SMARTGIGGS PRIVACY POLICY
Effective Date: March 1, 2026
Platform: Smartgiggs (Website and Mobile Application)
Legal Entity: Discountbox Ltd
Registered Address: GK-0957-9743 Adjei Gbortsui, Oyibi
Contact Email: connect@smartgiggs.com
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1. INTRODUCTION AND OVERVIEW
1.1 Our Commitment to Your Privacy
Discountbox Ltd ("we," "us," "our," or "the Company") operates the Smartgiggs platform, an online services marketplace that connects Customers ("Buyers") with independent Service Providers ("Sellers," "Vendors," or "Freelancers").
Your privacy is important to us. We are committed to protecting your personal data and being transparent about how we collect, use, and share it. This Privacy Policy explains how we handle your personal information when you use the Smartgiggs Platform, in compliance with the Data Protection Act, 2012 (Act 843) of the Republic of Ghana .
1.2 Acceptance of Terms
By accessing or using the Smartgiggs Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, you must not use the Platform.
1.3 Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or Platform features. We will notify you of material changes via email or through a notice on the Platform. The "Effective Date" at the top of this policy indicates when it was last revised .
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2. WHO WE ARE (DATA CONTROLLER)
For the purposes of the Data Protection Act, 2012 (Act 843), Discountbox Ltd is the Data Controller . This means we determine the purposes and means of processing your personal data .
Our Contact Details:
- Company Name: Discountbox Ltd
- Registered Office Address: [Insert Full Physical Address in Ghana]
- Postal Address: [Insert P.O. Box if applicable]
- Email: [Insert Email, e.g., privacy@smartgiggs.com]
- Phone: [Insert Phone Number]
Data Protection Supervisor
We have appointed a Data Protection Supervisor (DPS) to oversee our compliance with data protection laws. You may contact our DPS at: [Insert Email, e.g., dps@smartgiggs.com] .
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3. WHAT PERSONAL DATA WE COLLECT
We collect different types of personal data depending on how you interact with the Platform. Personal data means any information relating to an identified or identifiable living individual .
3.1 Information You Give Us Voluntarily
| Category | Examples |
| :--- | :--- |
| Account Information | When you register, we collect your first name, last name, email address, phone number, and password . |
| Profile Information | You may choose to add a profile photo, bio, skills, location, and other details to enhance your profile . |
| Seller Information | If you register as a Seller, we collect additional information required for verification, including your Ghana Card or passport, Tax Identification Number (TIN), business registration certificate (if applicable), and GhanaPost GPS address . |
| Transaction Information | Details about services you offer, purchase, or sell, including Gig descriptions, pricing, delivery timelines, and order history. |
| Communications | Information you provide when contacting our Support Team, including chat messages, emails, and any attachments . |
| Reviews and Ratings | Feedback, reviews, and ratings you post about Sellers or Buyers. |
| Payment Information | When you make or receive payments, we collect financial data such as mobile money details, bank account information, or card details. Note: Full payment card details are processed by our third-party payment processors and are not stored by us . |
3.2 Information We Collect Automatically
| Category | Examples |
| :--- | :--- |
| Device Information | IP address, device type, operating system, browser type, mobile carrier, and hardware IDs . |
| Usage Data | How you interact with the Platform, including pages visited, features used, time spent, clicks, and searches . |
| Location Data | General location derived from your IP address. We may collect precise location data only with your explicit consent . |
| Advertising IDs | Apple Identifier for Advertising (IDFA) or Google Advertising ID (AAID) for analytics and advertising purposes . |
| Cookies and Similar Technologies | Information collected via cookies, web beacons, and tracking pixels. See our Cookies Policy for more details . |
3.3 Information from Third Parties
- Social Media Logins: If you register using Facebook, Google, or Apple, we receive information from your social media account, such as your name, email address, profile picture, and friends list (depending on your privacy settings) .
- Identity Verification Services: For Seller verification, we may use third-party services like Smile Identity Inc. to verify your identity against governmental sources. This may involve sharing your ID information with such providers .
- Invitations: If you were invited to join Smartgiggs by another user, we may receive your contact information from that person .
- Other Users: We may receive information about you from other users, such as when they leave a review about your services or report a transaction.
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4. HOW WE USE YOUR PERSONAL DATA
We process your personal data only for lawful purposes and as described in this policy. Under the Data Protection Act, we must have a lawful basis for processing .
4.1 To Provide and Operate the Platform
- Create and manage your account
- Facilitate transactions between Buyers and Sellers
- Enable communication between users
- Process payments and payouts
- Display listings, profiles, and reviews
4.2 To Verify Seller Identity and Prevent Fraud
- Verify identity documents and business registration
- Conduct background checks as required
- Detect and prevent fraudulent activity, money laundering, and other illegal conduct
- Comply with legal obligations under Ghanaian law
4.3 To Communicate With You
- Send service-related notifications (order confirmations, payment receipts, account updates)
- Respond to your inquiries and support requests
- Send important information about changes to our Terms or Policies
4.4 To Improve and Personalize Your Experience
- Analyze usage patterns to improve Platform functionality
- Customize content and recommendations based on your interests
- Conduct research and statistical analysis
4.5 For Marketing Purposes (with your consent where required)
- Send promotional emails about new features, special offers, or partner services (you may opt out at any time)
- Display personalized advertisements on the Platform or third-party sites
- Send push notifications for marketing (you can disable these in your device settings)
4.6 To Ensure Security and Compliance
- Monitor for violations of our Terms of Use
- Protect the integrity and security of our systems
- Comply with legal obligations, court orders, or regulatory requests
- Report criminal activity to law enforcement authorities
4.7 Lawful Basis for Processing
We process your data based on one or more of the following:
- Your consent (which you may withdraw at any time)
- Performance of a contract with you
- Compliance with legal obligations
- Our legitimate interests (e.g., improving our services, preventing fraud) that do not override your fundamental rights
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5. SHARING YOUR PERSONAL DATA
We do not sell, rent, or trade your personal data. We may share your information in the following circumstances:
5.1 With Other Users (as necessary to provide the Service)
| Data Shared | Recipient | Purpose |
| :--- | :--- | :--- |
| Your name, profile photo, and ratings | Other users | To identify you on the Platform |
| Gig details and descriptions | All users | To display your service offerings |
| Contact information (phone, email) | Buyers and Sellers | To facilitate communication and service delivery |
| Reviews and feedback you post | All users | To maintain marketplace transparency |
5.2 With Service Providers and Partners
| Category | Purpose | Examples |
| :--- | :--- | :--- |
| Payment Processors | To process payments and payouts securely | Mobile money providers, banks, card processors |
| Identity Verification Services | To verify Seller identity | Smile Identity Inc. |
| Cloud Hosting Providers | To store data securely | AWS, Google Cloud, Azure |
| Analytics Providers | To analyze usage and improve our Platform | Google Analytics |
| Customer Support Tools | To manage support tickets and communications | Zendesk, Intercom |
5.3 With Government Authorities and Law Enforcement
We may disclose your personal data when required by law or to protect our rights, including:
- To comply with a court order, subpoena, or legal process
- To respond to requests from the Data Protection Commission or law enforcement agencies
- To prevent or investigate suspected fraud, illegal activity, or violations of our Terms
- To protect the safety, rights, or property of Discountbox Ltd, our users, or the public
5.4 With Your Consent
We may share your information with third parties for other purposes if we have obtained your explicit consent.
5.5 Business Transfers
If Discountbox Ltd is involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you of any such change and outline your choices.
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6. YOUR RIGHTS AS A DATA SUBJECT
Under the Data Protection Act, 2012 (Act 843), you have the following rights regarding your personal data :
| Your Right | What It Means |
| :--- | :--- |
| Right to be Informed | To be aware of how your data is collected and used (this Privacy Policy fulfills this right) . |
| Right of Access | To request confirmation of whether we hold your personal data and receive a copy of that data . |
| Right to Rectification | To request correction of inaccurate, incomplete, or outdated personal data . |
| Right to Erasure (Deletion) | To request deletion or destruction of your personal data where we no longer have a valid reason to retain it . |
| Right to Restrict Processing | To request that we suspend processing of your data in certain circumstances (e.g., while verifying accuracy) . |
| Right to Object | To object to processing based on legitimate interests or for direct marketing purposes . |
| Right to Data Portability | To receive your data in a structured, commonly used format and transmit it to another controller (where technically feasible). |
| Right to Withdraw Consent | To withdraw your consent at any time, where processing is based on consent. Withdrawal does not affect the lawfulness of processing before withdrawal . |
| Right to Complain | To lodge a complaint with the Data Protection Commission if you believe your rights have been violated . |
How to Exercise Your Rights:
To exercise any of these rights, please contact our Data Protection Supervisor at: [Insert Email, e.g., privacy@smartgiggs.com].
We will respond to your request within forty (40) days of receipt, as required by Section 35 of the Data Protection Act . We may request proof of identity to verify your request before processing.
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7. DATA SECURITY
7.1 Our Security Measures
We are committed to protecting your personal data through appropriate technical and organizational measures, as required by Section 28 of the Data Protection Act . These measures include:
- Encryption: Data in transit is protected using SSL/TLS protocols. Sensitive data at rest is encrypted using industry-standard algorithms (e.g., AES-256) .
- Access Controls: Access to personal data is restricted to employees and contractors who need it to perform their job functions, based on the principle of least privilege .
- Authentication: We use strong authentication mechanisms, including two-factor authentication for administrative accounts .
- Regular Security Assessments: We conduct vulnerability testing, penetration testing, and security audits to identify and address risks .
- Firewalls and Intrusion Detection: We maintain firewalls and monitoring systems to detect and prevent unauthorized access .
- Staff Training: Our employees receive training on data protection and security best practices .
7.2 Third-Party Processors
Where we engage third-party data processors (e.g., cloud providers, payment processors), we ensure through contracts that they:
- Comply with the Data Protection Act
- Implement appropriate security measures
- Process data only on our instructions
- Maintain confidentiality obligations
7.3 Data Breach Notification
In the event of a data breach that poses a risk to your rights and freedoms, we will:
- Notify the Data Protection Commission as soon as practicable
- Notify affected individuals without undue delay
- Take steps to mitigate the impact and prevent future occurrences
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8. DATA RETENTION
8.1 How Long We Keep Your Data
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements .
| Data Type | Retention Period |
| :--- | :--- |
| Account Information | Until you delete your account, plus a reasonable period afterward to comply with legal obligations |
| Transaction Records | At least seven (7) years for tax and regulatory compliance |
| Verification Documents | As long as your Seller account is active, plus a period afterward to prevent fraud |
| Communications and Support Tickets | Up to [e.g., 3 years] to improve our service and resolve disputes |
| Usage Data and Analytics | Up to [e.g., 2 years] for analysis and improvement |
8.2 Deletion and Anonymization
After the retention period expires, we will securely delete or anonymize your personal data so that it can no longer be associated with you . Anonymized data may be used for research or statistical purposes indefinitely.
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9. INTERNATIONAL DATA TRANSFERS
As a Ghanaian company, we primarily store and process data within Ghana. However, we may transfer your personal data to countries outside Ghana in the following circumstances:
- Cloud Service Providers: We may use cloud infrastructure providers (e.g., AWS, Google Cloud) that operate globally. These providers are contractually bound to protect your data and comply with Ghanaian data protection standards .
- Identity Verification Services: Our verification partner (Smile Identity) may process data internationally .
- Payment Processors: Payment transactions may involve processors located outside Ghana.
When transferring data outside Ghana, we ensure that:
- The recipient country has adequate data protection laws, or
- We have contractual safeguards in place (e.g., standard data protection clauses), or
- We have obtained your explicit consent .
Section 45 of the Data Protection Act requires data controllers established outside Ghana but using equipment in Ghana to process data to comply with Ghanaian law .
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10. COOKIES AND SIMILAR TECHNOLOGIES
10.1 What Are Cookies?
Cookies are small text files stored on your device when you visit a website. They help us recognize you and remember your preferences .
10.2 Types of Cookies We Use
| Cookie Type | Purpose |
| :--- | :--- |
| Essential Cookies | Required for the Platform to function (e.g., authentication, security) |
| Functional Cookies | Remember your preferences and settings |
| Analytics Cookies | Help us understand how users interact with the Platform |
| Advertising Cookies | Deliver relevant advertisements and measure ad performance |
| Social Media Cookies | Enable social media sharing and integration |
10.3 Managing Cookies
You can control cookies through your browser settings. Most browsers allow you to:
- View what cookies are stored
- Delete individual or all cookies
- Block cookies from specific websites
- Block all cookies
- Set preferences for certain types of cookies
Please note that blocking essential cookies may affect the functionality of the Platform .
For more detailed information, please see our separate Cookies Policy .
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11. CHILDREN'S PRIVACY
Smartgiggs is not intended for individuals under the age of eighteen (18) . We do not knowingly collect personal data from children under 18. If you become aware that a child has provided us with personal data without parental consent, please contact us immediately. If we discover that we have collected personal data from a child, we will take steps to delete such information .
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12. THIRD-PARTY LINKS
The Smartgiggs Platform may contain links to third-party websites, services, or applications (e.g., payment processors, social media platforms). This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party sites you visit .
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13. REGISTRATION WITH DATA PROTECTION COMMISSION
Discountbox Ltd is registered as a Data Controller with the Data Protection Commission of Ghana in compliance with Section 27 of the Data Protection Act .
- Registration Number: [Insert your DPC Registration Number once obtained]
- Registration Fee Paid: [e.g., GHS 120 for Small Business/Startup category]
- Renewal Date: [Registration must be renewed every two years]
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14. CONTACT INFORMATION
14.1 For Privacy-Related Questions or Requests
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Supervisor:
Data Protection Supervisor
Discountbox Ltd
Email: [Insert Email, e.g., dps@smartgiggs.com]
Phone: [Insert Phone Number]
Address: [Insert Full Address]
14.2 Data Protection Commission (DPC)
You have the right to lodge a complaint with the Data Protection Commission if you are unsatisfied with our response :
Data Protection Commission, Ghana
Office Address: Pawpaw Street, East Legon, Behind Bawaleshi Melcom, Accra, Ghana
Postal Address: P.O. Box CT7195, Cantonments, Accra-Ghana
Email: info@dataprotection.org.gh
Phone: +233 (0)256301360
Website: www.dataprotection.org.gh
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END OF PRIVACY POLICY
By using Smartgiggs, you acknowledge that you have read and understood this Privacy Policy.