Legal
Privacy Policy
This policy explains how Eastern Eye Konsult collects, uses, stores and protects personal data submitted through this website and in connection with events we organise.
About this policy
Eastern Eye Konsult (the legal entity name is to be confirmed — see document header) operates this website at eekgh.org and organises events in Ghana. This policy describes how we handle personal data in connection with those activities.
Our primary legal framework is the Data Protection Act, 2012 (Act 843) of the Republic of Ghana and the principles published by the Ghana Data Protection Commission. Where we process personal data of individuals located in the European Economic Area, the United Kingdom or other jurisdictions with their own data protection laws, those laws may additionally apply to that specific processing. We do not make a blanket claim of compliance with any particular regime.
This policy does not constitute legal advice. It is a working document that must be reviewed by qualified legal counsel before publication.
Information we collect
We collect personal data only where you actively provide it to us or where it is generated by your use of this website.
- RSVP submissions: full name, email address, phone number, number of guests, organisation name, attendance confirmation and any message or special request you include.
- Contact form submissions: full name, email address, optional phone number, subject and message.
- Event attendance: where you attend an event we organise, we may record your attendance, seating and any protocol requirements you have communicated.
- Website usage data: standard server logs may record your IP address, browser type, referring URL and pages visited. This data is used for security and operational purposes only.
- Cookies: see our Cookie Policy for details of any cookies set by this website.
We do not collect sensitive personal data (such as health information, political opinions or religious beliefs) unless you voluntarily include it in a message or special request, in which case we use it only to accommodate your request.
We do not knowingly collect personal data from children under 13. See Section 13 (Children's privacy) for more detail.
How we use your information
We use personal data for the following purposes:
- To respond to enquiries submitted through the contact form.
- To process RSVP submissions, manage event attendance lists and arrange seating and protocol.
- To communicate event information, updates or changes to people who have registered for an event.
- To coordinate with venues, caterers and other service providers strictly where necessary to deliver an event you have registered for.
- To maintain records of events we have organised, for operational and historical purposes.
- To operate and maintain the security of this website.
We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.
We do not use your personal data for direct marketing without your separate consent.
Lawful basis for processing
Under the Ghana Data Protection Act, 2012 (Act 843), personal data must be processed lawfully, fairly and transparently. We rely on the following bases:
- Consent: where you submit an RSVP or contact form, you are providing information voluntarily for the stated purpose.
- Legitimate interests: website security, fraud prevention and the operational management of events we organise.
- Legal obligation: where we are required to retain records under Ghanaian law.
Where the GDPR applies to specific processing activities (for example, where we process data of individuals in the EEA), we identify the applicable lawful basis under Article 6 GDPR for those activities. The bases above correspond broadly to Article 6(1)(a) (consent), Article 6(1)(f) (legitimate interests) and Article 6(1)(c) (legal obligation) respectively.
EEK to confirm: does the organisation process data of EEA/UK residents in a way that brings GDPR into scope? If so, a full GDPR Article 6 analysis should be completed by legal counsel.
Data sharing and third-party processors
We do not sell, rent or trade personal data.
We may share personal data with the following categories of third party, strictly where necessary:
- Event venues: to arrange seating, catering and access for registered attendees.
- Catering and hospitality providers: name and dietary/access requirements only, where provided.
- Technology service providers: hosting, email delivery and form processing services used to operate this website. These providers act as data processors under our instruction.
- Professional advisers: legal, accounting or insurance advisers where required.
- Regulatory authorities: where we are required to disclose information by law or court order.
EEK to confirm: list the specific technology providers used (hosting platform, email service, analytics, form backend). Each processor should be identified here with a brief description of what data they receive.
We require third-party processors to handle personal data securely and only for the purposes we specify. We do not authorise processors to use personal data for their own purposes.
International data transfers
This website is operated from Ghana. If you access it from outside Ghana, your data may be transferred to and processed in Ghana.
Where we use technology service providers whose servers are located outside Ghana, personal data may be transferred internationally. We take steps to ensure that such transfers are subject to appropriate safeguards.
EEK to confirm: identify the countries where data processors are located. Where transfers occur to countries without an adequacy decision under Act 843, confirm what safeguards are in place (e.g. contractual clauses, processor's own certifications).
Where the GDPR applies to specific processing, international transfers outside the EEA are subject to the requirements of Chapter V GDPR. We rely on appropriate safeguards for any such transfers.
Data retention
We retain personal data only for as long as necessary for the purposes described in this policy, or as required by law.
EEK to confirm specific retention periods, for example: contact form submissions retained for [X months]; RSVP records retained for [X years] after the event; event attendance records retained for [X years]. These periods should be set in consultation with legal counsel.
When personal data is no longer required, we delete or anonymise it securely.
Data security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction or alteration.
This website is served over HTTPS. Form submissions are transmitted securely.
Access to personal data is restricted to personnel who need it to perform their role.
No method of transmission over the internet or electronic storage is completely secure. While we take reasonable precautions, we cannot guarantee absolute security.
EEK to confirm: describe any additional security measures in place (e.g. access controls, encryption at rest, incident response procedures). This section should be reviewed by the organisation's IT or security adviser.
Your rights under the Ghana Data Protection Act
Under the Data Protection Act, 2012 (Act 843), you have the following rights in relation to your personal data:
- Right of access: you may request a copy of the personal data we hold about you.
- Right to correction: you may request that inaccurate or incomplete data be corrected.
- Right to deletion: you may request that we delete your personal data where we no longer have a lawful basis to retain it.
- Right to object: you may object to processing carried out on the basis of legitimate interests.
- Right to complain: you have the right to lodge a complaint with the Ghana Data Protection Commission.
To exercise any of these rights, please contact our data protection contact (see document header). We will respond within a reasonable time and in accordance with Act 843.
We may need to verify your identity before processing a request.
Additional rights where GDPR applies
Where the GDPR applies to specific processing activities involving individuals in the EEA or UK, those individuals additionally have:
- Right to data portability (Article 20 GDPR): to receive personal data in a structured, commonly used, machine-readable format where processing is based on consent or contract.
- Right to restriction of processing (Article 18 GDPR): to request that we restrict processing in certain circumstances.
- Right to withdraw consent (Article 7(3) GDPR): where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.
- Right to lodge a complaint with a supervisory authority in your country of residence.
EEK to confirm with legal counsel whether GDPR applies to any of the organisation's processing activities, and if so, which supervisory authority is the lead authority.
California privacy rights (CCPA/CPRA)
The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) apply to businesses that meet specific thresholds relating to annual gross revenue, volume of personal information processed, or revenue from selling personal information.
EEK to confirm with legal counsel whether the organisation meets the CCPA/CPRA applicability thresholds. If it does not, this section should be removed or replaced with a statement that CCPA/CPRA does not apply. Do not claim CCPA compliance if the thresholds are not met.
We do not sell personal information as defined under the CCPA/CPRA.
Children's privacy
This website is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13.
If you believe we have inadvertently collected personal data from a child under 13, please contact us immediately using the details in the document header and we will delete it promptly.
Event attendance by minors is subject to the terms communicated for each specific event, including any requirement for parental or guardian consent.
Links to third-party websites
This website may contain links to third-party websites. We are not responsible for the privacy practices of those websites. We encourage you to read their privacy policies before providing any personal data.
Changes to this policy
We may update this policy from time to time to reflect changes in our practices, technology or legal requirements. The effective date and last updated date in the document header will be updated accordingly.
Where changes are material, we will take reasonable steps to notify users, for example by posting a notice on this website.
Continued use of this website after a policy update constitutes acceptance of the revised policy.
Contact and complaints
For questions about this policy, to exercise your data rights, or to raise a concern about how we handle personal data, please contact:
EEK to supply: data protection contact name, email address, postal address and any reference number required by the Ghana Data Protection Commission.
If you are not satisfied with our response, you have the right to lodge a complaint with the Ghana Data Protection Commission at www.dataprotection.org.gh.
