Privacy Policy

This Privacy Policy explains how Pulseown Mobile ("Pulseown Mobile", "we", "us", or "our") collects, uses, stores, and protects personal information when you visit https://pulseownmobile.com or interact with our services.

This policy is issued in compliance with the Data Protection Act, 2012 (Act 843) of the Republic of Ghana. Pulseown Mobile is a data controller for the purposes of Act 843.

This policy tells you what we do with your data. Where consent is required, we will ask for it clearly. Other processing may be necessary to review an application, perform a contract, meet a legal duty, or protect a legitimate business interest.

1. What Personal Data We Collect

We collect the following categories of personal data:

• Application and identity data: your full name, location, requested plan, employer details, device preference, budget information, and, where required after the first review, a valid government-issued ID.
• Contact data: email address, phone number, WhatsApp number, and physical address where needed.
• Employment and payroll data: employer name, employment confirmation, payroll approval, deduction instructions, and deduction records for an employer-backed plan.
• Transaction data: plan number, customer number, device details, amount due, amount paid, due date, payment date, remaining balance, payment method, receipt reference, and order history.
• Device management data: device serial number or international mobile equipment identity number, enrolment or control status, and management command or audit records where a supported device is enrolled during an active plan.
• Communication records: emails, messages, and notes from support interactions.
• Website technical data: IP address, browser type, and basic service logs needed for security and reliable operation.

We collect only the data that is necessary and proportionate to the purpose for which it is collected, in accordance with Section 17 of the Data Protection Act, 2012 (Act 843).

Device management does not give us permission to read your personal messages, photos, passwords, or banking information. We do not continuously track a device's location unless a separate feature, legal basis, and clear notice specifically allow it.

2. How We Use Your Personal Data

We use your personal data to:

• Process, confirm, and manage your hire-purchase application and agreement.
• Assess whether the direct-customer or employer-backed route is suitable for the application.
• Verify employment and administer an authorised payroll deduction with a participating employer or payroll provider.
• Deliver your device and confirm receipt.
• Record the device identifier and, where agreed and lawful, enrol or manage a supported device during an active plan.
• Send payment schedules, receipts, reminders, and confirmations related to your plan.
• Respond to enquiries, complaints, and support requests.
• Verify your identity for the purpose of entering into a hire-purchase agreement.
• Comply with legal and regulatory obligations applicable in Ghana, including obligations under the Revenue Administration Act, 2016 (Act 915).
• Improve our website and service quality through aggregate, anonymised analysis.

We do not sell, rent, or share your personal data with third parties for their own marketing purposes.

3. Legal Basis for Processing

Under the Data Protection Act, 2012 (Act 843), we process your personal data on the following lawful bases:

• Contractual necessity: processing is required to perform or enter into the hire-purchase agreement with you.
• Legal obligation: we are required to process and retain certain data under Ghanaian law (including the Revenue Administration Act, 2016, and the Hire-Purchase Act, 1974).
• Legitimate interests: we process data to operate our business, manage outstanding hire-purchase agreements, and prevent fraud — where this does not override your rights.
• Consent: where you have provided explicit consent for a specific use, such as receiving promotional communications. You may withdraw consent at any time.

4. Data Retention

We retain personal data only for as long as is necessary to achieve the purpose for which it was collected, as required by Section 31 of the Data Protection Act, 2012 (Act 843).

• Transaction and payment records (hire-purchase agreements, payment receipts, order confirmations): retained for a minimum of six (6) years from the date the transaction is completed, in compliance with the Revenue Administration Act, 2016 (Act 915).
• Unsuccessful or abandoned applications: normally retained for up to twelve (12) months, unless a longer period is required for a complaint, fraud review, or legal duty.
• Identity, employment, payroll, and device management records: retained for the active plan and then only for as long as needed for legal, accounting, dispute, security, or audit purposes.
• Support and communication records: retained for three (3) years from the date of last interaction, unless related to an unresolved dispute.
• Website technical data (server logs, analytics): retained for twelve (12) months, then automatically deleted or anonymised.

At the expiry of each retention period, personal data is securely deleted or de-identified in a manner that prevents reconstruction in intelligible form, as required by Act 843.

5. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures are reviewed periodically.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Data Protection Commission of Ghana and, where required, you directly, in accordance with our obligations under Act 843.

6. Sharing of Personal Data

We may share your personal data only in the following circumstances:

• Service providers: companies that help us host the website, manage email and cloud files, process payments, support customers, or manage supported devices. They may use data only to provide the agreed service.
• Participating employers and payroll providers: for an employer-backed application, we may share the minimum information needed to verify employment, obtain payroll approval, administer deductions, reconcile payments, and resolve errors.
• Legal and regulatory bodies: where required by a valid court order, statutory obligation, or lawful request from the Ghana Revenue Authority or another competent Ghanaian authority.
• Dispute resolution: where disclosure is necessary for mediation or arbitration proceedings under the Alternative Dispute Resolution Act, 2010 (Act 798).

We do not share your personal data with any party for commercial marketing purposes without your explicit consent.

7. Cookies and Analytics

Our website may use session cookies necessary for basic website functionality. We do not use tracking cookies or third-party advertising cookies without your consent.

If we introduce web analytics tools, this policy will be updated to identify those tools, the data they collect, and how to opt out. You can control cookie settings at any time through your browser preferences.

8. Your Rights Under the Data Protection Act, 2012 (Act 843)

As a data subject under Ghanaian law, you have the following rights:

• Right of access: to request a copy of the personal data we hold about you (Section 18, Act 843).
• Right to correction: to request that we correct any inaccurate or incomplete personal data we hold.
• Right to deletion: to request that we delete your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to object: to object to certain types of processing, including direct marketing.
• Right to withdraw consent: where processing is based on your consent, you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, contact us at support@pulseownmobile.com. We will respond within a reasonable time, and no later than within 30 days of receiving your request.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Data Protection Commission of Ghana at www.dataprotection.org.gh.

9. International Data Transfers

Some of the service providers we use may process or store data outside Ghana. This can include website hosting, email, cloud storage, payment support, and device management providers. When data is transferred outside Ghana, we take reasonable steps to use providers and arrangements that protect the data and meet the requirements of the Data Protection Act, 2012 (Act 843).

10. Children's Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected personal data from a minor, please contact us immediately at support@pulseownmobile.com and we will delete such data promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated version will be published on this page with a revised "Last updated" date. We encourage you to review this policy periodically.

12. Contact and Data Controller Information

For questions about this Privacy Policy, to exercise your data rights, or to raise a data protection concern:

• Business name: Pulseown Mobile
• Email: support@pulseownmobile.com
• Phone: +233 500 741 015
• Address: Broadway Road, AM446, Tarkwa, Ghana
• Country: Republic of Ghana