Privacy Notice for Ladder Technology Systems GH Ltd

1. Introduction

At Ladder, we value your privacy, and we are committed to safeguarding your personal information. All personal data provided by you shall be protected and kept confidential among our affiliates, representatives, and privies. In providing our services, we are committed to protecting your personal information and ensuring its security.

Throughout the website, the terms “We”, “Us” and “Our” refer to Ladder.

This Privacy Notice (this “Notice”) explains how we collect, use, share and protect your personal data in connection with your relationship with us, whether you are a current user or prospective user, or simply visiting our website or platform and every other person we hold information about.

This Notice also sets out rights and who you may contact for further information. By engaging with our services, you Consent to the practices described in this Privacy Notice. We encourage you to read through this notice carefully to understand our commitment to your privacy and how are manage your personal information.

Your use of our services, and any dispute over privacy is subject to this notice and our Terms of Service including applicable limitations on damages and the resolution of disputes. Our Terms of Services are incorporated by reference into this notice.

Our websites and services are not directed at you if we are prohibited by any law of any jurisdiction from making the information on our website available to you and is not intended for any use that would be contrary to local law or regulation.

2. Definitions

For the purpose of this Privacy Notice, the following terms shall have the meanings set forth below

Consent

means the Consent of the data subject which must be a freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they (by a statement or by a clear affirmative action) signify their agreement to the processing of personal data relating to them.

Cookies

means small files that Ladder Website or its service provider transfers to your computer's hard drive through your web browser (if you allow) that enables the website's or service provider's systems to recognize your browser and capture and remember certain information.

Processing

means any operation or set of any operations performed on personal data or sets of personal data, whether or not by automated means, such

Data Subject

means a living, identified, or identifiable individual about whom Ladder holds personal data;

Data Processor

means a person or organisation which processes personal data on behalf of a data controller. This includes Ladder, its employees and third-party service providers

Data Controller

means the natural or legal person or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this notice, Ladder is the data controller of all personal data relating to data subjects;

Website

means https://ladder.africa/ and any other websites operated by Ladder that link to or reference this Privacy Notice.

Data Protection Legislation

means all applicable data protection and privacy laws including, but not limited to the Data Protection Act, 2012 (Act 843) of Ghana and any successor legislation

Personal Data Breach

means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed

Platform

means collectively the company’s website and application provided by Ladder.

Service Providers

means third-party companies or individuals that provide services on our behalf, including but not limited to IT services, payment processing, financial management, auditing, and customer service.

Personal Information

means any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual or household which includes but not limited to name, contact details, financial information and other identifiers.

3. Legal Basis

3.1. By using our services, engaging with us, or providing us with your personal information, you acknowledge that your information may be processed on various legal bases as described in this Notice. These bases may include, but are not limited to, the performance of a contract, compliance with legal obligations, legitimate interests pursued by Ladder or a third party, and your explicit Consent where applicable. You may withdraw Consent at any time, subject to legal or contractual restrictions and reasonable notice.

3.2. Ladder may request your explicit Consent to process your personal information in specific situations, such as when we need to collect sensitive information or when required by applicable laws. However, not all processing activities will require Consent as they may be based on other legal grounds.

3.3. If you wish to withdraw your Consent to the processing of your personal information where Consent is the legal basis, you may do so by contacting us at58c Orphan Crescent, Labone, Accra. Please note that withdrawing Consent may affect our ability to provide certain services to you and may result in the termination of your account or services with us.

3.4. If your personal data is to be processed for a purpose different from that for which it was originally collected and that purpose was not disclosed at the time of collection, Ladder will seek your Consent for the new purpose unless the processing is permitted under another legal basis.

4. Age Restriction

4.1. You affirm that you are over the age of 18 years and have the capacity to enter a contract in your own name and fully understand the terms herein.

4.2. Individuals under 18 years old are only allowed to sign up for our services or provide us with their information when an adult above the age of 18 is signing a contract in their stead.

5. How we use your Information

Your personal information may be used for the following purposes:

5.1. To manage your account, provide financial recommendations, execute transactions and deliver various wealth management services offered to clients by Ladder.

5.2. To comply with legal and regulatory requirements including but not limited to anti-money laundering and tax reporting obligations.

5.3. To enhance our services by conducting research and analysis and understanding user behaviour on our website or platform.

5.4. To respond to your inquiries, send account statements, and provide updates or notices related to your accounts or our services.

6. Data Protection Principles

We, our employees, agents, and contractors strictly adhere to the Data Protection Legislation sets in order to ensure that your personal information is handled with the utmost security standard and care. All personal data must be:

6.1. Processed lawfully, fairly, and in a transparent manner in relation to the data subject;

6.2. Collected and processed for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further, processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes shall not be considered to be incompatible with the initial purposes;

6.3. Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;

6.4. Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes, for which it is processed, is erased, or rectified without delay.

6.5. Kept in a form which permits identification of data subjects no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific, or historical appropriate technical and organisational measures required by the Data Protection Legislation in order to safeguard the rights and freedoms of the data subject;

6.6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

7. Information we collect

7.1. Whenever you visit our website or use our application, you may ask for certain personal and non-personal data which may fall into the following categories:

7.1.1 Your personal information such as your name, address, email, phone number, date of birth, gender, means of identification, financial information, investment preferences, and other details necessary for us to provide our services.

7.1.2. Records of communications with you, including but not limited to emails, phone calls, and written correspondence.

7.1.3. Whenever you visit our website, our web servers automatically collect non-personal information such as the domain name of the internet access provider, the internet protocol address used to connect computer to the internet, the average time spent on our website, pages viewed, information searched for, access times, usage statistics about your interactions with the Platform, including information accessed, time spent on pages or the service, and other relevant statistics.

8. Information You Share on the Platform

8.1. Our platform may allow you to contribute content to our platform, such as reviews, testimonials, ratings or comments, this content may be displayed publicly. By submitting such content, you grant us the right to use, reproduce, modify, and display it on our platform or in our marketing materials, subject to any limitations set forth in our terms of service. In addition, if you have created a user profile and uploaded a photograph of yourself in connection with your Ladder account, other users of the service will be able to see your user profile information and your photograph when you submit information to the Platform while logged in to your Ladder account.

8.2. Ladder provide certain features on it platform and application such as forums, blogs, or community areas, may allow you to share information publicly. Any information you choose to share in these areas can be viewed and accessed by other users of the platform.

8.3. Where you share information or link your account with third-party services (e.g., social media platforms or financial institutions), those services may have access to certain information about you. Ladder will not be responsible for how third-party services handle your data.

9. Cookies and Tracking Technologies

We may use cookies and similar technologies to enhance your experience on our website. You can set your browser to refuse all or some cookies or to alert you when cookies are being sent. However, some parts of our website may not function properly without cookies.

10. Using your Personal Data

10.1. We primarily collect your personal data to ensure that we provide the most efficient services to you, monitor the use and improve our website/App and other legitimate interests. Your information will solely be used and disclosed for the following purposes:

10.2. To help us verify your identity;

10.3. To carry out our obligations ensuing from any contract entered into between you and us;

10.4. To provide you with the products, services and information you request from us and we offer to you;

10.5. To assist you with enquiries and improve our customer service;

10.6. To carry out marketing and advertising, including to send you marketing and advertising communications tailored to our services and your specific usage;

10.7. To assist us in carrying out marketing analysis and customer profiling, conduct research, including creating statistical, geolocational and testing information;

10.8. To analyse the accuracy, effectiveness, usability, or popularity of the service(s)

10.9. To generate and review reports and data about our user base and service usage patterns;

10.10. To facilitate the Platform’s technical functioning, including troubleshooting and resolving issues, securing the services, and preventing fraud and abuse;

10.11. To allow us to communicate with you in any way (including e-mail, telephone, and text or multimedia messages);

10.12. For our user reward program purposes;

10.13. To help prevent and detect fraud or loss;

10.14. To update our records;

10.15. To make recommendations and suggestions to you about services offered by us unless you have previously asked us not to do so;

10.16. To send you service or support messages, such as updates, security alerts, email notifications and/or newsletters;

10.17. To conduct investigations and risk assessments;

10.18. As required or permitted by law;

10.19. For compliance with legal and regulatory obligations; and

10.20. As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, the public, or our services

10.21. Employees, agents, contractors, or other parties working on behalf of Ladder shall collect your personal data only to the extent required for the performance of their job duties and only in accordance with this Notice.

10.22. Employees, agents, contractors, or other parties working on behalf of Ladder shall process your personal data only when the performance of their job duties requires it. Your personal data held by Ladder cannot be processed for any unrelated reasons.

11. Data Accuracy

It is important that the information you provide to us is accurate and complete. You are responsible for ensuring that the Personal Data you share with us is correct and for notifying us promptly of any changes or updates to your information. This includes changes to your contact details, financial situation, or any other relevant information.

We take reasonable steps to ensure that the Personal Data we collect, use, and store is accurate and relevant for the purposes for which it was collected.

12. Data Confidentiality

We treat all Personal Data you provide as confidential. We implement strict policies and procedures to ensure that your data is only accessed and used by authorized personnel for legitimate business purposes.

You have the right to request copies of all information we hold about you, provided such requests comply with applicable laws and regulations. While we are committed to safeguarding the information you entrust to us, you also play a crucial role in maintaining confidentiality. This includes, but is not limited to, implementing and enforcing appropriate security measures, such as keeping passwords and other platform login details confidential, adhering to physical security protocols and interacting only with authorized representatives of Ladder.

13. Disclosure

13.1. We will not sell, publish, or disclose your personal data to third parties, except as necessary to provide our services or as outlined in this notice. Your personal data will only be disclosed under specific circumstances such as;

13.1.1. explicit Consent has been given to Ladder to provide information about you from and to third parties to provide our services.

13.1.2. We may share your Personal Data with trusted third-party service providers who assist us in delivering our services, such as IT support, payment processing, or data analytics. These providers are bound by confidentiality agreements and are only permitted to use your data for the purposes specified by us.

13.1.3. You have the right to request an erasure of your data at any time, unless we have a legitimate interest or are required under applicable law to retain your data (we will advise you in writing, if so).

13.2. You may request at any time that we halt further dissemination of your data or cease to use your data.

13.3. If you submit content in a public forum or a social media post, or use a similar feature on our website, that content is publicly visible.

13.4. We may disclose personally identifiable information if required to do so by law or in the good faith belief that such action is necessary to (a) conform with the requirements of the law or comply with legal process served on us, or (b) act in urgent circumstances to protect the personal safety of users of our service or members of the public.

13.5. To the extent practicable and legally permitted, we will attempt to advise you prior to any such disclosure, so that you may seek a protective order or other relief limiting such disclosure.

14. International Transfer of your Personal Data

14.1. Ladder may transfer your Personal Data with third-party service providers located in other countries who assist us in delivering our services. . We ensure to comply with applicable laws in the recipient country or organisation before transferring your personal information to ensure that your personal data is protected regardless of where it is processed.

14.2. Where Ladder transfers your Personal Data to a country that is not recognized as having adequate data protection standards by relevant authorities, we will take appropriate measures to ensure that your data remains protected.

14.3. Transfer of your Data outside of Ghana shall be in accordance to the provision of Ghana Data Protection Act 2012 (Act 843). We will therefore only transfer your personal data out of Ghana on one of the following conditions:

14.3.1. Your explicit Consent has been obtained;

14.3.2. The transfer is necessary for the performance of a contract between you and Ladder

14.3.3. The transfer is necessary to conclude a contract between Ladder and a third party in your interest;

14.3.4. The transfer is necessary for reason of public interest;

14.3.5. The transfer is for the establishment, exercise or defense of legal claims;

14.3.6. The transfer is necessary in order to protect your vital interests or the interests of other persons, where you are physically or legally incapable of giving Consent.

14.4. Provided, in all circumstances, that you have been manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country, this provision shall not apply to any instance where you are answerable in duly established legal action for any civil or criminal claim in another country.

14.5. We will take all necessary steps to ensure that your personal data is transmitted in a safe and secure manner. Details of the protection given to your information when it is transferred outside Ghana shall be provided to you upon request.

14.6. Where none of the conditions stipulated in clause 14.4 and 14.5 of this notice are met, Ladder will engage with The Data Protection Commission of Ghana for approval with respect to such transfer.

15. Right of a Data Subject

15.1. As a data subject you are entitled to specific rights following principal rights under the Data Protection Legislation:

15.1.1. You have the right to be informed about the purpose of data collection and processing of your personal data.

15.1.2. You have the right to access your personal data held by Ladder. This includes the right to request copies of your data and information about how it is being processed.

15.1.3. You have the right to request that we rectify inaccurate personal information.

15.1.4. You may request at any time that we halt further dissemination of your data or cease to use your personal information.

15.1.5. You have the right to request the deletion or removal of your personal data.

15.2. Ladder respect your privacy and understand that you may prefer not to receive marketing or advertising communications from us. You can opt out of receiving marketing or advertising emails, simply click the "unsubscribe" link at the bottom of any of our emails or follow the instructions provided in the email or contacting us. Once you opt out, we will promptly process your request. Please note that it may take a few days to fully remove your details from our systems, so you may continue to receive emails during this short period.

16. Website Security

Ladder is committed to ensuring the security of your personal data and protecting our website from unauthorized access, breaches, and other security threats. In order to help protect your information from unauthorized access, we have implemented a variety of technical, administrative, and physical security measures to protect your personal data and ensure the integrity of our website. These measures include, but are not limited to encryption, firewalls, secure socket layer (SSL) technology, regular security audits, and intrusion detection systems.

17. Data Breach Management Procedure

In the event where there is any accidental or unlawful destruction, processing, loss, alteration, unauthorized disclosure of, or access to your personal data, we shall:

17.1.1. notify you within 24 hours of the occurrence of the data breach;

17.1.2. properly investigate the breach and take the necessary steps to mitigate such breach;

17.1.3. identify remediation requirements and track the resolution of such breach; and

17.1.4. notify the Data Protection Commission of Ghana and/or any other regulatory authority, where necessary.

18. Employee Training on Data Privacy

We are committed to ensuring that our employees who collect, access, and process your personal data are properly trained in data privacy and protection. We provide comprehensive training to develop the necessary knowledge, skills, and competence required to effectively manage and comply with this notice and the Data Protection Legislation.

To maintain a high standard of data protection, we will create and implement an annual capacity building plan for our employees. This will focus on enhancing their understanding of data privacy and protection in accordance with the requirements of the Data Protection Legislation.

19. Limitation of Liability

19.1. Your use of our website is at your own risk. We make no representations or warranties regarding the accuracy, completeness, or reliability of any content or information provided on the website. We are not responsible for any errors, omissions, or inaccuracies in the content.

19.2. Our website may contain links to third-party websites, your use of any third-party site is subject to the terms and conditions of that site, and Ladder will not be liable for any loss or damage arising from your use of or reliance on such sites.

19.3. In no event shall we, our affiliates, directors, employees, partners, or agents be liable for any direct, indirect, incidental, special, consequential, or punitive damages, including without limitation, loss of profits, data, use, goodwill, or other intangible losses, resulting from (i) your access to or use of or inability to access or use our website; (ii) any conduct or content of any third party on the website; (iii) any unauthorized access, use, or alteration of your transmissions or content; or (iv) any other matter related to the website or the processing of your personal data.

20. Changes to This Notice

We may update this Privacy Notice from time to time. We will notify you of any significant changes by posting the new notice on our website and updating the effective date at the top of this notice.

21. Contact Us

If you have any questions or concerns about this Privacy Notice or our data practices, please contact us at [email protected]