and disclosure of Personal Data and indicates that Activezoon is dedicated to processing the Personal Data it receives or processes with absolute confidentiality and security.

This Policy applies to all forms of systems, operations, and processes within the Activezoon environment that involve the collection, storage, use, transmission, and disposal of Personal Data. 

Failure to comply with the data protection rules and guiding principles set out in the Ghana Data Protection Regulation, 2012 (GDPR) as well as those set out in this Policy is a material violation of Activezoon’s policies and may result in disciplinary action as required, including suspension or termination of employment or business relationship. 


This Policy applies to all employees of Activezoon, as well as to any external business partners (such as merchants, suppliers, contractors, vendors, and other service providers) who receive, send, collect, access, or process Personal Data in any way on behalf of Activezoon, including processing wholly or partly by automated means. This Policy also applies to third-party Data Processors who process Personal Data received from Activezoon. 

General Principles for Processing of Personal Data

Activezoon is committed to maintaining the principles in the GDPR regarding the processing of Personal Data. 

To demonstrate this commitment as well as our aim of creating a positive privacy culture within Activezoon, Activezoon adheres to the following basic principles relating to the processing of Personal Data:

Lawfulness, Fairness, and Transparency
Personal Data must be processed lawfully, fairly, and in a transparent manner at all times. This implies that Personal Data collected and processed by or on behalf of Activezoon must be in accordance with the specific, legitimate, and lawful purpose consented to by the Data Subject, save where the processing is otherwise allowed by law or within other legal grounds recognized in the GDPR. 

Data Accuracy
Personal Data must be accurate and kept up to date. In this regard, Activezoon: 

a.   shall ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to the Data Subject; 

b.   make efforts to keep Personal Data updated were reasonable and applicable; and

c.    make timely efforts to correct or erase Personal Data when inaccuracies are discovered.

Purpose Limitation

Activezoon collects Personal Data only for the purposes identified in the appropriate Activezoon Privacy Notice provided to the Data Subject and for which consent has been obtained. Such Personal Data cannot be reused for another purpose that is incompatible with the original purpose, except a new Consent is obtained. 

The purposes for which Activezoon will use your personal data include:

1.   For the provision of services to you. For example, when you purchase any of our products or services, we will use your personal data to process your order.

2.   For customer care and billing. When you use our products or services, we will use your personal information to bill you and to respond to inquiries and concerns that you may have about our products and services.

3.   Customer service messages. We will use your personal data to keep you updated with the latest information or changes about our products and services.

4.   For marketing purposes. In order to serve you better, we will use your personal data to market our products and services to you. 

5.   Fraud prevention and security. We will process your personal and traffic data in order to protect you against and detect fraud, to protect and detect misuse or damage to our platform.

6.   Managing our platform and understanding platform usage. We do this to manage the volume of jobs and to understand how you use our platform, products, and services.

Data Minimization

1.   Activezoon limits Personal Data collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed.

2.   Activezoon will evaluate whether and to what extent the processing of personal data is necessary and where the purpose allows, anonymized data must be used.

Integrity and Confidentiality

1.   Activezoon shall establish adequate controls in order to protect the integrity and confidentiality of Personal Data, both in digital and physical format, and to prevent personal data from being accidentally or deliberately compromised.

2.   Personal data of Data Subjects must be protected from unauthorized viewing or access and from unauthorized changes to ensure that it is reliable and correct. 

3.   Any personal data processing undertaken by an employee who has not been authorized to carry such out as part of their legitimate duties is unauthorized.

4.   Employees may have access to Personal Data only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Data for their own private or commercial purposes or to disclose them to unauthorized persons, or make them available in any other way. 

5.   The Human Resources Department must inform employees at the start of the employment relationship about the obligation to maintain personal data privacy. This obligation shall remain in force even after employment has ended. 

Personal Data Retention

1.   All personal information shall be retained, stored, and destroyed by Activezoon in line with legislative and regulatory guidelines. For all Personal Data and records obtained, used, and stored within the Company, Activezoon shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity, and requirement to retain. 

2.   To the extent permitted by applicable laws and without prejudice to Activezoon’s Document Retention Policy, the length of storage of Personal Data shall, amongst other things, be determined by: 

1.   the contract terms agreed between Activezoon and the Data Subject or as long as it is needed for the purpose for which it was obtained; or

2.   whether the transaction or relationship has statutory implication or a required retention period; or

3.   whether there is an express request for deletion of Personal Data by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require Activezoon to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data; or

4.   whether Activezoon has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

Notwithstanding the foregoing and pursuant to the GDPR, Activezoon shall be entitled to retain and process Personal Data for archiving, scientific research, historical research, or statistical purposes for the public interest.

3.   Activezoon would forthwith delete Personal Data in Activezoon’s possession where such Personal Data is no longer required by Activezoon or in line with Activezoon’s Retention Policy, provided no law or regulation is in force that requires Activezoon to retain such Personal Data. 


1.   Activezoon demonstrates accountability in line with the GDPR obligations by monitoring and continuously improving data privacy practices within Activezoon.

2.   Any individual or employee who breaches this policy may be subject to internal disciplinary action (up to and including termination of their employment), and may also face civil or criminal liability if their action violates the law.

Data Privacy Notice

1.   Activezoon considers Personal Data as confidential and as such must be adequately protected from unauthorized use and/or disclosure. Activezoon will ensure that the Data Subjects are provided with adequate information regarding the use of their Personal Data as well as acquire their respective Consent, where necessary.

2.   Activezoon shall display a simple and conspicuous notice (Privacy Notice) on any medium through which Personal Data is being collected or processed. The following information must be considered for inclusion in the Privacy Notice, as appropriate in distinct circumstances in order to ensure fair and transparent processing:

a.   Description of collectible Personal Data;

b.   Purposes for which Personal Data is collected, used, and disclosed;

c.    What constitutes Data Subject’s Consent;

d.   Purpose for the collection of Personal Data;

e.   The technical methods used to collect and store the information;

f.     Available remedies in the event of a violation of the Policy and the timeframe for remedy; and

g.   Adequate information in order to initiate the process of exercising their privacy rights, such as access to, rectification, and deletion of Personal Data.

3.   Activezoon’s Privacy Notice is available on Activezoon’s website via this link. 

Legal Grounds For Processing Of Personal Data 

The personal data we collect from our customers and how we collect it depends on the services that our customers subscribe to, how they use our services and how they interact or interface with us. This also applies to persons who are not customers of Activezoon but have interacted with Activezoon. We may also obtain your personal data from a third party with permission to share it with us.

Please note that we only process your personal data based on the grounds set out in the GDPR. Accordingly, in line with the provisions of the GDPR, the processing of Personal Data by Activezoon shall be lawful if at least one of the following applies: 

a.   Where you give us consent to the processing of your Personal Data for one or more specific purposes. You are at liberty to withdraw the consent and Activezoon will cease to process your Personal Data where there is no other basis to do so.

b.   Where the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;

c.    processing is necessary for compliance with a legal obligation to which Activezoon is subject;

d.   processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; and

e.   Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official public mandate vested in Activezoon.

We collect your personal data when you do any of the following:

a.   Buy or use any of our products and services;

b.   Use our network or other Activezoon products and services;

c.    Register for a specific product or service;

d.   Fill in your information on our KYC registration form, self-service applications, social media platforms;

e.   Visit or browse our website;

f.     Have given permission to other companies to share information about you;

g.   Where your information is publically available;

h.   Are the customers of a business we acquire or;

i.     Take part in a competition, prize draw, or survey.

Personal data we have about our customers, where applicable include name, phone number, address, sex, photograph, ID card number, fingerprint, educational information, job experiences, signature, etc.


Where the processing of Personal Data is based on consent, Activezoon shall obtain the requisite consent of Data Subjects at the time of collection of Personal Data. In this regard, Activezoon will ensure:

a.   that the specific purpose of collection is made known to the Data Subject and the Consent is requested in clear and plain language;

b.   that the Consent is freely given by the Data Subject and obtained without fraud, coercion, or undue influence;

c.    that the Consent is sufficiently distinct from other matters to which the Data Subject has agreed;

d.   that the Consent is explicitly provided in an affirmative manner;

e.   that Consent is obtained for each purpose of Personal Data collection and processing; and

f.     That it is clearly communicated to and understood by Data Subjects that they can update, manage or withdraw their consent at any time.

Valid Consent 

1.   For Consent to be valid, it must be given voluntarily by an appropriately informed Data Subject. In line with regulatory requirements, Consent cannot be implied. Silence, pre-ticked boxes, or inactivity does not constitute Consent under the GDPR. 

2.   Consent in respect of Sensitive Personal Data must be explicit. A tick of the box would not suffice.

Consent of Minors

In the unlikely event that we deal with minors, the consent of minors will always be protected and obtained from minors’ representatives in accordance with applicable regulatory requirements. 

Data Subject Rights

1.   All individuals who are the subject of Personal Data held by Activezoon are entitled to the following rights:

a.   Right to request for and access their Personal Data collected and stored. Where data is held electronically in a structured form, such as in a database, the Data Subject has a right to receive that data in a common electronic format;

b.   Right to information on their personal data collected and stored;

c.    Right to objection or request for restriction;

d.   Right to object to automated decision making;

e.   Right to request rectification and modification of their data which Activezoon keeps; 

f.     Right to request for deletion of their data, except as restricted by law or Activezoon’s statutory obligations;

g.   Right to request the movement of data from Activezoon to a Third Party; this is the right to the portability of data; and 

h.   Right to object to, and to request that Activezoon restricts the processing of their information except as required by law or Activezoon’s statutory obligations. 

i.     To opt out of marketing and unsolicited messages:

If you no longer want to receive marketing messages from Activezoon, you can choose to opt out at any time. If you’ve previously opted in to receive personalized content based on how and where you use our platform, you can also opt out at any time.

There are various ways to opt out:

·         Contact our customer services team – see the contact us page;

·         Click the unsubscribe icon or link from our email;

·         Disable push notification messages, including marketing messages, at any time in our apps/platform by changing the notification/alert settings on your device or by uninstalling the app;

2.   Activezoon’s well-defined procedure regarding how to handle and answer Data Subject’s requests are contained in Activezoon’s Data Subject Access Request Policy. 

3.   Data Subjects can exercise any of their rights by completing the Activezoon’s Subject Access Request (SAR) Form and submitting it to the Company via

Transfer of Personal data 

Third-Party Processor within Ghana

Activezoon may engage the services of third parties in order to process your Personal Data collected by us. The processing by such third parties shall be governed by a written contract with Activezoon to ensure adequate protection and security measures are put in place by the third party for the protection of Personal Data in accordance with the terms of this Policy and the GDPR. We may also share your personal data with law enforcement agencies where required by law to do so.

Where applicable, Activezoon will share your information with:

1.   Partners, suppliers, or agents involved in delivering the products and services you’ve ordered or used. For example, when you apply for a job, your job request may be handled by our business partner who is bound by contract to protect your personal data.

2.   Law enforcement agencies, government bodies, regulatory organizations, courts, or other public authorities if we have to, or are authorized to by law. For example, under the Cybercrimes Act, a law enforcement agency may request a service provider to keep or release any traffic data, subscriber information, content, or non-content information. This is however for law enforcement purposes only.

3.   A third party or body where such disclosure is required to satisfy any applicable law or other legal or regulatory requirements e.g to detect or prevent fraud or the commission of any other crime.

4.   A merging or acquiring entity where we undergo business reorganization e.g merger, acquisition, or takeover.

Transfer of Personal Data to Foreign Country

1.   Where Personal Data is to be transferred to a country outside Ghana, Activezoon shall put adequate measures in place to ensure the security of such Personal Data. In particular, Activezoon shall, among other things, conduct a detailed assessment of whether the said country is on the National Information Technology Development Agency (NITDA) White List of Countries with adequate data protection laws. 

2.   Transfer of Personal Data out of Ghana would be in accordance with the provisions of the GDPR. Activezoon will therefore only transfer Personal Data out of Ghana on one of the following conditions: 

a.   The consent of the Data Subject has been obtained;

b.   The transfer is necessary for the performance of a contract between Activezoon and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request;

c.    The transfer is necessary to conclude a contract between Activezoon and a third party in the interest of the Data Subject;

d.   The transfer is necessary for reason of public interest;

e.   The transfer is for the establishment, exercise, or defense of legal claims;

f.     The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.

Provided, in all circumstances, that the Data Subject has been manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country, this proviso shall not apply to any instance where the Data Subject is answerable in duly established legal action for any civil or criminal claim in a third country.

Activezoon will take all necessary steps to ensure that the Personal Data is transmitted in a safe and secure manner. Details of the protection given to your information when it is transferred outside Ghana shall be provided to you upon request.

3.   Where the recipient country is not on the White List and none of the conditions stipulated in Section 2 of this Policy is met, Activezoon will engage with NITDA and the Office of the Honorable Attorney General of the Federation (HAGF) for approval with respect to such transfer. 


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