1. INTRODUCTION

Welcome to our platform.

Our platform is designed to create a voluntary community of users who choose to participate in a structured contact-exchange system. The purpose of this system is to allow participating members to share their WhatsApp-associated contact numbers with other participating members through periodic contact files, including VCF files.

We take privacy, transparency, responsible data handling, security and informed user consent seriously.

This Privacy, Data Consent & Platform Participation Policy explains what information we collect, why we collect it, how we use it, how participating members' contact information may be shared, how the weekly contact-exchange system operates, and the responsibilities and rights of every participant.

By registering, activating an account, checking a consent box, downloading a contact file, or otherwise participating in the platform, you confirm that you have read and understood this policy and agree to the processing and sharing of your information as described below.

If you do not agree with these terms, you should not register for or participate in the contact-exchange program.


2. PURPOSE OF THE PLATFORM

The platform operates as a voluntary member-to-member contact-exchange community.

The purpose of the contact-exchange system is to allow participating members to share their voluntarily submitted WhatsApp contact numbers with other participating members who have also agreed to participate in the same system.

Members may periodically receive downloadable contact files containing contact information belonging to other eligible participating members.

The platform does not guarantee that participation will result in a specific number of WhatsApp Status views, messages, followers, customers, leads, sales, engagements, impressions or any other particular result.

Participation is intended to provide an opportunity for members to connect with one another. Actual results depend on numerous factors outside the platform's control.


3. IMPORTANT NOTICE ABOUT WHATSAPP STATUS VISIBILITY

The platform does not control WhatsApp and is not WhatsApp.

The platform is not operated by, affiliated with, sponsored by, endorsed by or officially connected to WhatsApp or Meta unless expressly stated otherwise.

Adding or importing another participant's phone number into your contacts does not guarantee that you will see that person's WhatsApp Status.

WhatsApp independently determines how its services operate, including privacy settings, Status visibility, contact relationships, account restrictions and other technical factors.

A participant may therefore receive and import a contact through the platform without being able to see that person's Status.

For this reason, no specific number of Status views or other engagement results are promised or guaranteed.


4. INFORMATION WE MAY COLLECT

Depending on how you use the platform, we may collect information necessary to operate and secure the service.

This may include:

Account Information

  • Full name or display name;
  • Phone number;
  • WhatsApp number;
  • Email address;
  • Username;
  • Password or authentication information;
  • Account registration date;
  • Account status.

Participation Information

We may collect information relating to your participation, including:

  • Activation status;
  • Membership status;
  • Contact-exchange eligibility;
  • VCF download history;
  • Dates of participation;
  • Account activity;
  • Referral information where applicable;
  • Contact distribution records;
  • Withdrawal or opt-out requests.

Payment Information

Where an activation or membership payment is required, information necessary to verify the transaction may be processed.

Payments may be handled through third-party payment providers.

Where possible, payment-card or other sensitive payment information will be handled directly by the relevant payment provider rather than unnecessarily stored on our systems.

Technical Information

Our systems may automatically collect limited technical information such as:

  • IP address;
  • Browser type;
  • Device type;
  • Operating system;
  • Login dates and times;
  • Security logs;
  • Error and diagnostic information.

Technical information may be used for security, fraud prevention, troubleshooting and proper operation of the platform.


5. WHY WE COLLECT YOUR INFORMATION

Information may be processed for the following purposes:

  • A. Account Creation: To create, maintain and administer your account.
  • B. Verification: To help prevent fake registrations, duplicate accounts, fraudulent activity and unauthorized access.
  • C. Contact Exchange: To operate the member contact-exchange system. This may include placing a voluntarily submitted WhatsApp number into an eligible member pool and making that number available through an appropriate contact file to other eligible participating members.
  • D. Weekly Contact Distribution: To generate and distribute periodic contact files containing participating members who have consented to the exchange.
  • E. Security: To detect suspicious activity, fraud, abuse, unauthorized access and attempts to manipulate the platform.
  • F. Customer Support: To respond to questions, complaints, technical problems and account-related requests.
  • G. Payment Verification: To verify activation or membership payments where applicable.
  • H. Service Improvement: To understand how members interact with the platform and improve its functionality, reliability and security.
  • I. Legal Compliance: To comply with applicable laws, lawful requests and legitimate legal obligations.

6. YOUR PHONE NUMBER AND CONTACT SHARING

This section is especially important.

By joining the contact-exchange program and submitting your WhatsApp number for participation, you understand and expressly agree that your number is intended to be shared with other eligible participating members.

Your number may therefore be included in a downloadable VCF or other contact file distributed to participating members.

This sharing is a fundamental part of the contact-exchange service.

You should therefore only submit a telephone number that you own or are legally authorized to provide and share for this purpose.

You must not submit another person's telephone number without their appropriate authorization or consent.

By providing your number and accepting the contact-exchange consent, you acknowledge that other participating members may obtain your number through the platform's contact distribution system.


7. VOLUNTARY AND INFORMED CONSENT

Participation in the contact-exchange program is voluntary.

Users should be given a clear explanation of the nature of the service before registration or activation.

The consent process is designed to ensure that participants understand that their submitted WhatsApp contact number may be shared with other participating members.

Users should carefully read the consent statement before selecting any button or checkbox indicating agreement.

If you do not want your WhatsApp number to be distributed to other participating members, you should not provide that number for participation in the contact-exchange program.


8. WITHDRAWING CONSENT

Participants may request to withdraw their consent from future participation in the contact-exchange program.

After receiving a valid withdrawal request, reasonable steps may be taken to:

  1. Disable the user's eligibility for future contact distributions;
  2. Remove the user's number from future contact-generation pools;
  3. Stop using the number for future distributions based on the withdrawn consent;
  4. Process applicable deletion, restriction or anonymization requests where legally required or appropriate.

However, withdrawal of consent cannot necessarily retrieve contact information that has already been downloaded by another participant.

For example, if your number was previously included in a VCF file that another participant downloaded and imported into their device, the platform may not have the technical ability to remotely delete that copy from the person's phone.

Participants should therefore understand the consequences of contact sharing before joining the program.


9. DOWNLOADED CONTACT FILES

Once a VCF or other contact file has been downloaded by a participating member, the platform cannot guarantee that the recipient will subsequently delete the file or remove the contacts from their device.

Reasonable measures will be taken to control the distribution of contact information through the platform's own systems.

However, information that has already been received and stored on another participant's personal device may be outside the platform's technical control.

Participants are expected to respect the privacy of other members and use received information only for lawful and legitimate purposes consistent with the purpose of the platform.


10. MEMBER RESPONSIBILITIES

Every participant is responsible for using the platform and information received through it responsibly and lawfully.

Participants must not:

  • Upload another person's telephone number without appropriate authorization;
  • Use members' contact information for harassment;
  • Send abusive or threatening communications;
  • Impersonate another person;
  • Engage in fraud or deception;
  • Attempt to obtain sensitive personal information from other participants;
  • Scrape or copy the entire member database;
  • Attempt to bypass platform security;
  • Manipulate membership or download records;
  • Create fraudulent or duplicate accounts;
  • Abuse automated systems;
  • Use the platform for unlawful activities;
  • Sell or distribute members' contact information outside the permitted purpose;
  • Use members' information for malicious, abusive or deceptive purposes.

Accounts may be suspended or terminated where there is evidence of serious abuse, fraud, security violations or other prohibited conduct.

Serious or potentially unlawful conduct may be reported to appropriate authorities where required or reasonably necessary.


11. NO GUARANTEE OF RESULTS

Participation in the platform does not constitute a guarantee of any particular outcome.

We do not guarantee:

  • A specific number of WhatsApp Status views;
  • A specific number of Status viewers;
  • A specific number of contacts;
  • Increased followers;
  • Increased messages;
  • Increased engagement;
  • Increased customers;
  • Increased sales;
  • Increased leads;
  • Increased business opportunities;
  • Any specific financial result.

Different participants may experience different results.

Results may be affected by WhatsApp privacy settings, account activity, contact settings, user behavior, technical limitations and numerous other factors outside our control.


12. WHATSAPP PRIVACY SETTINGS AND PLATFORM RULES

WhatsApp users control various aspects of their own accounts and privacy.

Participants are responsible for complying with WhatsApp's applicable Terms of Service, privacy policies and other rules governing their use of WhatsApp.

The platform does not instruct participants to spam, harass, abuse, impersonate, deceive or unlawfully contact other people.

Participants are responsible for how they use any contact information they receive.

Any restriction, suspension, limitation or other action taken against a participant's WhatsApp account by WhatsApp is outside the platform's control.


13. DATA MINIMIZATION

We aim to collect only information reasonably necessary for operating, securing and improving the service.

We do not intentionally require participants to provide unnecessary sensitive personal information simply to participate in the contact-exchange program.

Where information is not reasonably necessary for the stated purpose, we seek to avoid collecting it.


14. DATA SECURITY

Reasonable technical and organizational measures will be used to protect personal information against unauthorized access, unauthorized disclosure, accidental loss, destruction, unauthorized alteration and misuse.

Security measures may include:

  • Account authentication;
  • Access controls;
  • Database permissions;
  • Secure hosting practices;
  • Security monitoring;
  • Logging;
  • Administrative controls;
  • Reasonable measures designed to prevent unauthorized access.

However, no website, database, application or internet-based service can guarantee absolute security.

Participants acknowledge that online services may be exposed to risks such as cyberattacks, technical failures, unauthorized access or other events despite reasonable security measures.

Where applicable law requires notification of a data-security incident, appropriate steps will be taken in accordance with the applicable legal requirements.


15. DATA RETENTION

Personal information may be retained for as long as reasonably necessary to:

  • Maintain your account;
  • Provide the service;
  • Verify transactions;
  • Prevent fraud and abuse;
  • Maintain platform security;
  • Resolve disputes;
  • Maintain appropriate business records;
  • Comply with legal obligations;
  • Establish, exercise or defend legal claims.

When information is no longer reasonably required, it may be deleted, anonymized or securely disposed of, subject to applicable legal and operational requirements.


16. THIRD-PARTY SERVICE PROVIDERS

Certain parts of the platform may rely on third-party service providers.

These may include providers of:

  • Website hosting;
  • Cloud infrastructure;
  • Database services;
  • Payment processing;
  • Email delivery;
  • SMS or phone verification;
  • Security services;
  • Analytics;
  • Customer support.

Where third parties process information on behalf of the platform, reasonable measures will be taken to ensure that such processing is limited to legitimate service-related purposes and that appropriate safeguards are maintained.


17. PAYMENTS AND ACCOUNT ACTIVATION

Where an activation or membership fee is required, payment is separate from the user's underlying consent to data processing.

Payment for participation does not give a user ownership of another participant's personal information.

Payment also does not give a participant permission to use members' contact information for purposes outside the stated purpose of the platform.

Any applicable payment, cancellation or refund conditions will be communicated separately through the platform's relevant terms and policies.


18. USER PRIVACY RIGHTS

Subject to applicable law and reasonable identity-verification requirements, users may have rights relating to their personal information.

These may include the right to:

  • Know how their information is being processed;
  • Request access to personal information held about them;
  • Request correction of inaccurate information;
  • Request deletion where legally applicable;
  • Object to certain forms of processing;
  • Withdraw consent;
  • Request information about how their information is being used;
  • Raise a privacy-related complaint.

Privacy-related requests should be submitted through the platform's designated privacy or support channel.

Reasonable verification may be required before certain requests can be processed.


19. CHILDREN AND MINORS

The platform is intended for individuals who are legally permitted to participate in the service.

We do not knowingly seek to collect personal information from children where doing so would violate applicable law.

Individuals who are below the applicable legal age for independently consenting to this type of service should not register without the legally required involvement of a parent or guardian.

If information is discovered to have been collected in violation of applicable age or consent requirements, appropriate steps may be taken to delete, restrict or otherwise address that information.


20. INTERNATIONAL DATA PROCESSING

The technology used to operate an online platform may involve service providers or infrastructure located in jurisdictions outside Ghana.

Where personal information is stored or processed outside Ghana, reasonable steps will be taken to address applicable data-protection requirements.

Users acknowledge that cloud infrastructure, hosting providers and internet services may operate across multiple jurisdictions.


21. NO SALE OF MEMBER CONTACT DATABASE

The member contact database is not intended to be sold as a standalone personal-information product.

Participation in the contact-exchange program does not mean that a member's phone number may be sold to unrelated third parties for their independent marketing purposes.

The primary purpose of processing and distributing participating members' numbers is the operation of the member contact-exchange system described in this policy.

Any materially different use of personal information should be addressed through appropriate disclosure and consent where required.


22. POLICY UPDATES

This policy may be updated from time to time to reflect:

  • Changes to the platform;
  • New features;
  • Changes to our data practices;
  • Changes in applicable law;
  • Security improvements;
  • Operational requirements.

Where material changes are made, appropriate notice may be provided through the platform, dashboard, email or another reasonable communication method.

The "Last Updated" date will be changed when this policy is materially revised.


23. TRANSPARENCY

We believe participants should understand what they are agreeing to before submitting their personal information.

Participants are encouraged to read this policy carefully before registering or activating an account.

If any part of the contact-exchange system or data-sharing process is unclear, participants should seek clarification through the available support or privacy channel before submitting their information.


24. DATA PROTECTION AND APPLICABLE LAW

The platform intends to operate in accordance with applicable privacy and data-protection requirements.

For participants in Ghana, this includes applicable requirements under Ghana's data-protection framework, including the Data Protection Act, 2012 (Act 843), as applicable.

The platform may also consider other applicable privacy requirements depending on the location of users and the circumstances of the processing.

Nothing in this policy is intended to remove or restrict a legal right that cannot lawfully be excluded.


25. PRIVACY CONTACT

Privacy-related questions, requests, complaints, correction requests, deletion requests and withdrawal-of-consent requests should be submitted through the official privacy or support contact provided on the platform.

Users may be required to provide sufficient information to verify that they are the owner of the relevant account or personal information before certain requests can be processed.