1. Introduction and Scope

SmartMediaGH ("we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our digital media platform, including our website, mobile applications, live TV streaming services, radio broadcasting, and all related content and services.

This policy complies with Ghana's Data Protection Act, 2012 (Act 843) and other applicable privacy laws. By using our services, you consent to the collection and use of your information as described in this policy.

2. Information We Collect

We collect various types of information to provide and improve our services:

2.1 Personal Information

• Account Information: Name, email address, phone number, date of birth, and password when you create an account
• Profile Information: Profile pictures, preferences, viewing history, and favorite content
• Contact Information: Address, phone numbers, and emergency contact details
• Payment Information: Billing address, payment method details, and transaction history
• Communication Data: Messages, comments, reviews, and feedback you provide

2.2 Technical Information

• Device Information: Device type, operating system, browser type, and unique device identifiers
• Usage Data: Pages visited, content viewed, time spent on platform, and interaction patterns
• Location Data: General location information (city/country level) for content personalization
• Network Information: IP address, internet service provider, and connection type
• Performance Data: Streaming quality, buffering times, and technical issues

2.3 Automatically Collected Information

• Cookies and Similar Technologies: Session cookies, persistent cookies, and local storage data
• Analytics Data: User behavior patterns, content preferences, and platform performance metrics
• Log Files: Server logs, error reports, and system performance data

3. How We Use Your Information

We use the collected information for the following purposes:

• Service Provision: To provide and maintain our digital media services, including live TV streaming, radio broadcasting, and content delivery
• Account Management: To create and manage your account, process payments, and provide customer support
• Content Personalization: To recommend relevant content, shows, and programming based on your preferences and viewing history
• Platform Improvement: To analyze usage patterns, improve our services, and develop new features
• Communication: To send you updates, newsletters, promotional offers, and important service notifications
• Legal Compliance: To comply with applicable laws, regulations, and legal processes
• Security: To protect against fraud, unauthorized access, and other security threats
• Research and Analytics: To conduct research, analyze trends, and improve user experience

4. Information Sharing and Disclosure

We may share your information in the following circumstances:

4.1 Service Providers

• Content Delivery Networks: To ensure reliable streaming and content delivery
• Payment Processors: To process payments and manage billing
• Analytics Providers: To analyze platform usage and improve services
• Cloud Storage Providers: To securely store and backup data
• Customer Support Services: To provide technical support and assistance

4.2 Legal Requirements

• To comply with Ghanaian laws and regulations
• To respond to legal requests and court orders
• To protect our rights, property, and safety
• To investigate and prevent fraud or illegal activities

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.

4.4 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

5. Data Security and Protection

We implement comprehensive security measures to protect your personal information:

• Encryption: All data is encrypted in transit and at rest using industry-standard protocols
• Access Controls: Strict access controls and authentication measures for all systems
• Regular Security Audits: Periodic security assessments and vulnerability testing
• Employee Training: Regular privacy and security training for all staff members
• Incident Response: Comprehensive incident response procedures for data breaches
• Data Backup: Regular backups with secure storage and recovery procedures
• Network Security: Firewalls, intrusion detection, and network monitoring
• Physical Security: Secure data centers with restricted access

6. Data Retention and Storage

We retain your personal information for as long as necessary to provide our services and fulfill the purposes outlined in this policy:

• Account Data: Retained while your account is active and for 2 years after deactivation
• Usage Data: Retained for 3 years for analytics and service improvement
• Payment Information: Retained for 7 years to comply with financial regulations
• Communication Data: Retained for 2 years for customer support purposes
• Technical Logs: Retained for 1 year for security and troubleshooting

Data is primarily stored in secure data centers located in Ghana, with backup storage in other secure locations as necessary for service delivery.

7. Your Privacy Rights

Under Ghana's Data Protection Act and other applicable laws, you have the following rights:

• Access Right: Request access to your personal information and receive a copy
• Correction Right: Request correction of inaccurate or incomplete information
• Deletion Right: Request deletion of your personal information (subject to legal requirements)
• Portability Right: Request transfer of your data to another service provider
• Restriction Right: Request restriction of processing in certain circumstances
• Objection Right: Object to processing of your data for specific purposes
• Withdrawal Right: Withdraw consent for data processing at any time
• Complaint Right: Lodge complaints with the Data Protection Commission

To exercise these rights, please contact us at privacy@smartmediagh.com or +233 24 455 5245.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

8.1 Types of Cookies We Use

• Essential Cookies: Required for basic platform functionality and security
• Performance Cookies: Help us understand how users interact with our platform
• Functional Cookies: Remember your preferences and settings
• Advertising Cookies: Deliver relevant advertisements and measure their effectiveness

8.2 Managing Cookies

You can control cookie settings through your browser preferences. However, disabling certain cookies may affect platform functionality.

9. Children's Privacy

Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected such information, we will take steps to delete it promptly.

For users aged 13-17, we require parental consent for certain features and collect only limited information necessary for service provision.

10. International Data Transfers

Your information may be transferred to and processed in countries other than Ghana. We ensure that such transfers comply with applicable data protection laws and implement appropriate safeguards, including:

• Standard contractual clauses approved by the Data Protection Commission
• Adequacy decisions by relevant authorities
• Other appropriate safeguards as required by law

11. Third-Party Services

Our platform may contain links to third-party websites and services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

12. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify the Data Protection Commission within 72 hours of becoming aware
• Notify affected users without undue delay
• Document all breaches and our response measures
• Take immediate steps to contain and mitigate the breach

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by:

• Posting the updated policy on our platform
• Sending email notifications to registered users
• Displaying prominent notices on our website

Your continued use of our services after such changes constitutes acceptance of the updated policy.

14. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Data Protection Officer: privacy@smartmediagh.com
• General Inquiries: info@smartmediagh.com
• Phone: +233 24 455 5245
• Address: Accra, Ghana
• Website: www.smartmediagh.com

You may also contact the Data Protection Commission of Ghana for complaints or inquiries about data protection matters.

15. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of Ghana, particularly the Data Protection Act, 2012 (Act 843). Any disputes arising from this policy will be resolved in accordance with Ghanaian law.

Last Updated: January 2024

Effective Date: January 1, 2024