Privacy Notice
Last updated July 1st, 2023
PRIVACY NOTICE
This privacy notice for THE NOAH'S PROJECT LBG (doing business as THE NOAH'S PROJECT) ('Company,' 'we,' 'us,' or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:
- Visit our website at www.noahsproject.org or any website of ours that links to this privacy notice
- Download and use our mobile application - The Noah's Project, or any other application of ours that links to this privacy notice
- Engage with us in other related ways - including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@noahsproject.org.
Summary of Key Points
This summary provides key points from our privacy notice. You can find out more details about any of these topics in the full notice below.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with THE NOAH'S PROJECT and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We do not process sensitive personal information, unless necessary with your consent or as otherwise permitted by applicable law.
Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do I exercise my rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the app or Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information we collect may include:
- Your Name
- Email Address
- Your Country
Sensitive Information. We do not process sensitive information, unless necessary with your consent or as otherwise permitted by applicable law.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by Paystack or Hubtel.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account.
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including bluetooth, calendar, camera, and other features. You may change our access in your device's settings.
- Mobile Device Data. We automatically collect device information such as your mobile device ID, model, manufacturer, operating system, version information, browser type, and Internet Protocol (IP) address.
- Push Notifications. We may request to send you push notifications regarding your account or certain features. You may turn them off in your device's settings.
Information automatically collected
In Short: Some information - such as your Internet Protocol (IP) address and/or browser and device characteristics - is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, device name, country, location, and information about how and when you use our Services.
The information we collect includes:
- Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, including your IP address, device information, browser type, and activity information.
- Device Data. Information about your computer, phone, tablet, or other device you use to access the Services, including IP address, device and application identification numbers, location, browser type, hardware model, and Internet service provider and/or mobile carrier.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers, and other services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and social media platforms. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data, IP addresses, social media profiles, and custom profiles.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, including:
- To facilitate account creation and authentication and otherwise manage user accounts.
- To deliver and facilitate delivery of services to the user.
- To respond to user inquiries/offer support to users.
- To send administrative information to you, including details about our products and services, changes to our terms and policies.
- To fulfill and manage your orders, payments, returns, and exchanges.
- To enable user-to-user communications.
- To request feedback and to contact you about your use of our Services.
- To send you marketing and promotional communications, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
- To deliver targeted advertising to you.
- To protect our Services as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To identify usage trends.
- To determine the effectiveness of our marketing and promotional campaigns.
- To save or protect an individual's vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law, like with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:
- Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, for example to send special offers, develop personalized advertising, analyze Services usage, support marketing activities, or prevent fraudulent activities.
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.
In legal terms, we are generally the 'data controller' under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific or implied permission to use your personal information for a specific purpose. You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted to process your information without your consent, including:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with include:
- Ad Networks
- Affiliate Marketing Programs
- Cloud Computing Services
- Communication & Collaboration Tools
- Data Analytics Services
- Data Storage Service Providers
- Finance & Accounting Tools
- Government Entities
- Order Fulfillment Service Providers
- Payment Processors
- Performance Monitoring Tools
- Product Engineering & Design Tools
- Retargeting Platforms
- Sales & Marketing Tools
- Social Networks
- Testing Tools
- User Account Registration & Authentication Services
- Website Hosting Service Providers
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs. We obtain and store on your device your location for 3 months. You may revoke your consent anytime by contacting us.
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
- Other Users. When you share personal information or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly available outside the Services.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.
The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We do not at the moment, but may use cookies and other tracking technologies to collect and store your information in the future. This will be made known to you when the need arises.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information in the foreseeable future, even though at the moment we do not. Specific information about how we use such technologies and how you can refuse certain cookies will be set out in our Cookie Notice.
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information.
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Europe. If you are accessing our Services from outside Europe, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in Europe, Ghana, and other countries.
Please be sure to review the relevant sections of this Privacy Notice for additional details relevant to The Noah's Project LBG's participation in the EU-US and Swiss-US Privacy Shield.
9. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us, or 3 months past the termination of the user's account, or 12 months past the start of the idle period of the user's account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
11. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@noahsproject.org.
12. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in Section 17.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the contact details provided in Section 17 or updating your preferences. Please note that this will not affect the lawfulness of the processing before its withdrawal.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying 'STOP' or 'UNSUBSCRIBE' to the SMS messages that we send, or by contacting us using the details provided in Section 17.
Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account, or contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at info@noahsproject.org.
13. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California.
CCPA Privacy Notice
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
| B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | NO |
| C. Protected classification characteristics under California or federal law | Gender and date of birth | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
| G. Geolocation data | Device location | NO |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
| J. Education information | Student records and directory information | NO |
| K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics | NO |
| L. Sensitive personal information | Account login information, drivers' licenses, health data, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and sex life or sexual orientation | NO |
We will use and retain the collected personal information as needed to provide the Services or for:
- Category A – Log In purposes
- Category B – Not Applicable
- Category C – Not Applicable
- Category D – Processing Purchases on our platform
- Category E – Not Applicable
- Category F – Security checks
- Categories G through L – Not Applicable
We may also collect other personal information outside of these categories through instances where you interact with us in the context of:
- Receiving help through our customer support channels
- Participation in customer surveys or contests
- Facilitation in the delivery of our Services and to respond to your inquiries
How do we use and share your personal information?
The Noah's Project LBG collects and shares your personal information through:
- Targeting cookies/Marketing cookies
- Social media cookies
- Beacons/Pixels/Tags
- Social media plugins such as "Like" buttons and "Share" widgets
More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email at info@noahsproject.org, by calling at 233-50-319-2221, or by referring to the contact details at the bottom of this document.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
The Noah's Project has never disclosed or sold any personal information categories to third parties for a business or commercial purpose in the preceding twelve (12) months.
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
- Whether we collect and use your personal information
- The categories of personal information that we collect
- The purposes for which the collected personal information is used
- Whether we sell or share your personal information to third parties
- The categories of personal information that we sold, shared, or disclosed for a business purpose
- The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose
- The business or commercial purpose for collecting, sharing, or selling personal information
- The specific pieces of personal information we collected about you
Right to Non-Discrimination
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information, including:
- Social security information, drivers' licenses, state ID cards, passport numbers
- Account login information
- Credit card numbers, financial account information, or credentials allowing access to such accounts
- Precise geolocation
- Racial or ethnic origin, religious or philosophical beliefs, union membership
- The contents of email and text, unless the business is the intended recipient of the communication
- Genetic data, biometric data, and health data
- Data concerning sexual orientation and sex life
To exercise your right to limit use and disclosure of sensitive personal information, please email info@noahsproject.org.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf.
- You may request to opt out from future selling or sharing of your personal information to third parties.
Financial Incentives. We do not sell users' data and are not in a position to offer a financial incentive in exchange for the retention, or sale or sharing of a consumer's personal information.
To exercise these rights, you can contact us by email at info@noahsproject.org, or by referring to the contact details at the bottom of this document.
15. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
'Consumer' means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
'Personal data' means any information that is linked or reasonably linkable to an identified or identifiable natural person. 'Personal data' does not include de-identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
Your rights with respect to your personal data include:
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling
The Noah's Project has not sold any personal data to third parties for business or commercial purposes. The Noah's Project will not sell personal data in the future belonging to website visitors, users, and other consumers.
You may contact us by email at info@noahsproject.org or by referring to the contact details at the bottom of this document.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at info@noahsproject.org. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
16. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Dennis Owusu Afriyie, by email at owusuafriyie@gmail.com, or by post to:
THE NOAH'S PROJECT LBGDennis Owusu Afriyie
P. O. Box AF 898
Adenta-Accra, Ghana
If you have any further questions or comments, you may also contact us by post at the following corporate address:
THE NOAH'S PROJECT LBGP. O. Box AF 898
Adenta-Accra, Ghana
Phone: 00233-50-319-2221
