DATA PROCESSING INFORMATION

This privacy statement informs you about how we treat your data. To make the processing of your data transparent, we would like to provide you with the following information to give you an overview of these processing operations. To keep things fair, we additionally want to inform you about your rights pursuant to the Data Protection Act 843 of Ghana (2012), EU-General Data Protection Regulation (GDPR), and the Federal Data Protection Act (BDSG). 

We will inform you in detail about 

  1. General Information 
  2. Data Processing on our website
  3. Data Processing on our social media

AmaliTech gGmbH and AmaliTech Ghana Limited are the controllers of the data processing (hereinafter referred to as ‘we’ or ‘us’). 

  1. General Information
  2. Contact

If you have any questions or feedback concerning this information or wish to contact us to exercise your rights, please send your inquiry to: 

AmaliTech Ghana Limited 

SSNIT House
27 Ama Akroma Road

Takoradi
Email: info@amalitech.org

  1. Legal Basis

The legal term ‘personal data’ refers to all information relating to an identified or identifiable natural person (a living individual). 

We process personal data in compliance with the data protection regulations of the DPA of Ghana, GDPR, and the BDSG. We solely process data based on law. We process personal data 

  • solely with your consent (DP Act 843 section 20(1) and Art. 6 section 1 letter a GDPR), 
  • to perform a contract to which you are a party or to take steps at your request prior to entering a contract (DP Act 843 section 20(1a) and Art. 6 section 1 letter b GDPR), 
  • to comply with a legal obligation (DP Act 843 section 20(1b) and Art. 6 section 1 letter c GDPR) or 
  • where processing is necessary for the purposes of our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data (DP Act 843 section 20(1b) and Art. 6 section 1 letter f GDPR). 
  • If you apply for an open position in our company, we will, additionally, process your personal data to decide on whether to hire you (DP Act 843 section 17(c), § 26 para. 1 sentence 1 BDSG). 

    1. Period of Storage

    Unless otherwise stated in the following, we will only store your data for as long as required to achieve the intended processing purpose, to fulfill our contractual or statutory obligations, or according to our Retention Policy. Such statutory retention requirements may result from regulations under commercial or tax law. 

    1. Recipients of Data

    For certain processing activities, we rely on service providers. These processing activities include, for example, hosting, and maintenance. A ‘processor’ is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller. Processors process data not for their own purposes but solely for the controller and are contractually obliged to implement appropriate technical and organizational measures ensuring data protection. 

    Apart from that, we may transfer your data to postal and delivery services, our bank, consultants/auditors, or the fiscal authority if necessary. 

    Should your data be transferred to further recipients, you can find this information under the description of the respective processing activity. 

    1. Processing in the Exercise of your Rights pursuant to Art. 15 to 22 GDPR

    If you exercise your rights pursuant to DP Act 35 to 44 and Art. 15 to 22 GDPR, we process the personal data we collect to grant you your rights and to acquire proof thereof. For providing information and preparing such information, we will process the stored data only for this purpose as well as for purposes of data protection control and otherwise restrict processing in accordance with DP Act 35 and Art. 18 GDPR. These processing operations are based on DP Act 20(1c) and Art. 6 section 1 letter c GDPR in combination with DP Act 35 to 44, Art. 15 to 22 GDPR, and § 34 para. 2 BDSG. 

    1. Your rights

    As the data subject, you are entitled to exercise your rights against us. You have the following rights: 

    • Pursuant to DP Act 35(c), Art. 15 GDPR and § 34 BDSG, you have the right of access to information confirming whether and, if so, to what extent we are processing personal data concerning you. 
    • Pursuant to DP Act 843 section 33(a) and Art. 16 GDPR, you have the right to rectification of your data. 
    • Pursuant to DP Act 843 section 33(b), Art. 17 GDPR and section 35 BDSG, you have the right to the erasure of your personal data. 
    • Pursuant to DP Act 843 section 20(2 & 3) and Art. 18 GDPR, you have the right to require us to restrict the processing of your personal data. 
    • Pursuant to DP Act 843 section 35(1) and Art. 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and the right to transfer such data to another controller. 
    • Where you have granted us specific consent to a processing activity, you can withdraw such consent at any time pursuant to DP Act 843 section 20(3) and Art. 7 section 3 GDPR. Any such withdrawal of consent shall not affect the lawfulness of processing based on that consent prior to its withdrawal. 
    • If you are of the view that the processing of your personal data infringes the DP Act 843 and GDPR provisions, you have the right to lodge a complaint with a supervisory authority pursuant to DP Act 843 Art.77 GDPR. 
    1. Right to object

    Pursuant to DP Act 843 section 20(2) and Art. 21 section 1 GDPR, you have the right to object to processing activities based on Art. 6 section 1 letter e or letter f GDPR on grounds relating to your situation. If we process your personal data for the purpose of direct marketing, you may object to such processing pursuant to DP Act 843 section 40(2) and Art. 21 section 2 and section 3 GDPR. 

    1. Data protection officer

    You can contact our data protection officer via the following address: 

    Farida Baberin-Yor Beacher 

    AmaliTech Ghana Limited 

    SSNIT House
    27 Ama Akroma Road 

    Takoradi
    Email: farida.beacher@amalitech.org

    IIData processing on our website

    During the use of our website, we collect information that you provide yourself. We also automatically collect certain information about your use of the site during your visit to the site. In data protection law, the IP address is also considered personal data. An IP address is assigned to each device connected to the internet by the internet provider so that it can send and receive data. 

    1. Processing of Server-Log-Files

    When using our website for informative purposes only, general information that your browser transfers to our server is initially stored automatically (not via registration). This includes by default: browser type/-version, operating system used, page called, the previously visited page (referrer URL), IP address, date and time of server request, and HTTP status code. The processing is carried out in pursuit of our legitimate interests and is based on DP Act 843 section 20(1e) and Art. 6 section 1 letter f GDPR. This processing serves the technical administration and security of the website. The data collected will be deleted when the visitor logs off the site unless the visitor leaves a message that requires attention and/or response from the site administrator or any department, or there is a justified suspicion of illegal use based on concrete indications and further examination and processing of the information is necessary for this reason. We are unable to identify you as a data subject based on the information collected. Art. 15 to 22 GDPR, therefore, do not apply pursuant to Art. 11 section 2 GDPR, unless you provide additional information to enable your identification in order to exercise the rights set out in these articles. 

    1. Data Transfer to third countries

    Visiting our website may involve the transfer of certain personal data to third countries, i.e., countries where the GDPR is not applicable law. Such a transfer shall be authorized if the European Commission has decided that an adequate level of data protection is ensured in such a third country. 

    In the absence of such an adequacy decision by the European Commission, personal data will only be transferred to a third country if appropriate safeguards are in place in accordance with Art. 46 GDPR or if one of the conditions of Art. 49 GDPR is met. 

    Unless otherwise stated below, we use as appropriate safeguards the EU standard contractual clauses for the transfer of personal data to processors in third countries:   

    https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX%3A32010D0087 . 

    1. Contact and requests

    If you send us a message via the contact email provided, we will process the transmitted data for the purpose of responding to your inquiry. 

    If your request is directed towards the conclusion or performance of a contract with us, DP Act 843 section 20(1a) and Art. 6 section 1 letter b GDPR is the legal basis for the data processing. Otherwise, we process the data based on our legitimate interest in contacting inquiring persons. The legal basis for data processing is then DP Act 843 section 20(1b) and Art. 6 section 1 letter f GDPR. 

    1. Donation

    On our website, you have the possibility to support us and our projects with a donation. For this purpose, an input form is integrated into the website. For this integration of the form, the processing of your IP address is required. In the context of your donation, we only process the data that you yourself have entered in the form. The data processing is carried out to process your donation and, if necessary, send you a donation receipt. 

    The transfer of your data is encrypted (recognizable by the “https” in the address line of the browser). All data fields marked as mandatory are required to process your request. Failure to provide this data will result in us not being able to process your request. 

    The legal basis for the processing is in each case DP Act 843 section 20(1a) and Art. 6 section 1 letter b GDPR. 

    For the provision of the donation form and payment processing, we are supported by Wikando GmbH, which acts as our processor. 

    1. Donations by credit card

    We offer you the possibility to donate by credit card. Please note that the respective payment information is collected and processed by the respective payment service providers on their own responsibility.

          2. Donations by PayPal

    Furthermore, you have the possibility to donate via Paypal. Please note that the relevant payment information is collected and processed by PayPal (Europe) S.à r.l. et Cie, S.C.A., based in Luxembourg, under its own responsibility. 

    For more information on data protection at Paypal, please visit: https://www.paypal.com/de/webapps/mpp/ua/privacy-full?locale.x=de_DE#r5 

    1. Newsletter

    We offer on our website the possibility to register for our newsletter. After registration we will inform you regularly about the latest news on our projects. For the registration to the newsletter a valid e-mail address is required. To verify the e-mail address, you will first receive a registration e-mail, which you must confirm via a link (double opt-in). If you subscribe to the newsletter on our website, we process personal data such as your e-mail address and name based on the consent you have given us. The processing is based on the legal basis of DP Act 843 section 20(1) and Art. 6 section 1 letter a GDPR. You can revoke the consent granted at any time with effect for the future, for example via the “unsubscribe” link in the newsletter or by contacting us via the channels mentioned above. The legality of the data processing operations already carried out remains unaffected by the revocation. 

    When registering for the newsletter, we also store the IP address and the date and time of registration. The processing of this data is necessary to be able to prove that consent has been given. The legal basis results from our legal obligation to document your consent (DP Act 843 section 20(1) and Art. 6 section 1 letter c in conjunction with Art. 7 section 1 GDPR). 

    1. Application

    When you apply for a position at our company, we process your application data exclusively for purposes related to your interest in current or future employment with us. Your application will only be processed and acknowledged by the responsible contact person. All employees entrusted with data processing are obliged to maintain the confidentiality of your data. If we are unable to offer you a position, we will retain the data you provide for up to three months for the purpose of potentially answering questions relating to your application and rejection. This does not apply if legal provisions prevent deletion if further storage is necessary for the purpose of presenting evidence or if you have expressly consented to longer storage. Legal basis for the data processing is section 26 para. 1 BDSG. 

    If we keep your applicant data for a period of four months and you have expressly consented to this, we would like to point out that this consent can be freely withdrawn at any time in accordance with DP Act 843 section 20(3) and Art. 7 section 3 GDPR. Such a withdrawal of consent does not affect the lawfulness of the processing, which has taken place prior to the withdrawal. 

    1. Cookies

    We use cookies and similar technologies on our website. Cookies are small text files that are stored by your browser when you visit a website. This makes the browser identifiable so it can be recognised by our web server. We use so-called ‘session cookies’, which are deleted when the browser session is ended. Other cookies (‘persistent cookies’) are automatically deleted after a specific period, which may vary depending on the cookie. 

    In part, the use of cookies is necessary to maintain functionality and operation of our website. Apart from that, we use cookies and similar technologies to measure the coverage of our website and analyse the use of our website. 

    Cookies are stored on the computer of the user. Therefore, you as the user have full control over the use of cookies. You can delete cookies in the security settings of your browser at any time. You can object to the use of cookies entirely or for certain cases in your browser settings. 

    You can find information on how we use cookies and similar technologies in the description of the specific processing activity. Further information about cookies used on our website can be found via the privacy settings in the consent banner. 

    1. Google Analytics

    We use the Google Analytics service of the provider Google Ireland Limited (Google Ireland/EU) on our website.  

    Google Analytics is a web analytics service that allows us to collect and analyze data about the behavior of visitors to our website. Google Analytics uses cookies for this purpose, which enable an analysis of the use of our website. Personal data in the form of online identifiers (including cookie identifiers), IP addresses, device identifiers and information about interaction with our website are processed in the process. 

    Some of this data is information that is stored in the terminal device you are using. In addition, further information is also stored on your end device via the cookies used. Such storage of information by Google Analytics or access to information that is already stored in your terminal device only takes place with your consent. 

    Google Ireland will process the data thus collected on our behalf in order to evaluate the use of our website by the users, to compile reports on the activities within our website and to provide us with further services related to the use of our website and the internet. In doing so, pseudonymous usage profiles of the users can be created from the processed data. 

    The setting of cookies and the further processing of personal data described here takes place with your consent. The legal basis for the data processing in connection with the Google Analytics service is therefore DP Act 843 section 20(1) and Art. 6 section 1 letter a GDPR. You can revoke this consent at any time with effect for the future. If you have questions about deleting or correcting your personal data, please initiate a chat with us or send us an email at any time. 

    We only use Google Analytics with IP anonymization enabled. This means that the IP address of the user is shortened by Google Ireland within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The IP address transmitted by the user’s browser is not merged with other data. 

    You can also prevent the collection of information generated by the cookie by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout. 

    If you visit our website via a mobile device, you can deactivate Google Analytics by clicking on this link. 

    1. Google Maps

    We use Google Maps of Google Ireland Limited (Google Ireland/EU) on our website to display maps. For such an integration, a processing of your IP address is technically necessary so that the content can be sent to your browser. Your IP address is therefore transmitted to Google and Google may set its own cookies. This processing of personal data serves our legitimate interest in integrating the map service into our website. Legal basis for the data processing carried out in this regard DP Act 843 section 20(1b) and Art. 6 section 1 letter f GDPR. 

    In the case of Google services, the transmission of data to Google Inc. in the USA cannot be ruled out. Please also note the information in the section “Data transfer to third countries”. Further information on data protection at Google can be found in Google’s privacy policy at https://www.google.com/policies/privacy. 

    1. YouTube

    We use the YouTube service of Google Ireland Limited (Google Ireland/EU) on our website to integrate videos. For such an integration, a processing of your IP address is technically necessary so that the content can be sent to your browser. Your IP address is therefore transmitted to Google and Google may set its own cookies. We use YouTube in “extended data protection mode” so that no cookies are set by YouTube to analyze user behavior. 

    This processing of personal data serves our legitimate interest in integrating the video service into our website. The use of YouTube takes place on the legal basis of DP Act 843 section 20(1b) and Art. 6 section 1 letter f GDPR. 

    With YouTube, a transmission of data to Google Inc. and YouTube LLC in the USA cannot be ruled out. Please note the information in the section “Data transfer to third countries”. Users can find further information on data protection at Google in Google’s privacy policy at https://www.google.com/policies/privacy. 

    III. Data processing on our Social Media 

    We operate company pages on multiple social media platforms via which we offer further opportunities to obtain information about our company and for exchange. We operate company pages on the following social media platforms: 

    • Facebook 
    • Instagram
    • Twitter  
    • LinkedIn 
    • YouTube 
    • Tik Tok 

    Visiting a company page on social media can result in your personal data being processed. The information in your social media account constitutes personal data. This also encompasses messages and statements made with the account. Additionally, certain information about your visit to a company page is often collected automatically during your visit. 

    1. Data Processing during the visit of a social media Page 
      1. Facebook and Instagram Page 

    Certain information about you is processed relating to your visit to our Facebook or Instagram page on which we present our company or individual products. Facebook Ireland Ltd (Ireland/EU – ‘Facebook’) is the sole controller of this processing. Further information about the processing of personal data by Facebook is available via https://www.facebook.com/privacy/explanation. 

    Facebook provides the opportunity to object to certain processing activities; corresponding information and opt-out-methods are available via https://www.facebook.com/settings?tab=ads. 

    Facebook provides us with anonymized statistics and insights for our Facebook and Instagram page, which enable us to gain knowledge about the ways in which people interact with our page (so called ‘insights’). These insights are created based on certain information about persons who have visited our page. Facebook and we are joint controllers of this processing. The processing serves our legitimate interest in evaluating the ways in which people interact with our page and improving our page based on this. This finds its legal basis in DP Act 843 section 20(1b) and Art. 6 section 1 letter f GDPR. It is impossible to match the information obtained via insights to individual accounts which interact with our Facebook page. We have concluded an agreement with Facebook on joint controllership in which the data protection duties are allocated between Facebook and us. Details of the processing of personal data for the creation of insights and of the agreement we concluded with Facebook are available via https://www.facebook.com/legal/terms/information_about_page_insights_data. Regarding these processing activities, you may also exercise your rights (see above ‘Your Rights’) against Facebook directly. Further information is available in Facebook’s privacy statement via https://www.facebook.com/privacy/explanation. 

    Please note that user data is also processed in the USA and other third countries according to Facebook’s data protection guidelines. Facebook only transfers user data to countries for which the European Commission has made an adequacy decision pursuant to Art. 45 GDPR or based on appropriate safeguards pursuant to Art. 46 GDPR. 

                    2. LinkedIn Company Page

    Generally, the LinkedIn Ireland Unlimited Company (Ireland/EU – ‘LinkedIn’) is the sole controller of the processing of your personal data relating to a visit to our LinkedIn page. Further information on the processing of personal data by LinkedIn are available via: https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy. 

    If you visit or follow our LinkedIn company page, LinkedIn processes personal data to provide us with anonymized statistics and insights which enable us to gain knowledge about the ways in which interact with our page (so called ‘insights’). For this purpose, LinkedIn processes such data that you already shared with LinkedIn by adding it to your profile like, for example, position, country, field of work, seniority, company size and employment status. Further, LinkedIn collects information on how you interact with our LinkedIn company page, for example whether you follow our LinkedIn company page. LinkedIn does not share personal data with us by providing us with the insights. We only have access to a summarized version of the insights. Also, we are unable to make conclusions about individual members from the information in the insights. LinkedIn and we are joint controllers of the processing regard the page insights. The processing serves our legitimate interest in evaluating the ways in which people interact with our page and improving our page based on this. This finds its legal basis in Art. 6 section 1 letter f GDPR. We have concluded an agreement with LinkedIn on joint controllership in which the data protection duties are allocated between LinkedIn and us. The agreement is available via https://legal.linkedin.com/pages-joint-controller-addendum. The agreement stipulates the following: 

    • LinkedIn and we have agreed that LinkedIn is responsible for enabling you to exercise your rights pursuant to the GDPR. In order to do so, you can contact LinkedIn online via (https://www.linkedin.com/help/linkedin/ask/PPQ?lang=de) or via the contact details in the data protection guidelines. You can contact the Data Protection Officer of LinkedIn Ireland via the following link: https://www.linkedin.com/help/linkedin/ask/TSO-DPO. You can also reach out to us via the contact details mentioned above for the exercise of your rights relating to the processing of your personal data for insights. In such a case, we will forward your request to LinkedIn. 
    • LinkedIn and we have agreed that the Irish data protection commission shall be the responsible supervisory authority monitoring the processing for insights. You always have the right to lodge a complaint with the Irish data protection commission (see dataprotection.ie) or any other supervisory authority. 

    Please note that user data is also processed in the USA and other third countries according to LinkedIn’s data protection guidelines. LinkedIn only transfers user data to countries for which the European Commission has made an adequacy decision pursuant to Art. 45 GDPR or based on appropriate safeguards pursuant to Art. 46 GDPR. 

                    3.Twitter 

    Generally, Twitter Inc. (USA) is the sole controller of the processing of your personal data relating to your visit to our Twitter account. Further information on the processing of personal data by Twitter Inc. is available via https://twitter.com/de/privacy. 

                    4. YouTube 

    Generally, Google Ireland Limited (Ireland/EU) is the sole controller of the processing of your personal data relating to your visit to our YouTube channel. Further information on the processing of personal data by YouTube and Google Ireland Limited is available via https://policies.google.com/privacy. 

                    5. Processing of Data you Share with us via our Company Pages 

    Additionally, we process information which you provide us with via the respective social media platform. Such information can include the username, contact details or a message to us. Generally, we only process this personal data if we have expressly requested you to share this data with us like, for example, in connection with a survey. We are the sole controller of such processing activities. 

    We process this data in pursuit of our legitimate interest to reach out to persons submitting requests. The legal basis for this is DP Act 843 section 20(1b) and Art. 6 section 1 letter f GDPR. 

    Additionally, we might process such data shared with us for purposes of evaluation or marketing. Such processing is based on DP Act 843 section 20(1b) and Art. 6 section 1 letter f GDPR and serve our legitimate interest to develop our product range and inform you about our product range. Further data processing can take place if you have consented (Art. 6 section 1 letter a GDPR) or if this serves to fulfil a legal obligation (Art. 6 section 1 letter c GDPR).

    IV. Further data processing

    In certain cases, we process personal data that we have received from you not online but in other ways. 

    1. Donation

    If you support us or one of our projects with a donation, we use the personal data received in this process to process your donation. 

    The legal basis for the processing is in each case DP Act 843 section 20(1a) and Art. 6 section 1 letter b GDPR. 

     

    September 2022 

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