Privacy Policy 2024 • Ghana

Date: June 20, 2024
Version: v. 1

Introduction

This page describes how Intelli Holdings Inc, ("Intelli", "Intelli Concierge", "we", "our", "us") collects and processes personal information in accordance with this Privacy Policy.

Intelli values your privacy and is committed to protecting your personal information. This privacy policy outlines the types of information we collect, how we use and share it, and the measures we take to ensure its security. We respect and value the privacy of everyone who visits our website or uses our application and will only collect and use personal data in ways that are described here and in compliance with our obligations and your rights under the Data Protection Act, 2012 (Act 843) of Ghana.

Please read this Privacy Policy carefully and ensure that you understand it. By using our site and/or our application(s), you give your affirmative consent that you have read and accepted all the terms in this Privacy Policy. If you do not accept and agree with this Privacy Policy, you must stop using Our Site/application(s) immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

• "Account" means an account required to access and/or use certain areas and features of Our Site or application;
• "Cookie" means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below;
• "Customer" means a direct user with an active account and is a consumer of any Intelli Applications and/or a beneficiary to Services extended through Our Application;
• "Client" means an individual or business who doesn't have an account with us but benefits from or interacts with one of our customers.
• "Site" also known as "domain" means our website www.intelliconcierge.com and/or any subsequent software accessible from our website or across the internet affiliated with our primary site;

2. Information About Us

Our Site and application are operated by Intelli Inc and operates in Ghana, Kenya, South Africa, Tanzania, Nigeria and Ethiopia.

Data Protection Email address: support@intelliconcierge.com
Helpline Telephone number: +254745051091

3. What Does This Policy Cover?

This Privacy Policy applies to your use of our Site and application. Please note that we have no control over how your data is collected, stored, or used by other websites whose links may be provided on our website and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?

Personal data is defined as any information relating to an identified or identifiable natural person as per the Data Protection Act, 2012 (Act 843) of Ghana.

Personal data is any information that can be used to identify you. This includes your name, address, telephone number, email address, and other information that can be used to identify you. It also includes information about your preferences and interests.

5. What Are Your Rights?

As a data subject, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 14.
• The right to access the personal data we hold about you. Part 13 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 14 to find out more.
• The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 14 to find out more.
• The right to restrict (i.e., prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose(s).
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.
Further information about your rights can also be obtained from the Personal Data Protection Office.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Personal Data Protection Office.

6. What Data Do We Collect?

Depending upon your use of our Site and application, we may collect some or all of the following personal and non-personal data including but not limited to:

• Name
• Address
• Email address
• Whatsapp Telephone number
• Payment information
• Account login credentials
• Usage and device information (IP address, browser type, device model)
• Information about your preferences and interests

We use the information you provide to:

1. Identify you
2. Improve the service such as saving common questions and inquiries
3. Connect services like "Takeover" and "Address" with your clients whenever the assistant is unable to offer help or address the client's issues
4. For product research development
5. To provide measurements and analytics
6. Communicate with you (share marketing communications on our products)
7. Generally, improve your user experience
8. For Legal and Compliance purposes with the law

7. How Do We Use Your Personal Data?

Further to clause 6, we use your data for the necessary performance of a contract with you and because you have consented to the use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may also be used for the following purposes:

• Providing and managing your Account;
• Providing and managing your access to Our Site and application;
• Personalising and tailoring your experience on Our Site and application;
• Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information that you have the option to opt-out at any time.
• For purposes of "Know Your Customer" or Customer Due Diligence under the law.

We may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or any other means, with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the law, and you will always have the opportunity to opt-out.

8. OpenAI Language Models and Data Processing

Please note that Intelli uses OpenAI's language model as part of our services. While Intelli does not actively process user data, OpenAI uses and processes some of this data to provide and improve its services.

For users residing in the European Economic Area (EEA), Switzerland, or the UK, OpenAI complies with the applicable data protection laws. For more information on OpenAI's privacy practices, including the types of data they collect and how they use and protect it, please review OpenAI's EU Privacy Policy.

Google API Services User Data Policy

Intelli's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

9. How Long Will You Keep My Personal Data?

We store data until it is no longer necessary to provide our services or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs in accordance with the law.

10. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data to countries that have adequate data protection standards/laws or where you have consented to the processing or storing of personal data outside Kenya. We may in certain instances such as for analytics purposes or for the reasons in 6 and 7 above share your data with external third parties, that may be based out of your jurisdiction. In any such case, we shall ensure any such data is transferred securely and following best practice in your jurisdiction.

Data at Intelli is stored in renowned and secure servers. Data from the Intelli applications is stored in Amazon Web Services (AWS). Intelli uses Postgresql as the database engine and all access to the database is confidential and protected with reasonable security features.

11. Do You Share My Personal Data?

We do not sell or rent your personal information to third parties. We may share your personal data with processors and other companies in our group, including our affiliates in the United States and other jurisdictions, and this may include subsidiaries, a holding company or any other entity that is a party to a merger and/or acquisition of an interest in Intelli.

We also work with travel agencies to help streamline their customer interactions. Our AI assistant solution helps these agencies manage customer interactions, track necessary travel documents, and respond to inquiries on platforms such as WhatsApp and Facebook.

We may sometimes contract with the following data processors to supply certain services. These may include payment processing, delivery, and marketing. In some cases, those parties may require access to some or all of your personal data that we hold.

• Google Firebase based in the USA – the purpose for this is to process information about how customers use the Intelli application and optimize user experience; data processing that helps with data optimization and marketing purposes; data processing that helps to process customer communications. Please find Firebase's privacy policy here: https://firebase.google.com/support/privacy
• Vercel Analytics, a data processor that helps with analytics and insights to the Intelli application. Please find Vercel's privacy policy here.
• Clerk, a data processor that supports authentication services for our application. Please find Clerk's privacy policy here: Privacy policy | Clerk

If any of your personal data is required by a processor, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party's obligations under the law. Without prejudice, you are advised to read the privacy policies of any processors we may contract.

By using the Intelli site/application, You (the User) give to Us (Intelli) your consent to collect, use, and process your data for the purposes and in the manner indicated herein and in the driver or customer terms of use.

12. How Can I Control My Personal Data?

You have the right to access, update, or delete your personal information at any time. We provide you with the ability to access, rectify, port, and erase your data. You can also opt-out of marketing communications or request a copy of your data by contacting us at support@intelliconcierge.com. To learn more, call our helpline to be supported on any of the requests you may have.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request".

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14. We will respond to your subject access request within the timelines provided under the law. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required as communicated by our team from time to time from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies and similar technologies to enhance your experience on our website and app. These cookies collect data about your browsing behavior and preferences to personalize content and show relevant ads. You can manage your cookie preferences through your browser settings. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times. Please see our cookie policy here ____

15. How Do I Contact You?

If you have any questions about this Policy, or have any complaints, suggestions, questions or requests regarding anything you can contact us as described below.

Intelli Holdings Inc with a registered address in the State of Delaware at 251 little Falls Drive, city of Wilmington, County of Newcastle, Delaware 19808

Email: support@intelliconcierge.com
Telephone: +254745051091
X(Formerly Twitter): @intelli_concierge
Instagram: @intelli_concierge
LinkedIn: https://www.linkedin.com/company/intelli-concierge/

16. Changes to This Privacy Policy

We may change this Privacy Policy from time to time and in some instances without notice to you. This may be necessary, for example, if the law changes, or we change our business in a way that affects personal data protection. Any changes will be immediately posted on our Site and/or application and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site and/or application following the alterations. We encourage you to review this page regularly for the latest information on our privacy practices. By your use of our Site and/or application, you, by affirmative action, consent to these terms. Please do not use our Site and/or application or services if you do not consent to these terms.