1. INTRODUCTION AND SCOPE

Independence explosion festival (“IEF”, “we”, “our” or “us”) is a Ghanaian non-profit organization focused on empowering disadvantaged communities (especially children and youths) in health, education, food security and economic development. Protecting personal data in our programs is a core part of our mission. This Privacy Policy describes how IEF collects, uses, discloses and safeguards Personal Data (any information relating to an identified or identifiable individual) in compliance with Ghana’s Data Protection Act, 2012 (Act 843, as amended) (“GDPA”) and principles of data protection (fairness, purpose limitation, data minimization, accuracy, security, transparency) consistent with international standards. This policy applies to all IEF operations in Ghana, including our website and any digital or in-person services. Users aged 15 years or older may provide data under this policy (see Section 14).

2. DEFINITIONS

For purposes of this policy:

• ●  Data Controller: IEF alone or jointly with others, as the entity determining the purposes and means of processing Personal Data.
• ●  Data Subject: A natural person to whom Personal Data relates (here, any Ghanaian resident interacting with IEF).
• ●  Personal Data: Any information that identifies or can be linked to an individual (e.g. name, contact, ID number, online identifiers). Sensitive categories (“Special Personal Data”) include data relating to health, beliefs, race, sexual life or a “child under parental control”.
• ●  Processing: Any operation on Personal Data (collecting, storing, using, disclosing, erasing, etc.).

3. PERSONAL DATA WE COLLECT

IEF collects Personal Data needed to provide our services and fulfil our mission (see Section 4). Categories of Personal Data may include:

• ●  Identification: Name, date of birth or age, national ID or passport number, gender.
• ●  Contact information: Address, phone number, email address.
• ●  Demographics: Nationality, place of residence, and other non-sensitive data relevant to program

eligibility or reporting.

• ●  Health and education (if applicable): Basic health or academic background when required (e.g.

for school support or medical aid, to the extent necessary and with consent).

• ●  Transaction and financial data: Records of donations or payments made to IEF, such as billing

information or bank account (only as needed to process contributions).

• ●  Professional or volunteer data: Occupation, workplace, educational institution, or volunteer

experience if volunteering.

• ●  Electronic data and usage: IP address, browser and device information, and website usage data

collected via cookies and similar technologies (see Section 9).

We do not collect “Special Personal Data” (sensitive categories) about children (under 18) without explicit consent from the child or their guardian. We collect data directly from you (via forms, applications, donations, etc.) or automatically (cookies) only as permitted by law. If we obtain Personal Data from third parties (e.g. partner organizations, vendors), we will do so only with your consent or under lawful exception.

4. PURPOSES OF DATA PROCESSING

We use Personal Data solely for specific, explicit, and lawful purposes consistent with our mission, including (but not limited to):

• ●  Service delivery: To manage community programs (education, healthcare, relief, etc.), enrolment in projects, beneficiary management and assessments.
• ●  Communication and support: To respond to inquiries or requests (e.g. helpdesk, information requests, volunteer coordination) and to provide support.
• ●  Fundraising and donor relations: To process donations, issue receipts, report on fund usage, thank and update donors, and manage fundraising campaigns.
• ●  Compliance and reporting: To satisfy legal obligations or internal policies (e.g. accounting, tax reporting, regulatory compliance) and for audits.

• Website and analytics: To operate and secure the website/service, analyse usage, and improve our online and mobile services.

Before or at the time of collection, we will inform you of the purpose(s) of processing, the types of data collected, whether provision of data is voluntary or mandatory, and any consequences of not providing data. Personal Data is processed only to the extent reasonably necessary for the stated purposes. If we need to use your data for a new purpose (materially different from those described here), we will notify you and obtain fresh consent.

5. LEGAL BASIS FOR PROCESSING

Under the Ghana Data Protection Act, processing of Personal Data generally requires the consent of the Data Subject. By using our services or submitting information, you consent to this processing (see Section 14). We also rely on legal obligations (e.g. compliance with laws), and our legitimate interests (e.g. fraud prevention, defence of legal claims) to the extent they do not override your rights. In all cases, IEF processes data lawfully, fairly, and transparently. For example, we will only process personal data if:

• ●  You have given consent.
• ●  It is necessary to perform a contract or provide a requested service to you.
• ●  It is required by law (e.g. accounting or welfare laws).
• ●  It is necessary to protect life or vital interests of you or another person.
• ●  It is required for public interest or official authority tasks.

Where consent is the basis, you have the right to withdraw consent at any time by contacting us (see Section 13).

6. USE OF COOKIES AND SIMILAR TECHNOLOGIES

Our website and online services use cookies and similar technologies (web beacons, tags, scripts) to enhance functionality and analyse usage. Cookies may store your preferences or track how you navigate the site. Most browsers allow you to disable cookies; however, blocking cookies may prevent some features from functioning. We do not sell cookie-derived data, and all usage data is handled in accordance with this policy. For details, see our separate Cookie Policy.

7. DATA RETENTION

IEF retains Personal Data only for as long as needed for the purposes collected or to comply with legal obligations. For example:

• ●  Data related to active programs or donor records is retained for the duration of your involvement plus any required archival or audit period.
• ●  Contact and communication records (e.g. email, support tickets) are kept as long as necessary to manage relationships or legal claims.
• ●  Website log and analytics data are retained for limited periods to improve security and service.
  If Personal Data becomes inaccurate or obsolete, or we no longer have authorization to hold it, we will

rectify or securely delete it upon your request or as required by law.

8. DATA SECURITY

We implement appropriate technical and organizational measures to protect Personal Data against unauthorized access, disclosure, alteration or destruction. These include encryption, access controls, firewalls, secure backups, regular security reviews, and staff training. We require any third-party processors (e.g. cloud providers, mailing platforms) to maintain comparable security measures under contract. All IEF staff and contractors handling Personal Data are bound by confidentiality obligations.

In the event of a data breach (unauthorized access or acquisition of Personal Data), we will promptly notify the Ghana Data Protection Commission and affected individuals as required by law, and take all reasonable steps to mitigate harm and restore security. If notification is delayed at the direction of law enforcement or the Commission, we will comply with that direction.

9. SHARING PERSONAL DATA

We do not sell or rent Personal Data. We may share data only in limited circumstances, including:

• ●  Service providers: Third-party vendors engaged to provide services (e.g. payment processors, IT support, analytics, mailing systems). Such providers process data on our behalf and are bound by confidentiality.
• ●  Affiliates and partners: With related organizations (e.g. project partners, affiliates) solely to fulfill program purposes, under strict usage controls.
• ●  Legal compliance: When required by law, regulation or court order (e.g. tax authorities, law enforcement) or to respond to legal claims.

• ●  Protection of rights: To protect the rights, privacy, safety or property of IEF, our users, or others (e.g. reporting fraud, prevention of illegal activities).
• ●  With your consent: For any other purpose you explicitly authorize (e.g. featuring your story or photo on our website, only if you consent).

When sharing data outside Ghana (e.g. cloud servers or international partners), we ensure compliance with applicable laws. Note that the Ghanaian Act does not expressly restrict transfers, but prohibits sale of personal data. We will take reasonable steps to safeguard your data in any jurisdiction.

10. DIRECT MARKETING

We will not use your Personal Data for marketing (e.g. newsletters, appeals) unless you have given your prior opt-in consent. Any marketing communications will include an easy way to unsubscribe. You have the right at any time to withdraw consent or object to processing for marketing purposes by contacting us.

11. DATA SUBJECT RIGHTS

Under Ghana’s Data Protection Act, you have the following rights regarding your Personal Data (as applicable):

1. Right of Access: You can request confirmation whether we hold your Personal Data and, if so, obtain a copy and the details of processing purposes, data categories, recipients and the logic of any automated decisions.
2. Right to Correction/Erasure: You can request correction of inaccurate data or deletion of data that is incomplete, misleading or obtained unlawfully. If you request deletion because we no longer are authorized to retain the data, we will erase it unless there is a lawful reason to keep it.
3. Right to Object/Withdraw: You can withdraw consent at any time and ask us to stop processing your data (e.g. for direct marketing or automated profiling).
4. Right to Data Portability: While not expressly provided in the GDPA, we support transferring your data to another controller if technically feasible.
5. Right to Compensation: You can seek compensation from IEF for damages or distress if we fail to comply with the law.

To exercise your rights, contact us using the details in Section 13. We will respond to a verified request within the statutory period (up to 40 business days). We may require sufficient information to confirm your identity and locate the data. If we decline a request, we will explain the reasons as permitted by law.

12. CONSENT AND MINOR PARTICIPATION

By providing Personal Data or using our services, you confirm you are at least 15 years old and consent to this policy. If you are between 15 and 17 years of age (a minor under Ghana law), your parent or legal guardian must also consent to your participation and data processing. Under the Data Protection Act, a “child under parental control” is considered a protected category. IEF will require explicit parental/guardian assent for minors:

• ●  Data Subject Consent (Age ≥15): “I hereby consent to the collection and processing of my personal data by Jungle House Foundation for the purposes described in this Privacy Policy, in accordance with Ghana’s Data Protection Act. I understand I may withdraw this consent at any time.”
• ●  Parental/Guardian Consent (if Subject is 15–17): “I confirm that I am the parent/legal guardian of the above-named individual and give my permission for their data to be collected and processed by Jungle House Foundation as stated.”

(Signatures required on registration/consent forms – see sample below.) DATA SUBJECT (Age 15 or above):

Name: _______________________ Signature: _______________________ Date: ________

PARENT/LEGAL GUARDIAN (if Data Subject is under 18):
Name: _______________________ Relationship: _______________ Signature: _______________________ Date: ________

We do not knowingly collect personal data from children under 15. If we become aware of such data without parental consent, we will delete it immediately.

13. POLICY CHANGES AND GOVERNING LAW

This Privacy Policy may be updated periodically to reflect changes in our practices or law. The Effective Date above will be revised whenever the policy is updated. We will notify users by posting the new policy on our website and updating the Effective Date.
This policy is governed by Ghanaian law (GDPA and other applicable statutes) and nothing herein limits any rights you have under the law. In any conflict between this policy and mandatory law, the law will prevail.

14. CONTACT INFORMATION AND COMPLAINTS

For questions or to exercise your rights, contact Independence Explosion Festival:

• ●  Email: info@junglehousefoundation.org
• ●  Address: P.O. Box BT 755 ,com. 2, Tema, G. Accra, Ghana (or visit www.independenceexplosion.com)

For unresolved issues or to lodge a formal complaint, you may contact:

Data Protection Commission (Ghana)

P.O. Box CT 5420, Cantonments, Accra – Ghana
Website: www.dataprotection.org.gh – Email: info@dpc.gov.gh

DISCLAIMER: The information provided in this document is intended for general information and compliance guidance. It does not constitute legal advice Independence Explosion Festival does not guarantee that this policy covers every contingency; compliance with Ghanaian data protection law is a continuing obligation.

Appendix – Data Protection Boilerplate: IEF is duly registered with the Ghana Data Protection Commission as required by law. We adhere to best practices in data governance, including maintaining internal privacy policies, incident response plans, and regular staff training.

End of Policy.