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Legal

Privacy notice

What personal data Durbar collects, why, who sees it, how long we keep it, and your rights under Ghana's Data Protection Act, 2012 (Act 843).

Draft for legal review

This is a draft dated . It isn't in force yet and will change after review by a lawyer. Items in square brackets are still to be filled in.

Who we are

Durbar is made by Silentech [registered name, registration number and address to be added]. In this notice, "we" means Silentech.

Silentech has not yet confirmed its registration with the Data Protection Commission of Ghana as a data controller and processor. This notice is a draft and takes effect only once it has, when the registration number will be shown here.

Questions about your data go to our data protection contact [name and email to be added].

When we decide, and when an organizer does

For your Durbar account, the console, and the public site itself, we decide how your data is used: we are the controller.

When you buy a ticket, book a space, rent equipment, vote in a contest, are on a guest list or a graduand list, or are sent a gift, the organization behind it (the organizer, venue, rental vendor, institution or company) decides why your data is collected and what they do with it. They are the controller, and we process it for them under a written agreement. Their own privacy notice applies too, and you can contact them from their event, venue, vendor or contest page.

What we collect

We collect only what each task needs:

  • Account holders: name, phone number and email, the organization you belong to and your role, passkeys (we store only the public part), and a record of what you do in the console.
  • Buyers and bookers: name, phone number or email, what you bought or booked, and payment references. Card and MoMo details go to the payment provider, not to us.
  • Guests: what the organizer adds or imports (name, phone, email, group and plus-ones), whether you're coming and who you bring, and your answers to their registration form.
  • Graduands: what the institution imports (index number, name, programme, class, college, session, phone and email), what you confirm or dispute, your gown size, and the guests you name.
  • Renters: your name, phone or email, the delivery address and when it's delivered and collected, what you rent, photos the vendor takes of the equipment when it goes out and comes back, what the vendor keeps from your deposit and why, and your answer if you dispute it.
  • Studio orders: the contact name, phone or email and delivery address on an order; the name typed by whoever approves or asks for changes to a proof; photos the print partner takes at quality check and delivery; and a one-time delivery code texted to the recipient, of which we keep only a scrambled form (a hash).
  • Gift recipients: what the sending company gives us (name, phone or email, a start date for new staff), and what you give on your gift page: your delivery phone, address and GhanaPost GPS address, town, region, a note for the rider, your sizes and which item you chose.
  • Voters: for paid votes, your phone number, the name you give, the nominee and payment references. For free votes, your phone gets a one-time code by SMS; we keep a hash of the number, not the number, to hold each phone to its limit. Public counts and the hourly hash chain contain no voter data. If the organizer voids votes, the reason is public, and paid votes are refunded through the payment provider or the organizer records how they refunded you.
  • Smart items: when an NFC tag or QR code on a smart item is tapped, the day and time, NFC or QR, the phone's system (such as Android or iOS), and the town and country its network reports. We don't store the IP address or the browser's details with the tap, or anything that names you. A random cookie (see Cookies) tells a repeat tap from a first one.
  • Print and packing partners: the business's name, contact person, phone, email, town and the account they are paid to.
  • At the gate: when and at which gate each ticket was let in.
  • Technical data: addresses of the devices that call our servers, kept in logs for security.

Why we use it

We use personal data to:

  • sign you in with a code or a passkey;
  • sell and deliver tickets, take bookings and rentals, and send the messages that go with them;
  • send invitations and reminders, and record replies, for the organizer who invited you;
  • deliver rentals, Studio orders and gift kits to the right address, and confirm delivery with a code and a photo;
  • keep a record of an item's condition and of deposit decisions, so a disagreement can be looked into;
  • count votes fairly, hold each phone to the contest's limits, and publish a count anyone can check;
  • show a smart item's owner how often, where and on what kind of phone it was tapped, without naming anyone;
  • let people in at the gate, once per ticket;
  • process refunds and pay organizers, vendors and partners through the payment provider;
  • keep the service secure, find and stop fraud, and keep the records the law asks of us.

Our reasons in law

We process your data to carry out the contract you asked for (your account, your ticket, your booking), to meet legal duties such as tax records, and for our legitimate interest in keeping the service secure. We ask for your consent where the law requires it, and you can withdraw it at any time.

We don't send marketing without your consent, and every marketing message lets you stop them.

Who we share it with

We don't sell personal data. We share it only with:

  • the organizer, venue, vendor, institution or company you bought from, booked with, voted with or are listed by;
  • the print or packing partner making or delivering an order or a gift kit, who sees the name, phone and address it goes to, and for gift kits the sizes chosen, through a private link that stops working 30 days after the job is done;
  • payment providers (Paystack, and Hubtel as a fallback) to take payments, split them and refund them;
  • the companies that send our SMS and email;
  • the companies that host our servers and files [providers and regions to be added];
  • authorities, when the law requires it.

Data stored outside Ghana

Some of our providers store data outside Ghana [countries to be added]. Where they do, we use agreements that give your data the protection Ghanaian law requires.

How long we keep it

We keep data while it's needed for the purpose it was collected for, and then for as long as the law requires for tax and accounting records (the windows below). Then we delete it or make it anonymous.

The contents of texts and emails we send, which can include your phone number or email and a link to your ticket, are blanked 7 days after they are delivered, or 30 days after we give up on one. Sign-in codes go within a day of expiring, portal codes within 30 days, and sign-in sessions 7 days after they end. Backups are encrypted and replaced in turn, so what a backup held is gone within about a year.

If you ask an organizer, or us, to erase you, your name and contact details are removed from that organizer's guests, orders, tickets, bookings, rentals, gifts and vote payments, and messages to you are stopped. The sale or admission itself stays, as a record with no name on it, because the law asks for those. A graduand stays on their institution's roster, without contact details.

Votes, voids and the hourly hash chain are never changed or deleted, because the public count depends on them. They hold no phone numbers or names: a vote is linked to a voter only by a hash of the phone number.

Your rights

Under the Data Protection Act, 2012 you can:

  • ask what personal data we hold about you and get a copy;
  • ask us to correct data that's wrong, or delete data we no longer need;
  • object to how we use your data, or withdraw a consent you gave;
  • stop marketing messages at any time;
  • complain to the Data Protection Commission of Ghana.

How we protect it

Sign-in uses one-time codes and passkeys, with no passwords to steal. Each organization's data is kept apart in the database. Tickets are signed so they can't be forged. Money never passes through our own accounts, and we never pool funds: payments go through licensed payment providers (Paystack and Hubtel), which split them into each organization's account.

Cookies

We use only the cookies the service needs to work, such as the one that keeps you signed in. We don't use advertising cookies.

When you tap a smart item, we set one more cookie, durbar_v, for about 13 months. It holds a random value, is read only by smart-item links, and is stored only combined with the item and scrambled (hashed), so taps on two different items can't be joined up.

Changes to this notice

If we change this notice in a way that matters, we'll say so on this page and, for account holders, by email or SMS before the change applies.

See also our terms of service.