Privacy Policy
Arova Digital Enterprise operates the Arova Digital Platform, a loyalty and customer relationship management system accessible at arovadigital.com. We are committed to protecting the personal data of every individual who interacts with our platform.
1. Introduction
i. Arova Digital Enterprise ("Arova", "we", "us", "our") operates the Arova Digital Platform, a loyalty and customer relationship management system accessible at arovadigital.com. We are committed to protecting the personal data of every individual who interacts with our platform, whether as a merchant, a customer, or a visitor to our website.
ii. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, how we protect it, and what rights you have over your data. It applies to all users of the Arova platform and website.
iii. By registering for or using our platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with how we handle your personal data, please do not use the platform.
iv. This Privacy Policy complies with the Data Protection Act 2012 (Act 843) of Ghana.
2. Who We Are — Contact Details
Arova Digital Enterprise is the data controller responsible for your personal data.
• Legal name: Arova Digital Enterprise
• Trading name: Arova Digital Platform
• Company registration number: BN020210126
• Email address: hello@arovadigital.com
• Website: arovadigital.com
• WhatsApp: +1 860 869 9899
3. What Personal Data We Collect
3.1 Data collected from merchants
When a business registers on the Arova platform, we collect:
- i. Full name of the account owner.
- ii. Business name and business registration details.
- iii. Email address and phone number.
- iv. Business category, country of operation, and currency.
- v. Billing information for paid subscription plans (processed by our payment partner — we do not store card details).
- vi. Login credentials (passwords are stored in encrypted form and never readable by Arova staff).
- vii. Business logo and branding assets if uploaded by the merchant.
- viii. Configuration settings chosen by the merchant (reward rates, rules, branch structure).
3.2 Data collected from customers (collected by merchants using our platform)
When merchants record transactions for their customers on the Arova platform, the following data is collected and stored:
- i. Customer phone number (primary account identifier).
- ii. Customer full name (if provided by the merchant).
- iii. Purchase amounts and transaction dates.
- iv. Loyalty points balance and full transaction history.
- v. Redemption history.
- vi. Visit frequency and lifetime spend with that merchant.
- vii. Custom fields configured by the merchant (e.g. email address, date of birth, if enabled).
3.3 Technical and usage data
When you use the Arova platform or website, we may automatically collect:
- i. IP address and device type.
- ii. Browser type and version.
- iii. Pages visited and time spent on the platform.
- iv. Login timestamps and session data.
- v. Error logs and system diagnostic data.
4. Why We Collect Your Data — Legal Basis
We collect and process personal data only for specific, legitimate purposes in accordance with the Data Protection Act 2012 (Act 843). The table below sets out each purpose and its legal basis:
| Purpose | Data used | Legal basis |
|---|---|---|
| Providing the loyalty platform service to merchants | Merchant account data, customer transaction data | Contract performance |
| Sending transactional SMS to customers (balance updates, redemption confirmations) | Customer phone number, points balance | Legitimate interest / consent at enrollment |
| Sending marketing SMS campaigns on paid plans | Customer phone number, purchase history | Explicit opt-in consent — required separately from enrollment |
| Billing and subscription management for merchants | Merchant billing data | Contract performance |
| Platform security, fraud detection, and audit trail | Usage data, transaction logs, all activity logs | Legitimate interest and legal obligation |
| Legal compliance and record keeping | All data as required by law | Legal obligation |
| Responding to customer support requests | Account data, transaction history | Contract performance / legitimate interest |
| Improving platform performance and features | Anonymized usage data | Legitimate interest |
6. How Long We Keep Your Data
We retain personal data only for as long as necessary for the purposes described in this policy or as required by Ghanaian law:
| Category of data | Retention period |
|---|---|
| Active merchant account data | Retained for the duration of the merchant's active subscription plus 2 years after account closure |
| Customer loyalty data (points, transactions, visit history) | Retained for as long as the merchant account is active, plus 1 year after the merchant closes their account |
| Transaction records and audit logs | 7 years — for legal, tax, and regulatory compliance |
| SMS delivery records and consent records | 5 years — required for NCA compliance |
| Billing records | 7 years — for tax compliance under the Revenue Administration Act 2016 |
| Website usage and technical data | 12 months, then permanently deleted |
| Data breach records | Retained indefinitely for regulatory accountability |
7. How We Protect Your Data
Arova implements technical and organizational security measures to protect personal data against unauthorized access, accidental loss, destruction, or disclosure, in accordance with the Cybersecurity Act 2020 (Act 1038) and the Data Protection Act 2012 (Act 843). Our security measures include:
i. Encryption of all data in transit using HTTPS/TLS protocols.
ii. Encryption of sensitive data at rest.
iii. Secure password hashing — passwords are never stored in readable form.
iv. Role-based access controls — Arova staff and merchant staff can only access data relevant to their assigned role.
v. Full audit logging of every platform action for security monitoring and fraud detection.
vi. Regular review of access permissions and system security.
vii. A documented data breach response procedure — see Section 9.
No system can guarantee absolute security. If you believe your account has been compromised, contact us immediately at hello@arovadigital.com.
8. Your Rights Under Ghana's Data Protection Act 2012 (Act 843)
You have the following rights in relation to your personal data held by Arova:
| Your right | What it means |
|---|---|
| Right of access | You may request a copy of the personal data we hold about you. We will respond within 21 days. |
| Right to correction | You may request that inaccurate, incomplete, or outdated personal data be corrected. |
| Right to object | You may object to processing your personal data where that processing causes or is likely to cause you unwarranted damage or distress. |
| Right to prevent direct marketing | You may opt out of marketing SMS at any time by replying STOP to any message. Your request will be processed within 24 hours. |
| Right to erasure | You may request deletion of personal data that we are not legally required to retain. We will respond within 21 days. |
| Right to lodge a complaint | If you are dissatisfied with how we have handled your data, you may lodge a complaint with the Data Protection Commission of Ghana at dataprotection.org.gh. |
9. Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, Arova will:
i. Notify the Data Protection Commission as soon as practicable — and in no case later than 72 hours — after becoming aware of the breach.
ii. Notify affected individuals directly where the breach poses a high risk to their rights and freedoms, without undue delay.
iii. Document the nature of the breach, the categories and approximate number of individuals affected, the categories and approximate volume of records affected, the likely consequences of the breach, and the measures taken or proposed to address the breach.
iv. Cooperate fully with the DPC in any investigation arising from the breach.
Arova maintains a Data Breach Response Plan that is reviewed annually and updated whenever material changes are made to our data processing activities.
10. SMS Communications
10.1 Transactional SMS
Arova sends transactional SMS messages as part of the loyalty service. These include balance updates after purchases, redemption confirmations, and account-related notifications. Transactional SMS is sent based on the customer's enrollment in the merchant's loyalty program and does not require a separate marketing consent.
Every transactional SMS includes opt-out instructions. Customers may reply STOP at any time to stop receiving all SMS from that merchant through Arova.
10.2 Marketing and campaign SMS
Marketing SMS campaigns — including promotional offers, win-back messages, seasonal promotions, and tier upgrade notifications — are sent only to customers who have given explicit opt-in consent to receive marketing communications from that specific merchant. This consent is separate from the enrollment consent and must be actively given by the customer.
Merchants are responsible for maintaining opt-in records for their customers. Arova provides technical controls to ensure that only opted-in customers are included in marketing campaigns.
All marketing SMS messages clearly identify the sending merchant and include unsubscribe instructions. Opt-out requests are honored immediately.
11. Cookies
The Arova website (arovadigital.com) uses cookies and similar technologies. A separate Cookie Policy will be published at arovadigital.com/cookies. You can manage cookie preferences through your browser settings at any time. Disabling certain cookies may affect website functionality.
12. Children's Privacy
The Arova platform is intended for use by businesses and adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If you believe that a minor has provided personal data to Arova, please contact us immediately at hello@arovadigital.com and we will take steps to delete that data.
13. Changes to This Privacy Policy
Arova may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or platform functionality. When we make material changes, we will notify registered merchants by email at least 14 days before the changes take effect and update the version number and effective date at the top of this document. The current version of this Privacy Policy is always available at arovadigital.com/privacy. Continued use of the platform after the updated policy takes effect constitutes your acceptance of the revised policy.
14. Governing Law
This Privacy Policy is governed by the laws of the Republic of Ghana, including the Data Protection Act 2012 (Act 843), the Electronic Transactions Act 2008 (Act 772), and the Cybersecurity Act 2020 (Act 1038).
15. How to Contact Us
For all data protection queries, access requests, complaints, or to exercise any right described in this policy:
Data Protection Supervisor
Arova Digital Enterprise
Email: hello@arovadigital.com
Website: arovadigital.com
WhatsApp: +1 860 869 9899
Data Protection Commission of Ghana: dataprotection.org.gh