Privacy Policy

1. Introduction

AHOUFE, published by Lebutu Labs, is committed to protecting your personal data in accordance with the Data Protection Act, 2012 (Act 843) of Ghana and the regulations issued by the Data Protection Commission. This policy describes how we collect, use, and protect your information when you use the AHOUFE platform in Ghana.

2. Data controller

The data controller for personal data collected through the AHOUFE platform is:

• Lebutu Labs
• Headquarters: Toulouse, France / Abidjan, Cote d'Ivoire
• Ghana representative: [To be completed]
• Email: privacy@ahoufe.app
• Data Protection Commission registration: [To be completed]

3. Data collected

In the course of providing our services in Ghana, we collect the following categories of personal data:

• Mobile phone number (primary identifier)
• Full name
• Booking history and services received
• MTN MoMo or Vodafone Cash number (when in-app payments are enabled, for refunds only)
• Approximate location (for nearby salon search, with your consent)
• Device and browsing data (device type, browser, pages visited)
• Messages exchanged with the AhoufeBot chatbot

4. Purpose of processing

In accordance with Section 17 of the Data Protection Act, 2012 (Act 843), your personal data is processed for the following lawful purposes:

• Providing the booking service and connecting customers with partner salons
• Sending booking confirmations and appointment reminders via SMS
• Processing payments through MTN Mobile Money and Vodafone Cash when enabled
• Improving user experience and recommendation relevance
• Generating anonymised statistical reports for partner salons (AhoufeSight)
• Ensuring platform security and fraud prevention
• Responding to customer support enquiries

5. Lawful basis for processing

Under the Data Protection Act, 2012 (Act 843), AHOUFE processes your personal data based on the following lawful grounds:

• Consent: you provide your consent when registering and using the platform (Section 17(a))
• Contract: processing necessary for the performance of the booking service (Section 17(b))
• Legal obligation: retention of transaction records as required by law (Section 17(c))
• Legitimate interest: platform security, fraud prevention, and service improvement (Section 17(f))

6. Data sharing

Your personal data is shared only with:

• Partner salons concerned by your bookings (name, time slot, service chosen)
• Payment operators (MTN MoMo, Vodafone Cash) when in-app payments are enabled
• Google Cloud Platform (technical hosting)
• Competent authorities when required by law or court order

7. International data transfers

Your data is hosted on Google Cloud Platform in the europe-west1 region (Belgium, European Union). In accordance with Section 36 of the Data Protection Act, 2012 (Act 843), any transfer of personal data outside Ghana is carried out only where the receiving country ensures an adequate level of protection, or where appropriate safeguards are in place.

8. Data security

AHOUFE implements appropriate technical and organisational measures to ensure the security of your personal data, as required by Section 28 of the Data Protection Act, 2012 (Act 843):

• Encryption in transit (TLS 1.3) and at rest
• Strong authentication (SMS OTP via Firebase Auth)
• Access control based on the principle of least privilege
• Hosting on certified infrastructure (Google Cloud Platform — ISO 27001, SOC 2)
• Payment information is never stored by AHOUFE

9. Data retention

Your personal data is retained as follows:

• Account data: for the duration of your registration, then 3 years after last activity
• Booking data: 5 years from the date of service (accounting obligation)
• Browsing data: 12 months maximum
• Upon request for deletion: data will be erased within 30 business days
• Anonymised data for statistical purposes may be retained indefinitely

10. Your rights

Under the Data Protection Act, 2012 (Act 843), you have the following rights regarding your personal data:

• Right of access (Section 31): obtain confirmation that your data is being processed and receive a copy
• Right to rectification (Section 32): correct inaccurate or incomplete data
• Right to erasure: request the deletion of your account and data
• Right to object (Section 33): object to the processing of your data on legitimate grounds
• Right to withdraw consent: at any time, without affecting the lawfulness of prior processing

11. Exercising your rights and complaints

To exercise any of your rights, contact us at privacy@ahoufe.app. We will respond to your request within 30 business days. If you are not satisfied with our response, you may lodge a complaint with the Data Protection Commission of Ghana:

• Data Protection Commission
• No. 2 Rangoon Lane, Cantonments, Accra, Ghana
• Website: www.dataprotection.org.gh
• Telephone: +233 (0) 302 773 791

12. Changes to this policy

AHOUFE reserves the right to update this Privacy Policy. In the event of significant changes, users will be notified by push notification or SMS. The date of the last update is indicated at the top of this page.

13. Contact

For any questions regarding the protection of your personal data: