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Nafex Hub

Privacy policy and data safeguards

How Nafex Hub collects, safeguards and processes personal data.

Effective September 2026. Version 3.2. Governing jurisdiction: Republic of Ghana.

1. Corporate Identity & Data Controller

Identity of the legal entity responsible for personal data management.

This Privacy Policy sets forth the privacy and data protection principles of Nafex Hub Ghana Limited ("Nafex Hub", "we", "us", or "our"), a commercial entity duly incorporated under the Companies Act, 2019 (Act 992) of the Republic of Ghana, with our principal operating headquarters situated in Accra, Greater Accra Region, Ghana.

Nafex Hub acts as the designated Data Controller within the meaning and statutory definitions of the Ghana Data Protection Act, 2012 (Act 843). In this capacity, Nafex Hub determines the purposes and means of processing personal data collected from registered buyers, verified merchants, trade suppliers, logistics riders, and site visitors across our marketplace platform, web applications, and related mobile interfaces.

Data Protection Officer (DPO) Contact:

Office of Data Protection & Regulatory Compliance, Nafex Hub Ghana Ltd

Accra Commercial District, Greater Accra, Republic of Ghana

Dedicated Email: privacy@nafexhub.com / nafexgroupltd@gmail.com

2. Regulatory Scope & Legal Framework

Statutory laws governing electronic transactions, data privacy, and payments in Ghana.

Our data processing operations are strictly benchmarked against and conform to the following statutory enactments and regulatory guidelines of the Republic of Ghana:

  • Data Protection Act, 2012 (Act 843): Enforcing the fundamental principles of accountability, lawfulness, purpose specification, data minimization, data quality, security safeguards, and data subject participation.
  • Electronic Transactions Act, 2008 (Act 772): Governing electronic commerce, contractual validity of digital signatures, pre-contractual consumer disclosures, and intermediary safe harbors.
  • Payment Systems and Services Act, 2019 (Act 987): Enacted by the Parliament of Ghana and regulated by the Bank of Ghana (BoG), governing electronic money transactions, escrow facilitation, and integration with licensed payment service providers.
  • Protection Against Unfair Competition Act, 2000 (Act 589): Safeguarding consumers and legitimate merchants against deceptive representations, intellectual property infringement, and counterfeit merchandise.
  • International Data Standards & GDPR Adequacy: Where transactions involve diaspora buyers or cross-border B2B trade partners within the ECOWAS sub-region or the European Union, we uphold compliance standards aligned with Regulation (EU) 2016/679 (GDPR).

3. Personal Information We Collect

Specific categories of buyer, seller, rider, and transactional data collected.

Depending on your role and engagement on the Nafex Hub marketplace, we collect and process the following categories of personal data:

Buyer Account Data

Full legal name, primary email address, active telephone number (used for Mobile Money verification and transactional dispatch alerts), delivery GPS address, digital delivery coordinates, order records, and dispute submissions.

Merchant & KYC Verification

Business name, Registrar General’s Department / Office of Registrar of Companies (ORC) registration number, Tax Identification Number (TIN), Ghana Card (National Identification) number, physical store GPS address, and settlement bank/MoMo recipient codes.

Financial & Escrow Records

Transaction identifiers, NFX order numbers, payment timestamps, Paystack reference codes, Mobile Money MSISDN, and payout ledger entries. Important: Full debit/credit card numbers and CVV security codes are handled exclusively by PCI-DSS certified gateway Paystack and are never stored on Nafex Hub servers.

AI Support & Communications

Customer service chat logs, AI assistant conversation transcripts, ticket resolutions, internal messaging between buyers and verified merchants, and uploaded photographic or video dispute evidence.

We also automatically collect standard telemetry and diagnostic data, including client IP addresses, browser types, session cookies, operating system signatures, and referral URLs to ensure network integrity and combat automated fraud.

4. Lawful Grounds for Processing

The legal bases under Act 843 Section 18 supporting every data operation.

Pursuant to Section 18 of the Data Protection Act, 2012 (Act 843), personal data is processed solely under the following lawful conditions:

1. Contractual Performance

Processing is required to execute the electronic contract between buyer and seller, authenticate accounts, verify escrow funding, coordinate dispatch with delivery riders, and process refunds.

2. Statutory & Legal Obligations

Compliance with statutory reporting, invoicing regulations under Ghana Revenue Authority (GRA) Act 1151 / Act 870, Anti-Money Laundering legislation, and formal judicial or police requests under Act 843 §60.

3. Legitimate Commercial Interests

Protecting platform integrity, detecting and neutralizing card testing attacks, preventing multi-account voucher abuse, preventing off-platform fee circumvention, and maintaining high server availability.

4. Informed Consent

Where explicit consent is granted, such as subscribing to curated promotional updates, marketing broadcasts, or voluntary merchant surveys. Consent may be rescinded at any time.

5. Escrow Payment Mechanics & Payment Security

How your payments are held securely in escrow and protected under Bank of Ghana standards.

Nafex Hub operates an advanced, non-custodial marketplace escrow protection system engineered in partnership with Paystack Ghana Ltd, a licensed Payment Service Provider authorized by the Bank of Ghana under the Payment Systems and Services Act, 2019 (Act 987).

Principles of Nafex Escrow Protection

  • No Direct Merchant Custody: When you purchase an item using MTN Mobile Money, Telecel Cash, AT Money, or Visa/Mastercard, funds do not transfer directly to the merchant. Instead, funds are placed into cryptographic escrow status (in_escrow).
  • Server-Side Pricing Authorization: Order amounts are validated strictly against verified database catalog rates on our backend, eliminating unauthorized client-side tampering.
  • Conditional Payout Release: Escrowed funds are disbursed to the merchant’s payout recipient code only when the customer formally confirms delivery or the dispute inspection window expires with no dispute recorded.
  • 0% Commission: The platform deducts no commission before paying the seller.

6. Delivery Protocol & The 6-Digit Verification OTP

The cryptographic one-time passcode securing physical handoff and escrow release.

To guarantee mutual security for buyers, sellers, and dispatch couriers, Nafex Hub enforces a strict 6-Digit Delivery OTP Protocol:

  1. When a seller dispatches an order and marks it Out for Delivery, our automated server generates a unique, cryptographically random 6-digit numeric OTP (deliveryOtp) valid for a 24-hour window.
  2. This OTP is instantly delivered to the buyer via authenticated email and in-platform notification.
  3. Critical Security Notice: The buyer must inspect the merchandise upon courier arrival to verify quantity, condition, and quality. Do not share your 6-digit OTP until you have physically inspected and accepted the delivered items.
  4. When the buyer provides the OTP to the rider and it is verified in the system, the order transitions to Delivered, and the payment escrow engine automatically schedules the seller's payout release.

7. Third-Party Data Sharing & Sub-Processors

Trusted service providers who process data on our behalf.

Nafex Hub does not sell, rent, or monetize your personal information to marketing brokers. Personal data is shared strictly on a need-to-know basis with audited sub-processors who adhere to confidentiality agreements and security standards:

Partner / Sub-ProcessorCategory & Operational Purpose
Paystack Ghana LimitedPayment processing, escrow reconciliation, and MoMo disbursements
Mobile Network Operators (MTN, Telecel, AT)Transactional SMS alerts, OTP dispatch, and billing handshakes
Vetted Logistics & Rider PartnersPhysical delivery routing (name, recipient phone, and GPS delivery address only)
Cloudinary & Object StorageEncrypted hosting for product catalogs, merchant KYC, and dispute evidence
Ghana Revenue Authority (GRA)Mandatory tax reporting and statutory e-commerce invoice audits

8. AI Support Assistant & Telemetry Logging

Transparency on artificial intelligence chatbots, logging, and human handoff.

Nafex Hub deploys an automated AI Customer Support Assistant to deliver 24/7 self-service resolutions for order tracking, FAQ inquiries, returns guidance, and seller support.

  • Data Capture: Text prompts and conversation logs are indexed within our database (ai_conversations and ai_messages) to contextualize support inquiries and streamline ticket escalations.
  • Human Escalation: If the AI assistant cannot resolve your inquiry or if you request human review, the conversation transcript and metadata are automatically routed to our human support representatives.
  • No Unsanctioned Profiling: We do not deploy automated decision-making systems that produce legal or similarly significant effects concerning data subjects without human oversight.

9. Technical & Operational Data Safeguards

Encryption, role-based access controls, and defense-in-depth security.

In compliance with Section 28 of the Data Protection Act (Act 843), we enforce institutional, organizational, and technical safeguards designed to protect personal information against loss, unauthorized access, destruction, or disclosure:

In-Transit & At-Rest EncryptionAll communications are encrypted using modern Transport Layer Security (TLS 1.3). Database credentials, API secrets, and sensitive tokens are encrypted using AES-256 and salted scrypt algorithms.
Strict Role-Based Access (RBAC)Platform personnel access personal data strictly on a least-privilege basis. All administrator interventions are immutably audited via central logging.
Redaction in Audit LoggingPasswords, session JWTs, credit card tokens, and Mobile Money PINs are automatically redacted prior to log generation.
Automated Idempotency & Rate LimitingCritical payment endpoints and authentication handlers employ cryptographic HMAC signatures and IP rate-limiting to block brute-force and replay attacks.

10. Data Retention & Anonymization Schedule

How long we retain your information and statutory retention mandates.

We retain personal data only for as long as is necessary to fulfill the operational purposes for which it was gathered, or to comply with statutory legal, accounting, or regulatory requirements:

  • Active Account Profiles: Retained for the active lifetime of your registration on Nafex Hub.
  • Tax & Invoicing Ledgers: In strict compliance with the Ghana Revenue Authority (GRA) statutory obligations and the Companies Act, 2019, transaction logs, electronic receipts, tax summaries, and completed order archives are retained for a mandatory minimum period of six (6) years.
  • Dispute Records & Evidentiary Proof: Maintained for twenty-four (24) months after dispute resolution to handle legal reviews, chargeback appeals, or formal law enforcement requests.
  • Temporary Delivery OTPs: Automatically invalidated upon successful delivery or purged 48 hours post-expiration.

11. Your Statutory Rights under Act 843 & GDPR

Your legal rights to access, export, rectify, object, and erase your personal data.

Under Part V (Sections 32 through 40) of the Data Protection Act, 2012 (Act 843) and international privacy standards, you enjoy the following enforceable rights:

Right of Access (Act 843 §32)You may request formal confirmation and a copy of all personal records we hold concerning you.
Right to Rectification (Act 843 §33)You have the right to demand the immediate correction of inaccurate, misleading, or outdated personal information.
Right to Erasure / Anonymization (Act 843 §33)You may request the deletion or irreversible anonymization of your personal data when it is no longer required for statutory or contractual operations.
Right to Object & Restrict (Act 843 §34)You may object to the processing of personal data for direct marketing or processing likely to cause unwarranted damage or distress.

To exercise your statutory rights, you may submit a written notice to privacy@nafexhub.com. We will respond within twenty-one (21) business days as stipulated by Act 843.

12. Requesting Your Data or Erasure

How to obtain a copy of your personal records or ask for your account to be erased.

To receive a copy of your personal data, or to ask for your account to be erased, write to privacy@nafexhub.com from the email address on your account. Records the law requires us to keep, such as completed payment records, are retained for the period the law sets.

13. Cookies & Browser Telemetry

How cookies, local storage, and tracking tokens are utilized.

Nafex Hub utilizes cookies, web beacons, and local storage tokens to deliver a responsive, secure session experience:

  • Strictly Necessary Cookies: Essential for authenticating session JWTs, maintaining your shopping cart across browsing sessions, and CSRF attack mitigation.
  • Operational & Functional Preferences: Preserving your language preferences, currency view (GHS), and active delivery region selections.
  • Analytical & Diagnostic Telemetry: Aggregated, non-identifying measurements of server response times, load balancing efficiency, and UI interaction heatmaps.

You may adjust your browser settings to reject cookies; however, essential features including authentication, shopping cart persistence, and escrow payment authorization may fail to function correctly.

14. Cross-Border Transfers & Trade Connect

Protection standards for cross-border sourcing within ECOWAS and globally.

Through our Nafex Trade Connect B2B portal, buyers may initiate Requests for Quotation (RFQs) and source wholesale merchandise from international and regional suppliers across West Africa and overseas manufacturing hubs.

Pursuant to Sections 45 through 50 of the Data Protection Act (Act 843), personal data transferred across borders is safeguarded through standard contractual clauses ensuring that foreign recipients adhere to data protection standards substantially equivalent to Act 843. Supplier communications remain encrypted and indexed solely for transaction fulfillment and customs declaration records.

15. Policy Revisions & Regulatory Notification

How we notify users when statutory or operational updates occur.

We periodically review and enhance this Privacy Policy to mirror technological updates, workflow refinements, and statutory amendments enacted by the Parliament of Ghana or the Data Protection Commission (DPC).

When material modifications are made, we will provide at least fourteen (14) calendar days of advance notice via registered email notifications or prominent platform banners before the revised terms become effective.

16. Contact Channels & Supervisory Authority

Official contact information for our DPO and the Ghana Data Protection Commission.

For any inquiries, requests to exercise your statutory rights, or compliance concerns, please contact our Data Protection Officer directly:

Nafex Hub Data Protection Officer

Email: privacy@nafexhub.com

Support: nafexgroupltd@gmail.com

Headquarters: Accra, Republic of Ghana

Statutory Supervisory Authority

Data Protection Commission (DPC), Ghana

Website: www.dataprotection.org.gh

Location: East Legon, Accra, Ghana