Ladder Africa Privacy Policy

Ladder Africa is strongly committed to protecting your privacy and complying with your choices. Both personal and non-personal information collected is safeguarded according to the highest data protection standards worldwide. We maintain a robust and effective data protection program that complies with existing laws and follows the principles outlined under the General Data Protection Regulation (GDPR) and Ghana’s Data Protection Act, 2012.

Key Definitions

• Data Controller: Ladder Technology Systems GH Ltd, responsible for determining the purposes and means of processing personal data.
• Personal Data: Information that can identify you directly or indirectly, such as name, contact details, financial or identification information.
• Processing: Any operation performed on personal data, including collection, storage, or use. .
• Platform: Ladder’s website and mobile application collectively.

1.1 Our Commitment

Your information will not be shared, rented, or sold to any third party. We use state-of-the-art security measures to protect your data from unauthorized users and give you the ability to control what you share with us (opt-out). Ladder Africa processes data in accordance with GDPR principles—ensuring transparency, accuracy, and security at all times.

We are guided by the following data protection principles:

• Processed lawfully, fairly, and transparently in relation to individuals.
• Collected for specific, legitimate purposes and not further processed in a way incompatible with those purposes.
• Adequate, relevant, and limited to what is necessary.
• Accurate and kept up to date
• Retained no longer than necessary
• Processed securely, protecting against unauthorized access or loss.

1.2. Notice

We will clearly inform you when information that personally identifies you ("personal information") is requested and allow you to choose whether to provide it. Typically, this occurs when you subscribe to our product updates, newsletters, or other online services.

2.1. Data Collected and Purpose

Depending on the nature of your interactions with us, we may retain the following categories of personal and financial data:

• Identification and contact details: name, address, phone number, email address, date of birth, and identification documents.
• Financial information: bank details, transaction history, payment card information (stored securely and tokenized where applicable).
• Account information: login credentials, security questions, and preferences.
• Technical and device data: IP address, browser type, device identifiers, operating system, and log data.
• Communications and correspondence: messages, customer support inquiries, and correspondence.

2.2. Duration of Retention

We also collect limited usage data to enhance app performance and stability. Data is never sold or shared for marketing purposes without your explicit consent.

Personal and financial data are retained for as long as you maintain an active account with us and for a minimum period thereafter as required by financial regulations.

In compliance with regulations, we are legally required to retain customer identification and transaction data for a minimum of five (5) years after the end of the business relationship or the completion of a transaction.

Where no legal or regulatory retention requirement exists, data will be deleted or anonymized within 12 months of account closure or inactivity.

2.3 Consent

By providing your personal information, you consent to its use for the stated purposes and acknowledge that Ladder Africa is an authorized holder of such information. You may withdraw consent or opt out of communications at any time by following the unsubscribe link in our emails or contacting us directly.

3. Legal Basis

We process personal data under lawful bases, including performance of contract, compliance with legal obligations, legitimate business interests, and user consent where required. You may withdraw consent at any time by contacting us at [email protected].

4. Age Restriction

You affirm that you are over 18 years of age and have the capacity to enter into agreements with Ladder. Our services are not directed toward minors, and we do not knowingly collect data from anyone under 18 years old.

5. How We Use Your Information

We use your personal information to manage your account, execute financial transactions, provide wealth management tools, comply with legal obligations, improve our services, and communicate with you about updates and security alerts.

6.1 Information We Collect

We collect personal and non-personal data, including your name, contact details, identification, device data, and usage patterns.

6.2 Additional Information We Collect

In addition to standard data, Ladder’s app and website may collect limited technical data such as motion, orientation, and camera input when necessary for security or visual functionality. Access is subject to your explicit device permissions.

7.1. Use of Apple TrueDepth Camera Data

Ladder’s mobile app may use Apple’s TrueDepth camera technology to enable enhanced visual or augmented reality experiences.

All TrueDepth data is processed exclusively on your device and is never collected, transmitted, or stored by Ladder or any third party. We do not access, record, retain, or share facial geometry data or related imagery. TrueDepth data is used solely to improve in-app visual performance and is not used for identification, authentication, marketing, or analytics. Ladder complies fully with Apple’s App Store Review Guideline 5.1.1 and Developer Program License Agreement

7.2. LADY AI and Automated Design Support

Our in-app digital assistant, LADY AI, processes anonymized or pseudonymized inputs to deliver personalized financial education and guidance. Data processed through LADY AI is never sold, shared, or used for automated decisions with legal consequences. All AI systems are governed by Ladder’s AI Governance Policy, ensuring fairness, human oversight, and compliance with Ghana’s Data Protection Act and global AI standards.

8. Cookies and Analytics Enhancements

We use cookies and analytics technologies to improve website and app performance, detect bugs, and understand aggregate user behavior. These do not collect biometric or personally identifiable data unless explicitly provided by you.

9. Third-Party Services

We may use reputable third-party service providers for limited functions such as analytics, payment processing, and customer support. These providers only have access to the information necessary to perform their services and are contractually obligated to protect your data and use it solely for authorized purposes.

10. Location Data

Some app features may request access to your device’s location data to offer localized insights or recommendations. This information is processed only on your device and is not stored or transmitted to Ladder Africa servers.

11. Access to Your Information

You have the right to review and correct any personal data you’ve shared with us. To ensure accuracy, please contact us if your information changes or you wish to verify the data we hold.

12. Data Retention and Deletion

We retain your data only as long as necessary to deliver our services or meet legal obligations. You may request data deletion at any time by contacting [email protected]. Once your account is deleted, associated data is removed unless retention is required by law.

13. Security of Information

We employ multiple layers of security, including encryption, firewalls, and restricted access, to prevent unauthorized access, disclosure, or destruction of your data. Sensitive information transmitted online is protected through Secure Sockets Layer (SSL) technology.

14. Children’s Privacy

Ladder’s services are intended for users aged 18 and above. We do not knowingly collect personal information from individuals under 18. If we become aware of such data, we delete it immediately upon notice.

15. How to Opt-Out

You may opt out of receiving communications, product updates, or newsletters from Ladder Africa by clicking the unsubscribe link in our emails or contacting our support team.

16. Cookies and Analytics Enhancements

We use cookies and analytics technologies to improve website and app performance, detect bugs, and understand aggregate user behavior. These do not collect biometric or personally identifiable data unless explicitly provided by you.

17. Biometric and Camera Data Transfer

No biometric or camera data (including TrueDepth or facial geometry) leaves your device. All other data transfers comply with Ghana’s Data Protection Act (Act 843) and utilize encryption and contractual safeguards.

18. Changes to the Policy

If we make changes to this Privacy Policy, we will update the revision date below and post the changes on our website. If significant changes are made, we will notify you by email.

19. Additional Website Security Measures

Financial and biometric-related interactions on our app are protected by SSL encryption and verified through secure API gateways that comply with industry security standards.

20. Delete Your Ladder Account

When a user deletes their Ladder account, all personal information, including phone number, address, email, and next of kin details, will be permanently expunged from our database. It’s important to note that you cannot have access to your account, including moving money in and out of it.

When the retention period expires or upon receiving a valid deletion request:

• Your personal data will be permanently deleted from our active databases and systems.
• Backup and archival data, where immediate deletion is not technically feasible, will be securely encrypted and anonymized until it is automatically overwritten or destroyed according to our backup lifecycle policy.
• Anonymized data that can no longer identify an individual may be retained for statistical or analytical purposes.

To delete your Ladder account:

• Go to the profile section
• Select “Help”
• Choose “Close Account”

Contact Us

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