Kwanza Network Privacy Policy

Privacy Policy

Effective Date: August 16, 2025

Kwanza Network ("we," "us," or "our") is committed to protecting the privacy and personal data of our users, participants, partners, and visitors to our website (https://kwanzanetwork.com/) and those engaging with our programs and services. As an organization based in Ghana, we operate in compliance with the Data Protection Act, 2012 (Act 843) ("DPA"), which regulates the processing of personal data to safeguard individual privacy rights. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information. By using our website, applying to our programs, or interacting with our services, you consent to the practices described in this policy.

We are registered as a data controller with the Data Protection Commission of Ghana (DPC) where required under the DPA. If you have any questions about this policy or our data practices, please contact us at the details provided in Section 12.

1. Information We Collect

We collect personal data that is necessary for providing our services, facilitating program participation, and improving user experiences. Personal data refers to any information that identifies or can be used to identify an individual, as defined under the DPA. The types of information we may collect include:

• Personal Identification Information: Name, date of birth, gender, nationality, and passport or ID details (for program applications and international travel arrangements). Contact details such as email address, phone number, postal address, and social media handles.
• Professional and Educational Information: Educational background, qualifications, CV/resume, academic transcripts, and references (submitted during program applications). Employment history, skills, and career interests (to match participants with suitable projects or opportunities).
• Sensitive Personal Data: In limited cases, we may collect sensitive data such as health information (e.g., for travel insurance or accommodations during programs) or ethnic origin (for diversity monitoring in cultural exchange programs). Such data is processed only with your explicit consent and in strict compliance with DPA requirements for sensitive data.
• < excepto: Usage and Technical Data: Website interaction data, including IP address, browser type, device information, pages visited, and time spent on our site (collected via cookies and analytics tools). Log data from program applications or inquiries, such as submission timestamps.
• Other Information: Testimonials, feedback, or stories shared by participants (with your consent for publication). Payment information if applicable (e.g., for program fees, though our programs are often sponsored; processed via secure third-party providers). Information from partners, such as host institutions in Ghana or international collaborators.

We do not collect more data than is necessary (data minimization principle) and ensure it is relevant to the purposes outlined below.

2. How We Collect Information

We collect personal data through various methods, ensuring transparency and lawfulness as required by the DPA:

• Directly from You: When you submit an application for our immersive programs (e.g., the October 26 – December 10, 2025 cohort), contact us via email or forms on our website, sign up for newsletters, provide testimonials, or participate in events/blog discussions.
• Automatically: Through cookies, web beacons, and analytics tools (e.g., Google Analytics) when you visit our website. See Section 9 for details on cookies.
• From Third Parties: From partners like host institutions, universities, or referral sources (e.g., for verifying qualifications), or publicly available sources (e.g., social media for program promotion).
• During Programs: Through interactions in Ghana-based placements, such as project feedback forms or cultural exchange activities.

We will always inform you at the point of collection if data provision is mandatory or voluntary.

3. Purposes for Processing Your Information

We process personal data for legitimate, specified purposes in line with the DPA's purpose limitation principle. These include:

• Administering program applications, selections, and placements (e.g., matching participants to projects in Ghana).
• Facilitating cultural exchanges, travel arrangements, and certifications from Kwanza Network and host institutions.
• Communicating with you about programs, updates, blogs, events, or opportunities (e.g., newsletters on leadership and growth).
• Improving our services, website, and user experience through analytics and feedback.
• Publishing testimonials or stories (with your explicit consent) to promote our mission.
• Complying with legal obligations, such as reporting to the DPC or Ghanaian authorities.
• Marketing our programs (e.g., sending invitations to future cohorts), but only with your consent where required.

We do not process data for incompatible purposes without notifying you and obtaining consent if needed.

4. Legal Basis for Processing

Under the DPA, we process personal data based on one or more of the following grounds:

• Consent: Where you have freely given specific, informed consent (e.g., for newsletters or sensitive data).
• Contractual Necessity: To fulfill our obligations under program agreements or applications.
• Legitimate Interests: For activities like website analytics or program improvements, balanced against your rights.
• Legal Obligation: To comply with Ghanaian laws or DPC requirements.
• Public Interest: For initiatives promoting education, cultural exchange, and youth development in Africa.

5. Sharing and Disclosure of Information

We may share your personal data with trusted parties, ensuring appropriate safeguards:

• Service Providers: Third-party vendors for website hosting, email services, analytics (e.g., Google), or payment processing, bound by data processing agreements compliant with the DPA.
• Partners: Host institutions in Ghana, international collaborators (e.g., in Nigeria or Rwanda), or universities for program facilitation and certifications.
• Authorities: If required by law, such as to the DPC, courts, or regulatory bodies.
• Successors: In the event of a merger, acquisition, or restructuring of Kwanza Network.

We do not sell your data. For international transfers (e.g., to participants from outside Ghana), we ensure adequate protection levels, such as contractual clauses or consent.

6. Data Security

We implement reasonable technical, administrative, and physical measures to protect your data from unauthorized access, loss, or breach, in accordance with DPA Section 28 (integrity and confidentiality principle). This includes encryption, access controls, regular audits, and staff training. In case of a data breach, we will notify you and the DPC as required under the DPA.

7. Data Retention

We retain personal data only as long as necessary for the purposes described (storage limitation principle). For example:

• Application data: Up to 2 years after program completion for follow-up or references.
• Website analytics: Anonymized and retained indefinitely for trends.
• Legal records: As required by Ghanaian law (e.g., 7 years for financial data).

Data is securely deleted or anonymized when no longer needed.

8. Your Rights Under the DPA

As a data subject, you have rights under the DPA (Sections 28-40), including:

• Access: Request a copy of your personal data.
• Rectification: Correct inaccurate or incomplete data.
• Erasure ("Right to be Forgotten"): Request deletion where data is no longer necessary or consent is withdrawn.
• Objection: Object to processing based on legitimate interests or for direct marketing.
• Restriction: Restrict processing in certain cases (e.g., while verifying accuracy).
• Portability: Receive your data in a structured format (where applicable).
• Withdraw Consent: At any time, without affecting prior processing.

To exercise these rights, contact us (Section 12). We will respond within one month, free of charge unless requests are excessive. You can also complain to the Data Protection Commission (https://dataprotection.org.gh/) if unsatisfied.

9. Cookies and Tracking Technologies

Our website uses cookies to enhance functionality and analyze usage. Cookies are small files stored on your device.

• Essential Cookies: For site operation (e.g., session management).
• Analytics Cookies: To track visits and improve content (e.g., via Google Analytics).
• Marketing Cookies: For targeted promotions (if applicable).

You can manage cookies via browser settings. By using our site, you consent to cookies unless opted out. We do not use cookies for profiling without consent.

10. Children's Privacy

Our programs are for graduates and professionals (typically 18+). We do not knowingly collect data from children under 16 without parental consent. If we discover such data, we will delete it.

11. Changes to This Policy

We may update this policy to reflect changes in our practices or legal requirements. Updates will be posted on our website with the revised effective date. We encourage periodic review.

12. Contact Us

For questions, rights requests, or concerns:

• Email: info@kwanzanetwork.com
• Postal Address: Kwanza Network, Accra, Ghana
• Phone: +233558594859

Thank you for trusting Kwanza Network with your personal data. We are dedicated to fostering growth while respecting your privacy.