Click Communications Limited (CCL)is much concerned about the privacy of users of its web platforms. We are registered with the Data Protection Commission of Ghana; we committed to protecting your personal information and to use it properly in compliance with data privacy laws.. This policy describes how we may collect and use personal information, and the rights and choices available to users and visitors regarding such information.
We encourage you to make time to read this policy and ensure you fully understand it, before you access or use any of our services.
2.1. Visitor and User Information
We collect two types of information regarding our Visitors and Users:
- Identified and non-identifiable information pertaining to a Visitor or identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing our web platforms.
Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number, location information) which are only collected from Users with Paid Services, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected PayPal, Google or Facebook account), scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of our Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists
- We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website or any User Website, register a User Account, edit your User Website and upload information and content, and/or download and use any of the Click Communications Web Apps and/or Mobile Apps, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services and through the use of “cookies” and other tracking technologies.
- We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Service.
We collect such Non-personal and Personal Information for the following purposes:
- To provide and operate the Services;
- To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
- To provide our Users with ongoing customer assistance and technical support;
- To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages
- To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
- To send promotional messages on product and services including public announcement by other users of our platform, public and private organizations.
- To enhance our data security and fraud prevention capabilities;
- To comply with any applicable laws and regulations.
We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:
- our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support), or
- our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or
- our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of CCL’s campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
Click Communications Limited may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
5.1. Third Party Services:
Click Communications Limited has partnered with a number of service providers and clients whose services and solutions complement, facilitate and enhance our own. These include hosting, payment processing services, domain name registrars, marketing services, promotional services, content providers etc (collectively, “Third Party Service(s)”).
Such Third Party Services may receive or otherwise have access to our Visitors’ and Users’ contact Information – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and they may only use it for such purposes.
Note that users of our web platforms may upload bulk contacts (phone numbers) on our nstacom service platform for the sole purpose of sending bulk SMS, Webmail and Voice messages to those contacts. Those contacts may be stored in our contacts database and will be accessible to other users of our nstacom serves for sole purpose of sending promotional messages and public announcement to those contacts. We are not responsible for upload of such bulk contacts by our users and the messages sent to those contacts.
Click Communications is accountable for Personal Information that it collects and subsequently transfers to a third party. In particular, CCL remains responsible and liable under the Privacy Shield Principles if third-party agents engage to process the Personal Information on its behalf do so in a manner inconsistent with the Principles, unless CCL proves that it is not responsible for the event giving rise to the damage.
5.2. Law Enforcement, Legal Requests and Duties:
Where permitted by data protection laws, CCL may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
5.3. Protecting Rights and Safety:
CCL may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of CCL any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
5.4. Social Media Features and Framed Pages:
Our Services include certain Social Media features and widgets, single sign on features, such as the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”).These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
6.1. Promotional Messages:
We may use or make your contact number accessible to users of our nstacom and clientserviceplus services for the purpose of sending you customer service information, promotional content and messages either by e-mail, text messages, automated voice calls and similar forms of communication from CCL or our partners or users through www.nstacom.com platform.
If you do not wish to receive such promotional messages or calls, you may follow the “unsubscribe” instructions link contained in the promotional communications you receive.
6.2. Service and Billing Messages:
CCL may also contact you with important information regarding our Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.
It is imperative that you have control over your Personal Information. That’s why CCL is taking steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive). You have the right to file a complaint with the for data protection commission (but we still recommend that you contact us first).
If you are a CCL Web Service Visitor or User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, contact us for assistance. We will make all reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfill your request), subject to legal and other permissible considerations.
Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.
We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a complaint with the Data Protection Commission of Ghana; however we recommend that you contact us first so we can try to resolve it.
We may continue to retain such Personal Information even after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to information in our care. Where your Personal Information is no longer required we will ensure it is securely deleted.
CCL has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by CCL, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Information or any other User Content you upload, publish or otherwise share with CCL or anyone else.
We therefore encourage you to set strong passwords for your User Account and User Website, and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm
We acknowledge that some parts of this privacy document were picked from wix.com which we have been adopted and modified for our use.