Privacy Policy

K Nyame Educational Foundation respects and honors our supporters and sponsored children, their right to be treated courteously, fairly, and have their privacy protected. KNEF is committed to complying with the National Privacy Principles contained in the Ghana data protection act 2012.

​

KNEF adheres to best practices for the collection, use, and disclosure of personal information as outlined in this policy.

​

To protect both our supporters and the children we serve, and in keeping with our child protection policy, KNEF only provides supporters and sponsored children with the information necessary to build and maintain the sponsor-child relationship.

​

Periodically, KNEF may send marketing material to sponsors.

 

KNEF staff will clearly identify themselves when making contact with sponsors through digital communication channels. In email communication, KNEF’s logo and contact details will be included.

 

Collection, use, and management of information:

 

Personal information is supplied with consent.

​

Individuals and groups can make donations or inquiries anonymously. 

​

Prospective supporters can visit our website anonymously. 

​

Marketing and supporter experience surveys can be completed anonymously.

​

Personal details are required to link a sponsor with a child, to process and post a receipt, magazine, or letter, send new or updated child information, establish periodic payments and maintain the relationship between supporters and KNEF.

​

Each supporter is given a unique supporter number under which personal details are kept. This number and other details are used to verify an individual’s identity when they make contact.

​

Protecting your information:

​

KNEF has put in place procedural, physical, and electronic means to safeguard the personal information of our supporters.

​

KNEF has also verified the security and privacy provisions of other organizations with whom we provide information about supporters. These include our bank and mail house. 

​

KNEF does not rent, exchange, or sell mailing lists of our supporters to other organizations.

​

Supporters’ information is kept both in hard copy and electronic forms. In either case, KNEF has documented procedures to safeguard this information. Safeguards include storing copies of the information off-site.

​

Currently accepted encryption methodologies are used when collecting or transferring credit card information via the Internet, ensuring a secure environment for the transfer of your confidential data from your browser to our financial institution.

​

In certain restricted circumstances, personal information collected by KNEF Ghana (except for financial information) may be stored or processed outside of Ghana. In those circumstances, the information collected is subject to the legal jurisdiction of those countries.

​

Web Analytics and Advertising:

​

KNEF uses Google Analytics to help make our web site easier to find and to use. Google Analytics uses cookies to help collect anonymous traffic and activity data.

You can find out how Google safeguards this data, or you can opt-out of this service.

​

KNEF uses individual end-user tracking and data sharing with trusted third parties like Google, Facebook, and Microsoft for advertising and marketing purposes. 

You can find out how Microsoft safeguards this data, and you can opt-out of personalized/interest-based online advertising.

​

Correcting your information:

​

Supporters may see and correct incorrect or outdated personal information, as well as remove their names from mailing lists, at any time. 

​

Want to know more:

​

KNEF is available to answer specific questions regarding our organization or provide more information about our privacy policy. KNEF can be contacted at:

Knefghana.com or email contact@knefghana.com.

​

​

KNEF (“KNEF”) knows that protecting the privacy and confidentiality of your personal information (“Personal Information”) is of paramount importance. Collection, use, storage, retention, disclosure, and destruction of Personal Information by KNEF is governed by the Personal Information Protection and Electronic Documents Act (the “Act “), and any applicable provincial legislation. This privacy policy (the “Privacy Policy”) explains what personal information is collected from users of the KNEF website located at the URL: knefghana.com (the “Website”) and how it is used. It also explains how you can ask questions, make suggestions, and complain about our privacy practices. This Privacy Policy applies to Personal Information collected by KNEF. Be aware that KNEF may contain links to other websites provided and maintained exclusively by third parties not subject to this Privacy Policy. Please review the privacy policies on any external websites to determine their information handling practices. KNEF will not be liable under any circumstances for any damages whatsoever, direct, indirect, incidental, consequential, special, or indirect, resulting from any use of any third-party website linked to any website owned and/or operated by KNEF. The scope and application of the KNEF Privacy Policy are as follows: The Privacy Policy applies to Personal Information that is provided to KNEF from Employees and “non-employee” Persons who interact with KNEF that is collected, used, or disclosed by KNEF via its Website, or otherwise.

​

“Employees” in this context include past and present employees and independent contractors of KNEF.

​

“Non-employee Persons” in this context includes individuals who are viewers, readers, subscribers, members, advertisers, contest participants, job applicants, Internet users who are exposed to the media content of KNEF and about whom KNEF collects Personal Information, as more specifically defined below.

​

KNEF reserves the right to amend this KNEF Privacy Policy from time to time. The application of the KNEF Privacy Policy is subject to the requirements or provisions of any applicable legislation, regulations, or agreements (such as collective agreements), or the order of any court or other lawful authority. Exclusions from privacy protection: The KNEF Privacy Policy does not impose any limits on the collection, use, or disclosure of the following information by KNEF: a) information that is publicly available, such as a Person’s name, address, telephone number, and electronic address, when listed in a directory or made available through directory assistance; b) business contact information, such as the name, title or business address or telephone number of an employee of an organization; c) information shared publicly by a Person in their user profile, such as work or educational history, social media contacts, and other profile information; d) public information collected, used or disclosed in the course of journalistic activities; or e) aggregate information that cannot be associated with a specific person, such as demographic statistics about KNEF customers, or the number of visitors and average time spent on a website.

​

What Personal Information is collected through the Website:

​

There are six main classes of non-Employee Persons who may access the Website and the information we collect about each one is different: 

 

Visitors– Visitors to the Website may visit various pages on our Website to learn more about the services we offer and explore other information we publish on our site, including newsletters, videos, and webinars. We do not collect any Personal Information from visitors to the Website until they specifically decide to sign up as a user, the type of which are defined below. 

 

User– (Webinar Attendees & learners) – As a user of Webinars you will have to provide basic contact information to register (name, postal address, and email address). As a user of our learner services, you will need to provide your basic contact information to use the services (name, postal address, and email address) unless the purchaser of the service is an organization who registers on behalf of its employees, in which case full billing information is required. If any of the services you wish to access are paid services, we will require your credit card details to process the payments or your contact information for invoicing depending on the purchase price. 

 

User– (Purchasers) – As a purchaser of one of the products which KNEF offers for purchase to Visitors from time to time, including but not limited to subscriptions and the KNEF Salary Survey, we will require your name, email address, and credit card details to process the payments or your contact information for invoicing, depending on the purchase price. 

 

User– (Job Poster) – As a Job Poster you will need to supply your basic contact information when you sign up to use the service (name, email address, and organization). If you subsequently decide to use any of our paid services, we will require credit card details to process the payments for these services or your contact information for invoicing, depending on the purchase price. 

 

User– (Job Seeker) – There is no charge for Job Seekers, so we will not require any information relevant to payment such as credit card details. However, as a job seeker, you will need to supply your basic contact information when you sign up for the service (name, postal address, and email address). If you subsequently either apply for a job and/or create a CV IQ profile you will be required to enter information to complete your application or profile. This information includes information typically found in a resume, such as your experience and education, as well as responses to questions asked in relation to the position you are applying for (e.g., “How many years of experience do you have in a direct sales role?”).

 

All Job Seekers who create a CV IQ profile who are applying for a job for which the Job Poster has included as part of its application process a section called “Talent Predictor” will also need to complete our personality assessment which involves responding to between 50 and 100 questions. These answers will be processed by a third-party software partner to KNEF which is itself bound by the same terms and conditions of this Privacy Policy. For further information on sharing and keeping your Personal Information secure see more details described below. 

 

User– (Event/Volunteer Postings & Volunteers) – There is no charge for posting an event or volunteer positions or for volunteering, so there is no payment information required. However, the Organization posting the Volunteer position or Event listing will have to submit basic contact information when you sign up to use the service (name, email address, and organization) and details about the position. As a Volunteer, you will need to supply your basic contact information when you sign up for the service (name, postal address, and email address).

 

If you subsequently apply for the volunteer position you will be required to enter information to complete your application. As you explore the Website, we may also collect information via frequently used information-tracking tools, such as “cookies”. These cookies collect information such as your browser type, your Internet Protocol (IP) address, and the actions you take on the website (i.e., pages views and links clicked).

​

Purposes for Collection of Personal Information:

​

KNEF has collected and collects Personal Information for the following general purposes: a) to establish and maintain responsible commercial relations with Individuals and to provide ongoing service; b) to understand Individual needs; c) to develop, enhance, market or provide products and services; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible KNEF corporate re-organization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of KNEF, provided that the Personal Information disclosed continues to be used by the entity acquiring the information either for evaluation of the possible transaction, or, on completion of any such transaction, for the purposes permitted by this Privacy Policy.

 

As examples of the above:

​

1. KNEF may from time to time use a Person’s Personal Information to contact the Person about changes, enhancements or similar notices related to KNEF products and services.
    

2. if a Person indicated that he/she was interested in receiving offers or information from KNEF or certain of our selected sponsors or advertisers, KNEF may send the Person materials about products and services that KNEF feels may be of interest to the Person.
    

3. if a Person enters a contest or other promotion offered on a KNEF website, KNEF may, under the rules of the promotion, use the Person’s name and certain other information to administer the promotion, such as contacting, announcing, and promoting the winners of the promotion.
    

4. if a Person is a Job Poster becomes a user and wants to use our services to create a job posting KNEF may use the Personal Information provided by the Job Poster to create posting, process payments, communicate with Job Poster to provide CV IQ service, online assistance, and troubleshooting advice and other business communications and services consistent with industry practices, our services, and applicable law; and
    

5. if a Person is a Job Seeker and becomes a user and wants to create a CV IQ profile on our Website, KNEF may use the Personal Information provided by the Job Seeker to communicate with the Job Seeker, organize profile, and provide the Personal Information to the Job Poster who posted the job posting for which the Job Seeker submitted the Personal Information, and for the other purposes disclosed elsewhere in this Privacy Policy.

 

How is this information used:

​

The information we gather through use of cookies is used only in the aggregate and not tied to personally identifiable information. For example, we may track the number of visitors to a specific area of our Website or determine which of our services are used most frequently. We do this so we can continually work to improve our Website and ensure that we are providing the content and services that our visitors want to see and use. The information we gather from users who have signed up for a Job Poster account (“Job Poster(s)”) allows us to communicate with each Job Poster individually and provide them with the transactional communications necessary for their account. We may additionally use this information to send marketing or other communications unless the Job Poster has opted-out (see below). The information we gather from users who have signed up for a job seeker account (“Job Seeker(s)”) will be used to communicate with each Job Seeker individually and provide them with the transactional communications necessary for their account. We may additionally use this information to send marketing or other communications unless the job seeker has opted-out (see below). Additionally, any information the Job Seeker has included in his or her profile or in a specific job application will be made available to the Job Poster who posted the job to help that Job Poster to sort and select candidates to create the best shortlist for the position they are looking to fill. If the job seeker has chosen to make their profile “open”, certain aspects of it (resume, experience, education, etc.) will be visible to other Job Posters who may be looking for candidates.

​

Do you share my information with anyone:

​

Except as otherwise stated in this Privacy Policy, we do not trade, rent, or share Personal Information with third parties. We will never sell or rent your Personal Information to third parties for their use without your consent. As a Job Seeker who uses our services, you have given your consent to our sharing your Personal Information with the Job Poster who posted the job you are applying for as well as our third-party software service provider whose servers and systems are encrypted to maintain confidentiality and security of data to industry standards and who is contractually bound to protect and maintain your Personal Information in accordance with this Privacy Policy. KNEF also uses a third-party company to manage credit card processing. This company is not permitted to store, retain, or use billing information except for the sole purpose of credit card processing on KNEF’s behalf and they are required to maintain the confidentiality of the information we provide to them. We may also share non-personally-identifying information in the aggregate with third parties, such as the media, industry observers, potential customers, or partners.

 

For example, we may disclose the number of users that have been exposed to, or clicked on, through our Website. KNEF also partners with a third-party software supplier that works with a scientific partner to perform the personality assessment offered through some of the CV IQ services. The responses to the personality assessment questions will be provided to the scientific partner in a non-identifiable format to permit the scoring of those responses.

 

In other words, as a Job Seeker, none of your personally identifiable information will be provided to, or otherwise associated with your responses to the personality assessment questions provided to the external scientific partner solely for the purpose of permitting scoring of your assessment so there will be no ability for the scientific partner to identify you when scoring the personality assessment. All communications with our scientific partner will be done via a secure interface and no personal details of the Job Seeker will be transmitted with the response or the returned scores. As mentioned, if you are a Job Seeker and have created a CV IQ profile to apply for a job posting we will share your Personal Information you have submitted to us to the Job Poster who posted the job for which you are applying.

​

To whom does KNEF disclose Personal Information and why:

​

1. KNEF shares some of your Personal Information with third-party service providers for the purpose of delivering to you certain services if you have purchased these services from us (this does not apply to Job Seekers, Volunteer Postings, or Volunteers who are not obliged to pay for these services unless they have otherwise purchased a product or service from KNEF which is offered for sale generally to Visitors) This may involve the delivery or actual services or use of third-party platforms or technology. We provide as much information to the third-party service providers as is necessary. We will only share Personal Information with a third-party service provider if you purchase something or register for something relating to that service. Any such third-party service provider that we retain directly is and will continue to be contractually bound to safeguard your Personal Information, not to use it for any purpose other than the delivery of their services, and to otherwise comply with all privacy laws. Use of such third-party services, platforms, and/or technology by you directly, through redirection from the Website or otherwise, will be subject to such third-party service provider’s then-current terms and conditions of use and privacy policy. For a list of third-party service provider used by KNEF, please contact the KNEF privacy officer by e-mail at contact@knefghana.com
    

2. If you elect to subscribe to our mailing list, we will send you updates about us, our products, and other offerings and those of third-party vendors that we believe may be of interest to you. You may at any time opt-out from further receipt of any such e-mail communication. Please note, however, that by unsubscribing, you will no longer receive e-mail notices of changes to the Website’s terms and conditions of use, terms of sale, and/or this privacy policy and you will therefore be required to periodically review these to ensure that no changes have been made since your last visit.
    

3. KNEF may also disclose or share non-personally identifiable information with partners, advertisers, merchants, and/or prospective merchants to help explain our business and the effectiveness of our business or for promotional purposes. For example, we may disclose aggregated demographic information which does not include any personally identifiable information.
    

4. KNEF may transfer your Personal Information to service providers acting on its behalf to perform processing and other specialized services, for example, prize fulfillment of our contests, collection of overdue accounts, investigations regarding potential breaches of your obligations, product delivery, or credit card processing.
    

5. Your Personal Information may be processed and stored outside of the province in which you reside and/or outside of Ghana by us, an affiliate or a third-party service provider for the purposes set out in this Privacy Policy and, under the laws of these other jurisdictions, in certain circumstances foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your Personal Information.
    

6. KNEF may disclose your Personal Information to unrelated parties if we find you have violated any stated terms and conditions of use or terms of sale, or if we need to comply with applicable laws and lawful requests made by law enforcement bodies, governmental bodies, or other legal and regulatory authorities.
    

7. KNEF may disclose your Personal Information to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. We will require such parties to treat your Personal Information in accordance with this Privacy Policy and to use and disclose it only for the purposes for which it was collected.
    

How do you keep my information safe and secure?
 

We are committed to protecting the security of your Personal Information. We employ reasonable technical, administrative, and physical safeguards to protect the confidentiality of your Personal Information, employing industry-recognized technical safeguards, such as firewalls, and have adopted and implemented security procedures to protect your information from loss, misuse, or unauthorized alteration. Notwithstanding our efforts, we cannot guarantee absolute or unqualified protection of this information given the open nature and resulting instability of the Internet and World Wide Web, and we make no representations or warranties as to the effectiveness of our security and assume no liability for security breaches due to “hackers” or any failure in the security of your computer equipment, your Internet service provider or other networks and communications providers.
 

KNEF maintains personal information in a combination of paper and electronic files. We take technical, contractual, administrative, and physical security measures to protect your personal information, including:
 

1. Only employees who need the information to provide services to an individual or relating to an individual are granted access to personally identifying information about such an individual.
    

2. We have certain secure databases where we store data. We also may store your Personal Information in paper document files in our offices.
    

3. The processes of our business include sharing your Personal Information with others to carry out our services.
    

4. Access to this information will be based on a “need to know” basis as prescribed by the requirements of their job function only.
    

Not all KNEF interactions require that credit card information be provided. If you provide the credit card information to us, we work to help protect the security of your credit card information by using industry-standard secure encryption technology. Please be aware that electronic communications through the Internet (either in terms of online forms or questionnaires or by email) are not a secure medium, and any personal information you send to us through the Internet could be intercepted or captured. If your communication is very sensitive, or includes information such as your credit card number, you should not send it electronically unless the email is encrypted, you have adequate and up-to-date security software installed, you have no reason to believe that the system that you are using has been compromised and/or your browser indicates that the access to our website is secure. Materials posted to online forums such as bulletin boards or chat rooms are public, not secure, and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other internet users or identity theft.
 

Obtaining Consent:
 

KNEF will make reasonable commercial efforts to make sure Persons understand how their Personal Information will be used by KNEF. KNEF will obtain consent from Persons before or when it collects or uses the Personal Information. KNEF will never attempt to deceive Persons into giving consent. Person’s consent can be express, implied, or given through an authorized representative. A Person can withdraw consent at any time, with certain exceptions noted herein. KNEF, however, may collect, use, or disclose Personal Information without the Person’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law. When you sign up as a user of the Website, we explicitly ask you to confirm you agree to this Privacy Policy. Continued use of the Website constitutes on-going consent to this Privacy Policy. Additionally, we ask when you sign up whether you want to opt-in to non-transactional communications (e.g., product updates, news, and marketing materials). This preference can be changed at any time. Also, you can withdraw consent for the use of your Personal Information.

​

Refusing or Withdrawing Consent:

​

Subject to legal and contractual requirements, a Person can refuse to consent to KNEF’s collection, use or disclosure of Personal Information about the Person, or a Person may withdraw the Person’s consent to KNEF’s further collection, use or disclosure of Personal Information at any time in the future by giving KNEF reasonable notice and sending such request to knefghana.com unless: i) the consent relates to certain information required for credit approval which a Person applies for or accepts, ii) the consent is otherwise required by law or iii) the use or disclosure is permitted by law or is related to the legal or regulatory requirements described herein. If a Person refuses or withdraws the Person’s consent, KNEF may not be able to provide the Person or continue to provide the Person with some products, services or information which may be of value to the Person.

​

Internet Aspects:

​

Personal Information may be collected by KNEF or third-party service providers on KNEF’s behalf. Although the information collected, used, or disclosed on the Internet as described below usually does not constitute Personal Information (and to the extent that such is the case, then the obligations under the KNEF Privacy Policy do not extend to such information), KNEF provides the details below about Internet aspects of KNEF’s services for the purposes of disclosure. Internet Protocol Address (IP Address) When the user’s web browser requests a web page from another computer on the Internet, it automatically gives that computer the address where it should send the information. This address is called the computer’s “IP address.” For most users accessing the Internet from an Internet service provider (ISP), the IP address will be different every time the user logs on.

​

KNEF may use the user’s IP Address to:

​

• Facilitate the diagnosis and remedy of a technical problem reported by the user’s or KNEF’s technical team.

• Display (or allow the display by Third Party advertising providers of) more appropriate and relevant content and advertising, such as content and advertising based on the user’s geographic area, demographic profile, and Website session behavior.

• Estimate user traffic from specific countries or organizations. Many IP addresses are commonly associated with Internet service providers, universities, or major corporations in specific regions or localities. Aggregate information derived from IP addresses may also be reported to advertisers.
   

Cookies:
 

A cookie is a small text file, which often includes an anonymous unique identifier that is sent to the user’s web browser from a website’s computers and is stored on the user’s computer’s hard drive. Cookies cannot be used to run programs or deliver viruses to a user’s computer.

KNEF may use cookies to:
 

• Improve the operation and performance of the KNEF services and to make KNEF services easier and more convenient to use. For example, cookies help KNEF provide more personalized services by recalling user preferences on subsequent visits. Cookies also allow KNEF to save passwords and preferences for a user so that the user will not have to re-enter them on the next visit to the KNEF site.
   

• Measure aggregate user traffic and demographic statistics related to KNEF services and advertisements (e.g., number of users, average time spent, average age and similar statistics). This information helps KNEF to better understand when to update, change or offer new services and provides KNEF with details as to the performance of Third-Party advertisements and content. This information may be reported, in aggregate form only, to KNEF’s current and prospective sponsors, advertisers and business partners. No Personal Information will be disclosed in such reports.
   

• Display advertisements. KNEF and Third-Party advertising providers may use cookies when serving advertisements on KNEF sites. In some cases, advertisements from Third Party advertisers are delivered to users (in conjunction with KNEF Services) by such Third-Party advertisers, or by separately contracted advertising providers on their behalf, and not by KNEF; as such, the Third-party advertisers’ use of cookies is subject to their own privacy policies, not the KNEF Privacy Policy, and users should consult the privacy policies of such Third-Party advertisers.
   

• Most browsers are initially set up to accept cookies. If a user prefers, the user can reset his/her browser either to notify the user when the user has received a cookie or to refuse to accept cookies. The user should understand that while KNEF does not require a user to use cookies, certain KNEF services will not function properly if a user sets his/her browser to not accept cookies.
   

Links to Other Sites and Advertisements:
 

A KNEF service may contain links to other websites and services. While KNEF tries to link only to sites and services that share KNEF’s high standards and respect for privacy, a user should understand that KNEF is not responsible for the content of, or the privacy practices employed by, other companies or websites. This KNEF Privacy Policy applies only to the KNEF services related to this KNEF Privacy Policy. Many of the advertisements that are displayed in connection with KNEF services are served through one or more reputable Third-Party advertisement-serving companies that deliver the advertisements to users in conjunction with KNEF services.
 

International Use:
 

We are headquartered in Ghana. Personal information may be accessed by us or transferred to us in Ghana through the use of our services or by visitors or users of the Website elsewhere in the world. By providing us with Personal Information, you consent to this transfer. We will protect the privacy and security of Personal Information according to this Privacy Policy, regardless of where it is processed or stored, however, you explicitly acknowledge and consent to the fact that Personal Information stored or processed in Ghana will be subject to the laws of Ghana, including the ability of governments, courts or law enforcement or regulatory agencies of Ghana to obtain disclosure of your Personal Information. Please note that privacy laws in some provinces are different than those in Bono East (where the Website’s registered office is based) or under federal Ghana Law.
 

Additional Information:
 

KNEF automatically collects certain information about the user’s computer hardware and software. This information may include browser type, operating system type, domain names, access times, and referring website addresses. This information is used by KNEF to operate the service, to maintain the quality of the service, and to provide general statistics regarding the use of the KNEF Website. Certain KNEF Services may be co-branded and offered in conjunction with another company or organization. If a user registers for or uses such services, both KNEF and the other company or organization may receive information collected in conjunction with the co-branded services.
 

The KNEF Privacy Policy Principles:

​

Definitions:

​

Collection:

​

the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.

​

Consent:

 

voluntary agreement with the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the Person or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of KNEF. Implied consent is consent that can reasonably be inferred from a Person’s action or inaction.

​

Disclosure:

 

making Personal Information available to a Third Party.

​

Employee:

 

employee or independent contractor (including freelancers)1 of KNEF

1The inclusion of independent contractors, including freelancers, within the definition of “Employee” is for convenience of reference only, and does in no manner imply that such individuals are employees of the company within the meaning of employment legislation or are in an employee-employer relationship with the company.

​

Individual:

​

an individual other than an Employee who (a) corresponds with KNEF, including complaints and including applications for employment; (b) enters an contest sponsored by KNEF; or (c) uses, or applies to use, the products or services of KNEF.

 

Person:

​

an Employee or an Individual.

 

Personal Information:

​

information about an identifiable Person, but not: a) information that is publicly available, such as a Person’s name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; b) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; c) information collected, used or disclosed in the course of journalistic, literary or artistic activities; or d) aggregate information that cannot be associated with a specific person, such as demographic statistics about KNEF customers, or number of visitors and average time spent on a website.

 

Third-Party:

​

a person other than the Person or his agent, or an organization other than KNEF

 

Use:

​

the treatment, handling, and management of Personal Information by KNEF

​

Principle 1 – Accountability

​

Charity Village is responsible for Personal Information under its control and shall designate one or more persons who are accountable for Charity Village ‘s compliance with the following principles. 1.1 Responsibility for ensuring compliance with the provisions of the Charity Village Privacy Policy rests with the senior management of Charity Village, which shall designate one or more persons to be accountable for compliance with the Charity Village Privacy Policy. Other people within Charity Village may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to- day collection and processing of Personal Information. 1.2 KNEF has designated a Chief Privacy Officer to oversee compliance with the KNEF Privacy Policy.  KNEF is responsible for Personal Information in its possession or control, including information that has been transferred to a Third Party for processing. KNEF shall use appropriate means to provide a comparable level of protection while information is being processed by a Third Party (see Principle 7). 1.4 KNEF is continually in the process of implementing and updating policies and procedures to give effect to the KNEF Privacy Policy, including: a) implementing procedures to protect Personal Information and to oversee KNEF ‘s compliance with the KNEF Privacy Policy; b) establishing procedures to receive and respond to inquiries or complaints; c) training and communicating to staff about KNEF ‘s policies and practices; and d) developing public information to explain KNEF ‘s policies and practices.

​

Principle 2 – Identifying Purposes for Collection of Personal Information

​

KNEF has collected and collects Personal Information for the purposes set out below and shall identify the purposes for which Personal Information is collected at or before the time the information is collected. 2.1 KNEF has collected and collects Personal Information for the following purposes: a) to establish and maintain responsible commercial relations with Individuals and to provide ongoing service; b) to understand Individual needs; c) to develop, enhance, market or provide products and services; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible KNEF corporate re-organization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of KNEF, provided that the Personal Information disclosed continues to be used by the entity acquiring the information either for evaluation of the possible transaction, or, on completion of any such transaction, for the purposes permitted by this Privacy Policy.

​

As examples of the above:

​

1. KNEF may from time to time use a Person’s Personal Information to contact the Person about changes, enhancements or similar notices related to KNEF products and services.
    

2. if a Person indicated that he/she was interested in receiving offers or information from KNEF or certain of our selected sponsors or advertisers, KNEF may send the Person materials about products and services that KNEF feels may be of interest to the Person; and
    

3. if a Person enters a contest or other promotion offered on a KNEF website, KNEF may, under the rules of the promotion, use the Person’s name and certain other information to administer the promotion, such as contacting, announcing, and promoting the winners of the promotion.
    

Further references to “identified purposes” mean the purposes identified in this Principle.  KNEF shall specify orally, electronically or in writing the identified purposes to the Person at or before the time Personal Information is collected. Upon request, persons collecting Personal Information shall explain these identified purposes or refer the Person to a designated person within KNEF who shall explain the purposes. Unless required by law, KNEF shall not use or disclose, for any new purpose, Personal Information that has been collected without first identifying the new purpose and obtaining the consent of the Person.
 

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
 

The knowledge and consent of a Person are required for the collection, use or disclosure of Personal Information, except where inappropriate.  Generally, KNEF shall seek consent to use and disclose Personal Information at the same time it collects the information. However, KNEF may seek consent to use and disclose Personal Information after it has been collected but before it is used or disclosed for a new purpose. In obtaining consent, KNEF shall use reasonable efforts to ensure that a Person is advised of the identified purposes for which Personal Information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the Person. KNEF will require Individuals to consent to the collection, use or disclosure of Personal Information as a condition of the supply of a product or service only if such collection, use, or disclosure is required to fulfill the identified purposes. In determining the appropriate form of consent, KNEF shall take into account the sensitivity of the Personal Information and the reasonable expectations of the Persons.  In general, the use of products and services by an Individual, or the acceptance of employment or benefits by an Employee, constitutes implied consent for KNEF to collect, use and disclose Personal Information for all identified purposes.  An Individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Individuals may contact KNEF for more information regarding the implications of withdrawing consent.  In certain circumstances, Personal Information can be collected, used, or disclosed without the knowledge and consent of the Person. For example, KNEF may collect or use Personal Information without knowledge or consent if it is clearly in the interests of the Person and consent cannot be obtained in a timely way, such as when the Person is a minor, seriously ill or mentally incapacitated. KNEF may also collect, use, or disclose Personal Information without knowledge or consent if seeking the consent of the Person might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law. KNEF may also use or disclose Personal Information without knowledge or consent in the case of an emergency where the life, health, or security of an individual or property is threatened. KNEF may disclose Personal Information without knowledge or consent to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise related to the legal or regulatory requirements described herein. The KNEF, its outside suppliers and other third parties to whom we disclose information under this policy may perform activities outside of Ghana. As a result, your information may be securely used, stored, or accessed in other countries and may be subject to the laws of those countries. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries.
 

Principle 4 – Limiting Collection of Personal Information
 

KNEF shall limit the collection of Personal Information to that which is necessary for the purposes identified by KNEF shall collect Personal Information by fair and lawful means. 4.1 KNEF collects Personal Information primarily from Individuals or its Employees. 4.2 KNEF may also collect Personal Information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information.
 

Principle 5 – Limiting Use, Disclosure and Retention of Personal Information
 

KNEF shall not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the Person or as required by law. KNEF shall retain Personal Information only if necessary, for the fulfillment of the purposes for which it was collected. In certain circumstances Personal Information can be collected, used, or disclosed without the knowledge and consent of the Person. (See Principle 3.7) In addition, KNEF may disclose a Person’s Personal Information to: a) a person who, in the reasonable judgment of KNEF, is seeking the information as an agent of the Person; b) a Third Party or Third Parties, where the Person consents to such disclosure or disclosure is required by law.  KNEF may disclose Personal Information about its employees: a) for normal personnel and benefits administration; b) in the context of providing references regarding current or former employees in response to requests from prospective employers; or c) where disclosure is required by law.  Only those Employees of KNEF who require access for business reasons, or whose duties reasonably so require, or properly designated representatives of KNEF, are granted access to Personal Information about Individuals and Employees.  KNEF shall keep Personal Information only if it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where Personal Information has been used to make a decision about a Person, KNEF shall retain, for a period that is reasonably sufficient to allow for access by the Person, either the actual information or the rationale for making the decision. KNEF shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to Personal Information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased, or made anonymous.
 

Principle 6 – Accuracy of Personal Information
 

Personal Information shall be as accurate, complete, and up to date as is necessary for the purposes for which it is to be used. Personal Information used by KNEF shall be sufficiently accurate, complete, and up to date to minimize the possibility that inappropriate information may be used to make a decision about a Person. KNEF shall update Personal Information about Persons as and when necessary to fulfill the identified purposes or upon Alert by the Person.
 

Principle 7 – Security Safeguards
 

KNEF shall protect Personal Information by security safeguards appropriate to the sensitivity of the information.  KNEF shall protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification, or destruction, through appropriate security measures. KNEF shall protect the information regardless of the format in which it is held. KNEF shall protect Personal Information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.  All employees of KNEF with access to Personal Information shall be required as a condition of employment to respect the confidentiality of Personal Information.
 

Principle 8 – Openness Concerning Policies and Practices
 

KNEF shall make readily available to Persons specific information about its policies and practices relating to the management of Personal Information.  KNEF shall make information about its policies and practices easy to understand, including a) The title and address of the person or persons accountable for the compliance with the KNEF Privacy Policy and to whom inquiries or complaints can be forwarded; b) The means of gaining access to Personal Information held by KNEF; and c) A description of the type of Personal Information held by KNEF, including a general account of its use.  KNEF shall make available information to help Persons exercise choices regarding the use of their Personal Information.
 

Principle 9 – Access to Personal Information
 

KNEF shall inform a Person of the existence, use and disclosure of his or her Personal Information upon request and shall give the Person access to that information. A Person shall be able to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.  Upon request, KNEF shall afford to a Person a reasonable opportunity to review the Personal Information in the Person’s file. Personal Information shall be provided in understandable form within a reasonable time and at minimal or no cost to the Person. In certain situations, KNEF may not be able to provide access to all of the Personal Information that they hold about a Person. For example, KNEF may not provide access to information if doing so would likely reveal Personal Information about a Third Party or could reasonably be expected to threaten the life or security of another person. Also, KNEF may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated during a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law, or if the information was collected as part of journalistic activities. If access to Personal Information cannot be provided, KNEF shall provide the reasons for denying access upon request. Upon request, KNEF shall provide an account of the use and disclosure of Personal Information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, KNEF shall provide a list of organizations to which it may have disclosed Personal Information about the individual when it is not possible to provide an actual list. To safeguard Personal Information, an individual or employee may be required to provide sufficient identification information to permit KNEF to account for the existence, use and disclosure of Personal Information and to authorize access to the individual’s file. Any such information shall be used only for this purpose. KNEF shall promptly correct or complete any Personal Information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the Person’s file. Where appropriate, KNEF shall transmit to third parties having access to the Personal Information in question any amended information or the existence of any unresolved differences.  A Person can obtain information or seek access to his or her Personal Information by contacting a designated representative at KNEF principal office. An employee can obtain information or seek access to his or her Personal Information by contacting his or her immediate supervisor within KNEF
 

Principle 10 – Challenging Compliance
 

A Person shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for the compliance of KNEF with the KNEF Privacy Policy.  KNEF shall maintain procedures for addressing and responding to all inquiries or complaints from Persons about KNEF ‘s handling of their Personal Information. If any Person at any time has any questions or concerns about KNEF ‘s privacy practices, the Person can email to contact@knefghana.com KNEF shall inform Persons about the existence of these procedures as well as the availability of complaint procedures. The person or persons accountable for compliance with the KNEF Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints. KNEF shall investigate all complaints concerning compliance with the KNEF Privacy Policy. If a complaint is found to be justified, KNEF shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A Person shall be informed of the outcome of the investigation regarding his or her complaint.