Privacy Policy

1. Introduction

Welcome to Hoga (“we,” “our,” “us”). We are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy describes how we collect, use, disclose, and protect personal information you provide through our website, apps, and services (collectively, the “Platform”) in connection with Hoga’s contribution, donation, and fund-collection services.

By using the Platform or providing us with your personal data, you agree to the terms of this policy and consent to the processes described herein.

2. Definitions

Personal Data / Personal Information: Any information relating to an identified or identifiable natural person (e.g. name, phone number, email, payment info)

Processing: Any operation performed on personal data — collection, storage, use, disclosure, deletion, etc.

Controller / Data Controller: Hoga (we determine how and why your data is processed)

Processor / Service Provider: Third-party entities (e.g., payment providers, hosting) that process data on our behalf under contract

Data Subject: You — the person whose personal data is collected or processed

3. Legal Basis for Processing

We process your personal data on one or more of the following legal bases:

Consent: Where you agree for us to process your data (e.g. when you sign up, make a contribution, provide identification)

Contractual necessity: To fulfill services you request (e.g. completing a donation, issuing receipts)

Legal obligation: To comply with relevant laws, regulations, or government requests (e.g. anti-money laundering, tax reporting)

Legitimate interests: For fraud prevention, security, improving our services, and ensuring the Platform’s integrity, provided your rights are not overridden

4. What Information We Collect

We may collect the following categories of information:

4.1 Identity & Contact Information

Full name

Email address

Phone number

Physical or postal address

Preferred language

4.2 Payment & Financial Information

Mobile money account number and provider

Bank account or card details (via payment providers — we do not store raw card data)

Transaction history (donations, contributions)

Payment receipts

4.3 Verification & Compliance Data

Government-issued ID (e.g. national ID, passport)

Proof of address (e.g. utility bill)

Other KYC / AML documents (as required)

4.4 Technical & Usage Data

IP address

Device and browser information (type, operating system)

Usage logs (pages visited, time, features used)

Cookies, analytics, and tracking technologies

Location (if permitted)

4.5 Communications & Support Data

Correspondence (emails, chat, support tickets)

Feedback, surveys

5. How We Use Your Information

We use personal data for the following purposes:

To create and manage your account

To process contributions, refunds, and payments

To issue receipts and transaction records

To verify identity (KYC/AML compliance)

To detect, prevent, and investigate fraud, security issues, or abuse

To communicate with you (notifications, receipts, updates, support)

To analyze and improve the Platform (product analytics, error logs, feature enhancements)

To comply with legal and regulatory obligations

For internal reporting, audit, and record-keeping

6. Disclosure of Your Information

We may share your information in the following cases:

With service providers & processors: Payment gateways, hosting providers, analytics providers — under binding contracts requiring confidentiality

Legal / regulatory authorities: When required by law, regulation, court order, or governmental request

For fraud prevention / security: To prevent abuse or enforce terms

Business transfers: In the event of a merger, acquisition, or sale of assets (with notice)

Public directory (optional): If you or your organization opt into our public “jar” directory or leaderboard, certain non-sensitive data (e.g. campaign name, total contributions) may be displayed publicly

We will not sell, rent, or lease your personal data for commercial marketing purposes without your explicit consent.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, accounting, or reporting obligations. After that period, we either delete or anonymize the data.

8. International Transfers

Your data may be transferred to and stored in countries outside the country in which you reside (e.g. cloud servers). Whenever we do so, we ensure appropriate safeguards (contractual clauses, encryption) are in place to protect your data.

9. Your Rights

Under relevant data protection laws (including Ghana’s Data Protection Act, 2012), you have rights including:

The right to access the personal data we hold about you

The right to correct or update inaccurate or incomplete data

The right to restrict or object to certain processing

The right to delete your personal data (“right to be forgotten”) (subject to legal requirements)

The right to data portability (obtain your data in machine-readable format)

The right to withdraw consent (for processing based on consent)

The right to lodge a complaint with the Data Protection Commission or applicable authority

To exercise these rights, please contact us (see Section 13).

10. Security Measures

We employ appropriate technical and organizational safeguards to protect personal data from unauthorized access, disclosure, alteration, or destruction, including:

Encryption in transit (TLS) and at rest

Secure coding practices, input validation, regular security audits

Access controls and role-based permissions

Audit logs and monitoring

Incident response plan

However, no system is completely secure; use of the internet is at your own risk.

11. Cookies & Tracking

We use cookies, web beacons, and similar technologies to collect technical and usage data. Cookies may help with remembering your preferences, session management, analytics, and security.

You can choose to disable cookies via your browser settings, though this might limit functionality of the Platform.

12. Children & Minors

Our services are not intended for individuals under the age of 18. If we become aware that we have collected data from a minor without verified parental consent, we will delete such data as soon as possible.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or Platform features. We will notify you of material changes (e.g. via email or in-app notice) and update the “Last Updated” date.

Your continued use of the Platform after changes constitute your acceptance of the revised policy.

14. Contact Us

If you have questions, requests, or concerns about this policy or your data, you can reach us at:

Email: hello@usehoga.com