Your privacy rights in Ghana

Effective Date

This Ghana Privacy Supplement is effective as of November 12, 2026.

Who This Supplement Covers

This supplement applies to you if you live in Ghana. It adds the duties and rights that the Data Protection Act, 2012 (Act 843) sets out to our Privacy Policy, which tells you what personal data we collect, how we use and share it, and how long we keep it. Read the two documents together. Where they differ, this supplement applies to you.

Delalify LTD is responsible for the personal data of everyone who lives in Ghana, as our General Terms provide. Delalify LTD is the data controller of the personal data that we collect about you for Delalify's purposes, such as your account, your billing records, and your use of our websites.

• Company: Delalify LTD
• Company registration number: CS020410222
• Address: Liberation Road, 7th Floor, Atlantic Tower, Accra, Ghana
• Digital address: GL-126-4836
• Email: privacy@delalify.com

When a business uses Delalify to process your personal data, such as an employer that keeps staff records in People or a company that sends you messages through Channels, that business is the data controller of that data. Delalify LTD then acts as the business's data processor under Exhibit D of our Data Processing Agreement, so send your request about that data to the business first.

The Data Protection Act, 2012 (Act 843) governs how we process your personal data. Act 843 requires us to process it lawfully and reasonably, to collect only what a specific purpose needs, to keep it accurate and secure, to keep it no longer than that purpose needs, and to let you take part in how we process it.

The Data Protection Commission enforces Act 843. Section 27 requires a data controller that intends to process personal data to register with the Commission, and section 50 requires it to renew that registration every two years. Delalify LTD registers with the Commission as a data controller under those sections.

Delalify LTD has appointed a Data Protection Supervisor under section 58 of Act 843 to monitor how Delalify complies with the Act. You can reach the Data Protection Supervisor at privacy@delalify.com. Put 'Data Protection Supervisor' in the subject line so that we can pass your message on directly.

Act 843 gives you the rights below. To use any of them, write to privacy@delalify.com and say which right you want to use. We may ask you for proof of your identity before we act, as section 32 allows.

Right to Be Informed

Sections 23 and 27 require us to tell you why we collect your personal data, who collects it, who receives it, and how you can access and correct it. Our Privacy Policy and this supplement give you that information. If you want a description of the personal data that we hold about you, the purposes for which we process it, and the people to whom we may disclose it, ask us at privacy@delalify.com.

Right to Give and Withdraw Consent

Under section 20, we process your personal data with your prior consent, unless we need it for a contract with you, the law authorizes or requires the processing, or another ground in that section applies. We ask for your consent before we set statistics, preferences, or targeting cookies and before we send you marketing emails. You can withdraw that consent at any time on our preferences page, through the unsubscribe link in each marketing email, or by writing to privacy@delalify.com.

Right to Access Your Personal Data

Under sections 32 and 35, you can ask us to confirm whether we hold personal data about you, to describe it, and to give you a copy of it in a form that you can understand. We will reply within forty (40) days of receiving your request, as section 35(10) requires.

Right to Have Your Personal Data Corrected

Under section 33, you can ask us to correct or delete personal data about you that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or unlawfully obtained. You can update most of your account information in your account settings, and you can send any other request to privacy@delalify.com. We will either make the change or show you the evidence that supports the data, we will tell you what we did, and we will tell each person to whom we disclosed the data about the correction.

Right to Object

Under section 20(2), you can object to our processing of your personal data, unless a law provides otherwise. When you object, we will stop that processing, as section 20(3) requires.

Right to Prevent Processing

Under section 39, you can write to us at any time to require us to stop, or not to begin, processing your personal data for a purpose or in a manner that causes or is likely to cause you unwarranted damage or distress. Within twenty-one (21) days of receiving your notice, we will tell you in writing that we have complied or intend to comply, or why we have not complied.

Right to Be Free from Automated Decision Making

Under section 41, you can write to us at any time to require that no decision that significantly affects you is based solely on the automated processing of your personal data. If we take such a decision about you, we will tell you as soon as reasonably practicable. You can then require us in writing, within twenty-one (21) days of our notice, to reconsider the decision, and within twenty-one (21) days of your notice, we will tell you in writing how we will comply. Under section 41(4), this right does not cover a decision that we take while we consider whether to enter into a contract with you, with a view to entering into that contract, or while we perform it, a decision that a law authorizes or requires, or a decision in other circumstances that the Minister prescribes.

Right to Be Free from Direct Marketing

Under section 40, we use your personal data for direct marketing only with your prior written consent, and you can require us at any time to stop. Use the unsubscribe link in any marketing email, or write to privacy@delalify.com, and we will stop sending you marketing messages.

Right to Compensation

Under section 43, if you suffer damage or distress because we breach Act 843, you are entitled to compensation from us, subject to the reasonable-care defense in section 43(2). Write to privacy@delalify.com with the details of your claim. You can also seek a remedy in a court with jurisdiction; our General Terms do not limit your statutory rights.

Right to Complain to the Data Protection Commission

You have the right to complain to the Data Protection Commission, which section 3 of Act 843 empowers to investigate complaints. The Complaints section of this supplement explains how.

Delalify Apps

When you use a Delalify app, we send personal data to the sub-processors on our subprocessor list, which process it in the United States, the European Union, Nigeria, and Ghana. The list gives the purpose and the location of each sub-processor. Each sub-processor signs a written agreement that requires it to protect personal data to the standard that data protection laws, including Act 843, require, as the Sub-Processors section of our Data Processing Agreement sets out.

Conjoin

A business chooses a region when it creates a Conjoin account, and Conjoin keeps the account's users, files, databases, messages, logs, backups, and search indexes in that region. Today, a business can choose the United States or the European Union. Conjoin is setting up a region in Ghana, called gh. Once that region opens, Conjoin will keep the users, files, databases, messages, logs, backups, and search indexes of each account in the gh region inside Ghana.

Conjoin Cloud Global, which operates in the United States, keeps the account-level data of every account, whichever region the account is in. That data covers the names, emails, and sign-ins of the account's team members, along with the account's API keys, plan, invoices, payments, settings, resource IDs, usage totals, and custom domains. Our Conjoin data residency page sets out which data stays in each region.

Section 37 of Act 843 treats some personal data as special personal data, which covers data about a child under parental control and data about a person's religious or philosophical beliefs, ethnic origin, race, trade union membership, political opinions, health, sexual life, or criminal behavior.

Delalify doesn't ask its customers or website visitors for special personal data for its own purposes. A business can put special personal data on Delalify only where the business and Delalify agree to it in writing or where a specific Delalify service requires that data, as Exhibits A and D of our Data Processing Agreement provide. The business also needs a ground under section 37 of Act 843 for processing that data.

If you are unhappy with how we handle your personal data, write to our Data Protection Supervisor at privacy@delalify.com so that we can try to resolve your concern.

You can also complain to the Data Protection Commission through its complaint form, where you say whether you complain as a data subject and whether you want to stay anonymous. The Commission investigates the complaint, and where it finds that we failed to meet a request or a notice, it can order us to comply, as sections 35, 39, 40, 41, and 44 of Act 843 provide.

Send every question about this supplement or about your personal data to privacy@delalify.com. You can also write to Delalify LTD at Liberation Road, 7th Floor, Atlantic Tower, Accra, Ghana (digital address GL-126-4836).