Privacy Policy

1 · The data controller

1.1 REE LIMITED COMPANY, a company incorporated under the laws of the Republic of Ghana with registration number CS018200126, whose registered office is at Nii Kokey Baale Avenue 21, Accra, Ghana, determines the purposes for which and the manner in which personal data collected through the Platform is processed, and is the data controller in respect of that data.

1.2 Enquiries and requests under this Policy may be addressed to hello@reegoapp.com or to +233 245 263 310.

2 · Scope

2.1 This Policy applies to personal data processed by the Company through the Platform. It forms part of the Terms of Service.

2.2 This Policy does not govern the processing of personal data by a Designer or a Seller after disclosure to them under clause 6.1. Each such person is a separate controller in respect of the data they hold and is responsible for their own compliance with applicable law.

3 · Definitions

3.1 "Personal data" means data about an individual who can be identified from that data or from that data together with other information in the possession of the Company. "Processing" means any operation performed upon personal data, including collection, recording, storage, use, disclosure and erasure. "Data subject" means the individual to whom personal data relates.

4 · Categories of personal data collected

4.1 Account data

Telephone number; electronic mail address; name; city; stated preferences as to occasions and styles; and the password, which is stored in hashed form and is not recoverable by the Company. The Company also records whether the telephone number and the electronic mail address have been verified.

4.2 Authentication and security data

One-time verification codes issued to the data subject, stored in hashed form; and, in respect of each session, the device description, the browser identification string, the internet protocol address and the times of sign-in and of last use.

4.3 Request data

Where a Buyer submits a request for bespoke work: the occasion, the required date, the stated budget, the locality for collection or delivery, the look from which the request originated, the Buyer's name and telephone number, and, where the Designer's form so provides, the Buyer's body measurements. All messages exchanged between the Buyer and the Designer in the resulting thread, including quotations and prices, are also recorded.

4.4 Job and client data

Where a request results in work being undertaken: the client record maintained by the Designer, comprising name, telephone number, locality, measurements and the Designer's notes; the status history of the work; the name of any carrier engaged and the charge for carriage; the date of delivery; and any review subsequently submitted.

4.5 Published data

Photographs and other material uploaded by the data subject; looks and listings published; and, in the case of a Seller or a Designer, the trading name, locality, telephone number and WhatsApp number published upon the profile. Data in this category is published to the public by the data subject and is intended to be so published.

4.6 Usage data

Records of pages and items viewed, saved and selected, and of the look from which a request originated. Where the data subject is not signed in, such records are associated with a browser session identifier rather than with an account.

4.7 Payment data

In respect of a Subscription, and of a delivery fee where a delivery has been requested of the Company: the fact, amount and date of payment, its status, and the reference assigned by the payment provider. Card numbers, mobile money personal identification numbers and comparable authentication credentials are not transmitted to, processed by or stored upon the Company's systems; they are submitted directly to the payment provider, which processes the payment on the Company's behalf as described in clause 10 of the Terms of Service.

5 · Purposes of processing and lawful basis

5.1 Personal data is processed for the following purposes:

• the creation and administration of accounts, and the publication of profiles and listings;
• the transmission of a request to the Designer to whom it is addressed, and the conduct of the resulting correspondence;
• the verification of contact particulars and the security of accounts, including the detection of unauthorised access;
• the moderation of Content, the investigation of reports and complaints, and the prevention and detection of fraud;
• the maintenance of records of completed work from which publicly displayed indicators are derived;
• the billing and administration of Subscriptions and the keeping of accounting records;
• the analysis of usage for the purpose of maintaining and improving the Platform; and
• compliance with legal obligations to which the Company is subject.

5.2 The Company processes personal data on the basis of the consent of the data subject, given upon registration or upon submission of the data; for the performance of the agreement constituted by the Terms of Service; for compliance with a legal obligation; and, in respect of security and fraud prevention, for the legitimate interests of the Company and of its Users.

5.3 Consent may be withdrawn at any time in accordance with clause 8. Withdrawal does not affect the lawfulness of processing carried out before withdrawal, and may prevent the Company from continuing to provide the Platform to the data subject.

6 · Disclosure of personal data

6.1 Disclosure to a Designer or Seller. Where a Buyer submits a request for bespoke work, the Company discloses to the Designer to whom the request is addressed the Buyer's name, telephone number, locality, stated budget and required date, and any measurements provided. Where a Buyer contacts a Seller, the contact takes place directly between them. Such disclosure is the substance of the service requested. A Provider receiving such data may use it only for the purpose of performing the work or supplying the goods requested, and clause 6.4 of the Terms of Service so provides.

6.2 Disclosure to processors. The Company discloses personal data to the following categories of service provider, each of which processes it upon the Company's instructions and for no other purpose: a provider of short message services, for the despatch of verification codes; a provider of electronic mail services, for the same purpose and for notifications; a payment services provider, for the taking of Subscription and delivery fee payments and for the making of refunds; and a provider of hosting and storage infrastructure.

6.3 Disclosure required by law. The Company may disclose personal data where required to do so by law, by an order of a court, or by a competent authority, and where disclosure is necessary to protect any person from harm or to investigate suspected fraud.

6.4 The Company does not sell personal data, and does not disclose it to advertisers, data brokers or any other third party for the purposes of marketing.

7 · Transfer outside Ghana

7.1 The Platform is hosted, and personal data is stored, upon infrastructure situated in the United Kingdom, and electronic mail is despatched through a service operating in the same region. Personal data collected through the Platform is accordingly transferred outside the Republic of Ghana for the purposes described in clause 5.

7.2 The Company employs providers which afford appropriate technical and organisational safeguards in respect of data so transferred, and requires each of them to process personal data only upon the Company's instructions.

8 · Rights of data subjects

8.1 A data subject may:

• request access to the personal data held about them by the Company;
• request correction of personal data which is inaccurate or incomplete;
• request erasure of personal data and the closure of the account, subject to clause 9.2;
• object to processing for a specified purpose, or withdraw a consent previously given; and
• request that processing be restricted pending the determination of a request made under this clause.

8.2 A request under clause 8.1 shall be made in writing to hello@reegoapp.com from the telephone number or electronic mail address recorded upon the account. The Company shall respond within a reasonable period and shall not charge a fee. The Company may require satisfactory verification of the identity of the person making the request before acting upon it, disclosure to a person falsely claiming to be the data subject being itself a breach of this Policy.

8.3 Limitation. The Company is unable to procure the erasure of personal data held by a Designer or a Seller within that person's own records. A data subject seeking such erasure should apply to that person directly and may inform the Company where the application is refused.

9 · Retention

9.1 Account data is retained for so long as the account remains open. Request, message and job data is retained for so long as it remains necessary to the parties to the User Transaction to which it relates. Records relating to payments are retained for the period required by law for accounting and taxation purposes.

9.2 Upon a request for erasure, the Company shall delete or irreversibly anonymise the personal data of the data subject, save that the Company may retain: records which it is required by law to keep; and anonymised records of completed transactions from which the data subject cannot be identified.

10 · Security

10.1 The Company employs technical and organisational measures appropriate to the risk, including the hashing of passwords and verification codes, the encryption of data in transit, the facility for a data subject to terminate any session recorded upon the account, and the restriction of internal access to personnel who require it.

10.2 No system of transmission or storage is entirely secure. Where a breach of security occurs which is likely to affect the personal data of a data subject, the Company shall notify the data subject and shall take such further steps as the law requires.

11 · Children

11.1 The Platform is not directed to persons under the age of eighteen (18) years, and the Company does not knowingly collect personal data relating to such persons. Where the Company becomes aware that it holds such data, it shall delete it.

12 · Cookies and similar technologies

12.1 The Company places upon the data subject's device a limited number of cookies which are necessary for the operation of the Platform, being those which maintain a session and record that the data subject is signed in.

12.2 The Company does not operate third-party advertising or cross-site tracking technologies upon the Platform.

13 · Amendment of this Policy

13.1 The Company may amend this Policy from time to time. The version in force is that published upon the Platform and identified by the version date appearing above. Where an amendment is material, notice shall be given upon the Platform.

14 · Contact

Enquiries and requests concerning this Policy may be addressed to REE LIMITED COMPANY at hello@reegoapp.com or on +233 245 263 310, or by post to Nii Kokey Baale Avenue 21, Accra, Ghana.