Privacy Policy

Effective date: December 7, 2025

This Privacy Policy explains how ACE MARKETING & PROMOTIONS, INC. (“we”, “our”, “us”) collects, uses, and protects personal data when individuals interact with kernellumen.com, our communication channels, and our financial literacy services in Ghana. We comply with Ghana’s Data Protection Act, 2012 (Act 843) and other applicable regulations.

1. Personal data we collect

We collect personal data only when it is relevant to delivering our services or fulfilling a legitimate business interest. The data we handle includes:

  • Contact information such as name, email address, phone number, and organisational affiliation provided via forms, emails, or calls.
  • Session logistics data including preferred languages, group composition, and scheduling details.
  • Feedback and survey responses used to improve our educational content.
  • Technical information such as IP addresses, browser types, and device identifiers captured through cookies and analytics tools.

We do not knowingly collect personal data from children under 16 without parental or guardian consent.

2. Legal basis for processing

We process personal data under the following legal bases recognised by the Ghana Data Protection Act:

  • Consent: When individuals voluntarily provide information through forms or surveys.
  • Contractual necessity: When data is required to deliver requested services or manage event participation.
  • Legitimate interest: For security, service improvement, analytics, and internal record keeping, balanced with individual rights.
  • Legal obligations: To comply with applicable laws, regulatory requirements, or lawful requests.

3. How we use personal data

We use collected data to:

  • Respond to enquiries, schedule consultations, and manage event logistics.
  • Deliver educational materials, toolkits, and follow-up resources tailored to participant needs.
  • Analyse anonymised trends to improve our curriculum and website experience.
  • Send service updates, policy notices, and educational content that align with user preferences.
  • Maintain accurate records for auditing, accounting, and compliance purposes.

We do not sell personal data and we avoid sharing information with third parties except as described below.

4. Sharing and international transfers

We may share personal data with trusted service providers who support our operations, including email platforms, cloud storage providers, and professional advisors. These partners are contractually bound to protect data and use it only for agreed purposes.

When personal data is transferred outside Ghana, we implement safeguards such as contractual clauses, secure transfer protocols, and privacy commitments aligned with Act 843 requirements.

5. Data retention and security

We retain personal data only for as long as necessary to fulfil the purposes outlined in this policy, meet legal obligations, or resolve disputes. Retention periods vary depending on the nature of the interaction:

  • Enquiry records: up to two years.
  • Service delivery records: up to five years after completion.
  • Analytics data: up to three years in aggregated form.

We implement administrative, technical, and physical safeguards to protect data against loss, misuse, or unauthorised access. These measures include access controls, encrypted storage solutions, and regular policy reviews.

6. Individual rights

Individuals interacting with our services have rights under Ghana’s Data Protection Act, including the right to:

  • Request access to personal data we hold about them.
  • Request corrections to inaccurate or incomplete data.
  • Withdraw consent where processing is based on consent.
  • Object to processing for direct marketing or legitimate interests.
  • Request deletion when data is no longer needed or was unlawfully processed.

Requests can be sent to [email protected]. We may require verification before fulfilling certain requests to protect privacy.

7. Cookies and analytics

We use cookies and similar technologies to understand website usage, remember user preferences, and enhance functionality. Please review our Cookie Policy for detailed information about cookie categories, purposes, and controls.

8. Updates to this policy

We may update this Privacy Policy to reflect regulatory changes, operational adjustments, or new services. We will post the updated version on this page with a revised effective date. Significant changes may be communicated via email or on the website.

9. Contact us

If you have questions or concerns about this Privacy Policy or our data practices, please contact:

ACE MARKETING & PROMOTIONS, INC.
457 Rockaway Ave, Valley Stream, NY 11581, serving Ghanaian clients remotely
Phone: +233 24 711 5094
Email: [email protected]