Privacy notice

1. Purpose

This Privacy Notice explains how Horizonlumen (“we”, “us”, “our”) collects, uses, and protects personal data in line with the Data Protection Act, 2012 (Act 843) of Ghana and guidance from the Data Protection Commission.

2. Data controller

Horizonlumen is the data controller for information gathered through this website, consultations, workshops, and client engagements.

Contact details:
31 Cape Coast Way, Cape Coast, Ghana
[email protected]
+233 27 991 3372

3. Information we collect

• Website analytics: aggregated usage data (page visits, device types). This data is anonymised before analysis.
• Contact messages: name, email, phone number, and message content submitted via our contact form or email.
• Engagement records: financial diaries, transaction summaries, and household objectives shared during advisory sessions.
• Operational data: invoices, contracts, and correspondence with partners and vendors.

4. Lawful bases for processing

We rely on the following lawful bases under the Data Protection Act:

• Consent: when households voluntarily share information for advisory purposes.
• Contractual necessity: when we need data to deliver agreed services.
• Legitimate interests: to analyse anonymised usage data and improve operations, provided such interests do not override individual rights.
• Legal obligations: to comply with tax, regulatory, or court requirements.

5. How we use information

• Delivering household financial guidance and customised resources.
• Scheduling consultations and responding to enquiries.
• Maintaining accurate records for accountability and review.
• Enhancing our services through aggregated, anonymised analysis.

6. Sharing and disclosure

We do not sell or rent personal data. Information may be shared only when:

• The household gives explicit consent (e.g., introductions to partner organisations).
• We engage trusted service providers (such as secure data storage platforms) under confidentiality agreements.
• Law enforcement or regulators request access under Ghanaian law.

7. Storage and retention

Data is stored in secure, access-controlled systems located in Ghana or jurisdictions with comparable protections. We retain personal data only for as long as necessary:

• Contact enquiries: up to 12 months after closure.
• Client engagement records: up to 24 months after the final review unless a longer period is required by law.
• Financial records: minimum duration required by the Ghana Revenue Authority.

We securely destroy or anonymise data after retention periods.

8. Your rights

Under the Data Protection Act, you may:

• Request access to your personal data.
• Ask for corrections to inaccurate or incomplete information.
• Withdraw consent for certain processing activities.
• Request deletion of data where applicable.
• Object to processing based on legitimate interests.

To exercise these rights, contact us via [email protected]. We will respond within 30 days.

9. International transfers

If we transfer data outside Ghana, we ensure comparable safeguards, such as contractual clauses or transfers to jurisdictions recognised by the Data Protection Commission.

10. Security measures

We implement administrative, technical, and physical controls, including encryption, access logs, staff training, and secure disposal procedures.

11. Children’s information

Our services primarily engage adults responsible for household finances. When minors are involved (e.g., education planning), a parent or guardian provides necessary information and consent.

12. Updates

We may update this notice to reflect legal changes or new practices. The “effective date” indicates the latest revision. Significant updates will be communicated via our website or direct email to clients.

13. Questions or complaints

Questions can be directed to [email protected] or by phone at +233 27 991 3372. You may also contact the Data Protection Commission of Ghana for unresolved concerns.