Your data, handled in the open.

UrielleX is operated by [Registered company name] (company number [Registrar-General company number]), [Registered office address, city, Ghana] ([GhanaPost GPS digital address]). In this policy “we” and “us” mean that company.

We are registered with Ghana's Data Protection Commission as a data controller under the Data Protection Act, 2012 (Act 843), registration number [DPC registration number]. Our privacy contact is [Name of Data Protection Supervisor].

This policy covers the UrielleX website, the web app, the mobile apps and our API. It explains how we use personal data, meaning information about you as an identifiable person.

UrielleX is used by organizations, such as classes, schools, associations and alumni groups, to collect contributions from their members. Two parties handle your data:

• Your organization decides who is on its roster, how much to collect and what its contribution policy says. When an admin uploads a roster with your name and phone number, they are responsible for having the right to do so and for telling you. For roster and contribution records, we process data on the organization's behalf.
• We are responsible for your UrielleX account, sign-in and SMS codes, payment processing through Paystack, subscription billing, this website and its contact form.

If you have a question about why a group has your details, ask that group's admin. We will also help. See Contact.

When you create or use an account

• Your name (as your organization listed it, or as you entered it) and phone number, which is how you sign in.
• Your email address, used for payment receipts.
• Your password, stored only as a one-way hash. We cannot read it.
• Which organizations you belong to, your role in each, whether an admin has blocked you, and which version of each group's policy you accepted.
• When you accepted these terms and this policy, and which versions.

When an organization adds you to its roster

• Your name and phone number, even before you register. This is how the app recognises you when you sign up.

When you contribute

• The amount, the periods it covers (for example, the months), the type (dues or voluntary), any note you add, the date, the status, and the payment reference.
• The payment channel (for example, mobile money or card) and the fees on the payment, as reported by Paystack.
• We do not receive or store card numbers, CVVs or mobile-money PINs. You enter those on Paystack's checkout.

When you run an organization

• The organization's name, logo, contribution settings and policy.
• The payout bank or mobile-money account. Paystack confirms the account name before we save it.
• Subscription purchases, and usage against the plan (members, groups, SMS sent).

When you verify your phone

• Your phone number is sent to our SMS provider to send and check a one-time code. We don't store the code.

When you contact us

• What you type into the contact form: name, phone, optional email and organization, topic and message.
• Your IP address and browser details with that message, to stop spam and abuse.
• If you use live chat, the chat provider handles the conversation. See Service providers.

Automatically

• Server logs: IP address, device and browser type, pages or endpoints requested, and errors. These are for security and fixing problems.

Act 843 lets us process personal data only for a lawful reason. Ours are:

• To provide the service you signed up for (performing our agreement with you): creating your account, joining you to your groups, showing what you owe and have paid, taking payments through Paystack, settling them to the organization, sending sign-in codes, and texting admins before their plan renews.
• To keep the service safe (legitimate interests): stopping fraud, spam and abuse, securing accounts, limiting repeated requests, and investigating problems.
• To meet legal obligations: keeping business and tax records, and responding to lawful requests from authorities.
• With your consent: loading live chat on this website. You can withdraw consent at any time under “Cookie settings”.

We don't sell personal data, rent it, use it for advertising, or send marketing messages without your consent. We don't make decisions about you by automated means that have legal or similarly significant effects.

• Admins of your organization can see your name, phone number, email, role, contributions, policy acceptance, and whether you have registered. They can change your role, block you or remove you from that organization. They can't see anything about your other organizations.
• Other members of your organization can see the group's member list (names and phone numbers) and its contribution history (names and amounts).
• Our staff with platform-owner access, only when needed to run the service, support you or act on a request.
• Our service providers, listed below, only to do their job for us.
• Authorities, when the law requires it, or when it is needed to protect someone's safety or investigate fraud.
• A buyer or successor, if our business is sold or reorganised. This policy would continue to apply to your data.

These companies process personal data for us, under contract, only for the purposes described:

Paystack is a licensed payment processor. It must keep its own records of the transactions it handles, under its own privacy policy and financial regulations. Deleting your UrielleX account doesn't delete Paystack's records.

Some of our providers store or process data outside Ghana. When they do, we use providers that protect it to a standard at least as strong as Act 843. We also rely on contractual safeguards and only transfer what the service needs.

We keep personal data only as long as we need it for the reasons above:

• Passwords are hashed. Sessions use signed tokens, which stop working when an account is blocked or deleted.
• Payment amounts and destinations are set on our server. Paystack's secret keys never reach browsers or apps, and every payment webhook's signature is checked.
• Each organization's data is separated. Admins can only reach their own organization.
• Deleting an account or organization asks for the password again.

No system is perfectly secure. If a breach affects your personal data, we will notify you and the Data Protection Commission as the law requires.

Under the Data Protection Act, 2012 (Act 843), you can:

• Be informed about how your data is used. That is this policy.
• Access the personal data we hold about you, and get a copy.
• Correct data that is inaccurate, out of date or incomplete.
• Have data deleted when we no longer have a lawful reason to keep it.
• Object to processing, and withdraw consent where consent is the reason we use your data.
• Refuse direct marketing. We don't send it without consent.
• Complain to us, and to the Data Protection Commission.

To use these rights, email [privacy@yourdomain.com], call [+233 XX XXX XXXX], or send a message through our contact form with the topic “Privacy & data”. Please include the phone number on your account. We may call or text that number to confirm the request is yours. We aim to respond within 21 days, and we don't charge for reasonable requests.

For data a group added about you (such as your roster entry), you can also ask that group's admin. We will pass on requests where the group needs to act.

Your account: open the app, go to Profile → Delete my account and confirm with your password. It happens straight away. Your account, name, phone number and email are erased. So are your memberships, your roster entries and any messages you sent us. Contributions you made stay in each group's records, so its accounts stay correct, but your name, phone number and note are removed from them.

An organization: an admin can delete it from Admin → Settings → Delete organization. This erases its roster, memberships, contribution records, settings, policy and logo, and switches off its payout account.

Can't sign in? See Delete your account to ask us to do it for you.

This website stores a small amount in your browser:

• Essential: your light or dark mode choice, and your cookie choice. These stay in your browser and are never sent to us.
• Live chat (optional): tawk.to sets cookies to keep the conversation going between pages. It loads only if you choose “Allow chat”.

The web and mobile apps store your sign-in token on your device so you stay signed in, and remember which organization you last used. We don't use advertising or cross-site tracking cookies. You can change your choice at any time with “Cookie settings” at the bottom of every page.

Accounts are for people aged 18 or over. Where contributions relate to a child, such as school dues, the account should belong to a parent or guardian. We don't knowingly collect data from children. If you think a child has created an account, contact us and we will delete it.

We will update this policy when our service or the law changes. The date at the top shows the latest version. If a change affects how we use your data, the apps will ask you to review and accept it before you continue.

[Registered company name]
[Registered office address, city, Ghana]
Email: [privacy@yourdomain.com] · Phone: [+233 XX XXX XXXX]

If you're unhappy with how we handled your data, please tell us first so we can put it right. You can also complain to the Data Protection Commission of Ghana at dataprotection.org.gh.