GHANA TELECOMMUNICATIONS COMPANY LIMITED (Telecel Ghana) a company incorporated under the laws of the Republic of Ghana and having its registered office at Manet Tower A, South Liberation Link, Airport-City, Accra, PMB 221, Accra-North. Telecel Ghana has endeavoured to make this Privacy Policy clear, concise, and understandable. If you need any clarification, please do not hesitate to contact us at compliance@telecel.com.gh. Telecel Ghana is committed to respecting your privacy. Telecel Ghana has established this Privacy Policy so that you can understand the care with which we intend to treat your information. This Privacy Policy sets forth our policies and practices regarding the collection, use and disclosure of personal information (your "Data") we receive from you for purchasing our Virtual Private Cloud Service ("the Service"). By using the Service, you acknowledge and agree to the policies and practices described in this Privacy Policy. From time to time, we may make changes to this Privacy Policy to reflect any changes to our privacy practices in accordance with changes in legislation, regulation or best practices. We will notify you about material changes to this Policy. We encourage you to periodically review this Privacy Policy to stay informed about our privacy policies and practices. We have published this updated Privacy Statement to take into account new requirements and to explain how we collect, store and use personal data.

By purchasing our Service, you voluntarily and willingly provide us with certain information, including personally identifiable information, which we collect in order to provide the Service. As applicable in the General Data Protection Regulations (GDPR) and Data Protection Act 2012 (Act 843), Telecel Ghana may have cause outlined below to process Personal Information both as a Processor and as a Controller. Personally identifiable information refers to information about you that can be used to contact or identify you, and information on your use of the Service ("Personal Information"). Personal Information that we collect may include, but is not limited to, your company name, phone number, billing address or other billing information, email address and business postal address. Personal Information may also include information you supply to us concerning your preferences and interests expressed in the course of use of the Service.

We collect your information from you in the following ways:

Registration: When you register to become a user of our Service, you provide us with Personal Information to create your account. If you decide not to share certain information, you may not receive the full benefit of being a user or have access to all of the features and functionality of the Service.

Website Usage: When you visit our Website, our servers automatically record information that your browser sends whenever you visit. This information may include, but is not limited to, your computer's Internet Protocol address, browser type, the web page you were visiting before you came to our Website and information you search for on our Website. We may also collect information about the fact that you use certain features and functionality of our Service and your responses to our surveys and research initiatives.

Service Usage: When you purchase and use our Service, we track your use of the Service and your viewing of content on the Service, including tracking:

• Performance and reliability, such as how quickly the Service responds when you click a button, how many problems you experience with the Service and how quickly information is sent or received over a network connection.


• Application use, such as the features of the Service that you use the most often and how often you use Help resources.


• Certain information about your computer Service and hardware, such as your IP address, operating system version, web browser version, your hardware ID (which indicates the device manufacturer, device name, and version), and your regional and language settings. Although when a report is sent to us, standard computer information is sent as well. This information is sent to us when you are connected to the Internet and will identify you based on the information you submit when you use the Service.

Cookies: Like most websites, we use "cookies" and web log files to collect information to track usage and trends, to improve our Service, to deliver a customized experience, and to provide third party advertising. A cookie is a small data file that resides in the memory of your computer, mobile phone or other device and enables us to recognize you when you return to our Website or log into our Service. We may use "persistent cookies" to save your registration ID and login password for future logins to the Website. We may also use "session ID cookies", which expire after a short period of time or when you close your browser. Session ID cookies are used to identify a particular visit and are used to enable certain features of the Website or Service, to better understand how you interact with the Website and Service, and to monitor aggregate usage and web traffic routing on the Website. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the Website you visit. If you do not accept cookies, however, you may not be able to use all portions of the Website, receive the full benefit of being a user or have access to all of the features and functionality of the Service. Log Files, IP Addresses and Information About Your Computer and Mobile Device: When you use the Service or visit our Website, the communications standards on the Internet result in our automatically receiving the URL of the site from which you came from and the site to which you are going when you leave our Website or Service. We also receive the IP address of your computer, your computer or mobile device operating system, the type of web browser you are using, and the name of your ISP or mobile carrier.

Consent to Use of Your Information: By submitting information, including Personal Information, to Telecel Ghana, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy. You have the right to withdraw your consent to Telecel Ghana's collection and use of your information by changing your account settings or closing or terminating the Virtual Private Cloud, but your withdrawal of consent will not be retroactive. We may use the information you provide to (i) provide our Service and Website to you and administer your use of our Service and Website, (ii) improve and enhance the Service and/or Website and their features and functionality, (iii) to communicate with you and fulfil requests you may make and (iv) to provide you with information and announcements with respect to our Service.

Telecel Ghana Communications: Telecel Ghana may use your Personal Information to communicate with you through email and text messages and notices posted at the Company Website or your Company account and to provide you with customer support. If you decide at any time that you no longer wish to receive any such communications, please follow the "unsubscribe" instructions provided in any of the communications sent to you, or update your "account settings" information. Please note that even if you opt out of receiving messages from us, we may still send you messages as may be required to provide you with customer support or otherwise with respect to your account.

Improvements and Customization: We may also use the information provided by you or obtained through your use of the Service and our Website to improve our Website, services, features and content, to customize your user experience, and to better understand your needs and interests.

Management and Administration: We use information we obtain by technical means (such as the automatic recording performed by our servers or through the use of cookies) for the above purposes as well as to monitor, measure and analyze use of the Service and our Website to generate and derive useful data and information concerning the interests, characteristics and website use behaviour of our users, and to verify that visitors to the Website meet the criteria required to process their requests.

Non-Personal Information: Because Non-Personal Information does not personally identify you, we may use such information for any purpose, at our sole discretion, unless otherwise noted in this Privacy Policy. In addition, we reserve the right to share Non-Personal Information with affiliates and other third parties, for any purpose. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we do combine any Non-Personal Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined.

General: We do not sell or rent your Personal Information to third parties for marketing purposes. Further, we only share your Personal Information with third parties as described in this Privacy Policy, including to carry out your instructions or to provide the Service, unless otherwise compelled by law or as necessary to enforce our agreements with you or to protect the rights or property of Telecel Ghana or its users or the public. We may provide aggregated anonymous data about the usage of the Service to third parties for purposes that we deem, in our sole discretion, to be appropriate.

Your Account Profile: We will display the Personal Information you select in your profile page and elsewhere in the service according to the preferences you select in your "account settings". This information will be made available for public viewing to Company's users and we encourage users to think carefully about the information disclosed in their profile pages. You can review and revise your profile information at any time.

Service Providers, Business Partners and Others: We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Website-related services (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Website's features) or to assist us in analysing how the Service or our Website is used. These third parties have access to your Personal Information only for purposes of performing these tasks on our behalf and are bound by confidentiality agreements that restricts the use of your Personal Information.

Compliance with Legal Process; Protection of Company, its Users and the Public: We may be required to disclose your Personal Information, profile information and/or information with respect to your use of the Service and your activities as a user if required by subpoena or other legal process or requirement or if Company reasonably believes that such disclosure is necessary (i) to investigate, prevent or take action with respect to suspected or actual illegal activities or to assist government enforcement agencies, (ii) to protect the safety of any person from death or serious bodily injury, (iii) prevent fraud or abuse of the Service or Website, Telecel Ghana's users or the public, (iv) to enforce our agreements with you, (v) to investigate and defend ourselves against any third party claims or allegations or to protect the security or integrity of our Website or Service, (vi) to exercise or protect the rights and property of Telecel Ghana, its users and the public.

Sharing with Companies within our Corporate Family: We may share your personal information within our group of affiliated companies as well as our parent company. This sharing enables us to provide you with information about products and services which might interest you. To the extent that our parent company and corporate affiliates have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy. They also will comply with applicable laws governing the transmission of promotional communications and, at a minimum, give you an opportunity in any commercial email they send to choose not to receive such email messages in the future.

Business Transfers: Telecel Ghana may sell, transfer or otherwise share your information to a third party in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy of Company and you agree that any such third party will have the right to continue to use your Personal Information and other information that you provide to us or which we obtain through your use of the Service.

You may access, review, revise, correct, or delete the Personal Information provided in your registration or account profile by changing your "account settings." If you update any of your information, we may keep a copy of the information that you originally provided to us in our archives for uses documented in this policy.

You have a number of rights under data protection legislation, which have been strengthened under the GDPR. If you would like to request to review, correct, update, suppress or otherwise limit our use of your Personal Information that has been previously provided to us, you may contact us by email at compliance@telecel.com.gh. If you are concerned about the manner in which we have collected and used your personal data, please contact us using the contact details above – we will do our best to help.

We will respond to your request in accordance with applicable law. For your protection, we will only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. In each event, you must clearly indicate the information that you wish to have changed or suppressed. We will endeavour to comply with your request as soon as reasonably practicable and in compliance with applicable law. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed. Finally, we are not responsible for removing or suppressing information from the databases of third parties with whom we have already shared your Personal Information or limiting their use of your Personal Information. If you wish to change or suppress information provided to an affiliate or third party, please contact them directly.

Customer Community, Blogs and Profiles: We may make other services available through our Website and Service (for example, message boards, forums, "profile pages" and blogs) to which you are able to post information and materials (collectively referred to as the "Customer Community"). Please note that any information you disclose through the Customer Community may be available to visitors to the Website and to the general public. We urge you to exercise discretion and caution when deciding to disclose Personal Information, or any other information, via the Customer Community. We are not responsible for the use of any Personal Information you disclose through the Customer Community.

Security of Your Personal Information: Telecel Ghana has appropriate measures in place to help ensure that your Data is protected against unauthorised access or use, alteration, unlawful or accidental destruction, cyber-crime and accidental loss. Although we make reasonable efforts as a service provider to protect your Data from loss, misuse, or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the Internet. Telecel Ghana shall take reasonable and appropriate technical and organisational measures against the unauthorised or unlawful deliberate interference to your Data, however, there is still some risk that criminals could find a way to thwart our security systems. There is no guarantee that your Data may not be accessed, disclosed, altered or destroyed by breach of any of Telecel Ghana's physical, technical or managerial safeguards and we are not responsible for third party circumvention of your privacy settings or Telecel Ghana's security measures. You are responsible for maintaining the secrecy of your unique password and account information and for controlling access to your Company account.

Your Obligations: As a user (i) you must comply with the then current version of this Privacy Policy and (ii) you must keep your password and account information confidential. Any violation of these guidelines may result in the suspension, restriction or termination of your account at Telecel Ghana's discretion.

Retention Period: We will retain your information for as long as is necessary to: (1) provide the use of the Service; (2) invoice to you your use of the Service and to maintain records until invoicing for the Service cannot be lawfully challenged and legal proceedings may no longer be pursued; (3) communicate with you regarding other services that we offer; (4) comply with applicable legislation, regulatory requests and relevant orders from competent courts; (5) enforce our agreements with you; or (6) fulfil any of the other purposes detailed in this Privacy Policy.

Contacting Us: We are committed to privacy and will only use the information you provide us in accordance with this Privacy Policy. If you have any comments or questions regarding this Privacy Policy, please contact us at compliance@telecel.com.gh.