PRIVACY POLICY

Introduction

Regarding our privacy policy, if you have any questions or concerns, please contact us via email on info@doxacapitaltd.com. You can also find the legislation online if you look for the General Data Protection Regulation ((EU) 2016/679) (GDPR).

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We hope however that if any issues do arise, you will speak to us first. 

We both do and will respect our privacy and protect your personal data and this Privacy Policy explains to you how we will do this, both when you visit our website (www.doxacapitaltd.com) and when you use our software applications.

We will comply with data protection laws and principles and so your data will be:

  • Used lawfully and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

What we will explain below is how we will collect and process your data, including that which you give to us as well as that which we correct. Before going any further, please understand that if you are under 18, we will not have any contact with you.

Doxa as a Data Controller

Under the law, we will act as a data controller once you visit our website (www.doxacapitaltd.com) and every time that you do. In this role, we are responsible for deciding how we hold and use personal information about you.  This means that it is important that you know who we are. Therefore, we have provided our full details below.

Company Name: Doxa Capital Limited

Email Address: info@doxacapitaltd.com

Physical Address:  No. 14 Pineapple Street, East Legon, Accra

Changes

We are always reviewing our Privacy Policy to keep it up to date. You can help us too as it is important that the personal data we hold about you is accurate and current. So, please let us know as soon as possible if your personal data changes during the course of your relationship with us. Just use the contact details provided above.

How Doxa Collects your Personal Information

Doxa collects personal information about you from the following sources:

Direct Interactions: This is information about you (including your identity, contact, financial, and marketing and communications data). You consent to give us information about you by filling the forms on our website or on other services sites (together with our sites); or by corresponding with us (i.e. by email or chat). It includes information that you provide when you register to use our site; subscribe to any of our services; search for a service; and when you report a problem with our services or any of our sites. If you contact us, we will keep a record of that correspondence.

Automated Technologies or Interactions: As you interact with our site, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.

Information we Receive from other Sources Including Third Parties and Publicly Available Sources:  Doxa will receive personal data about you from various third parties and public sources as set out below.

Technical Data:  From the following parties: (i) analytics providers, (ii) advertising networks, and (iii) search information providers.

Contact, financial and transaction data from providers of technical, payment and delivery services;

Identity and contact data from data brokers or aggregators; and

Identity and contact data from publicly available sources.

 

What Doxa Collects and How the Company Contains It

Doxa may collect, use, store and transfer different kinds of personal data about consumers. This includes the following:

  • Identity Data which includes first names, maiden names, last names, usernames or similar identifiers, marital statuses, titles, dates of birth and genders.
  • Contact Data which includes billing addresses, delivery addresses, email addresses and telephone numbers.
  • Financial Data which includes bank accounts and payment card details.
  • Transaction Data which includes details about customer payments, purchased products and services, and legal services provided by Doxa or proposed by us.
  • Technical Data which includes internet protocol (IP) addresses, login data, browser types and versions, time zone settings and locations, browser plug-in types and versions, operating systems and platforms, and other technology on the devices used to access our website.
  • Usage Data which includes details of your use of our website and services and your visits to our site including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
  • Profile Data which includes your username and password, interests, preferences, feedback and survey responses.
  • Marketing and Communications Data which includes your preferences in receiving marketing from Doxa and our third parties as well as your communication preferences.

 

To explain the terms that we use, personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We do not collect any Special Categories of Personal Data about you which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union memberships, information about your health, or generic and biometric data. Nor do we collect any information about criminal convictions and offences.

We are very clear above that this website and our business is not for anyone below the age of 18 years. If you are below this age, please log out now.

Third Parties

When you consent to provide us with your personal data, we will also ask you for your consent to share this data with third parties for the purposes we have set out in this policy.

Who are those third parties? They are External Third Parties who are service providers acting as processors based overseas who provide IT and system administration services.

They are also third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. We might want to acquire other businesses or merge with them. If a change like this occurs, then the new owners may use your personal data in the same way as we have set out in this privacy policy.

Rest assured though. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. This means that we do not let our third-party service providers use your personal data for their own purposes. They can only process your personal data for specified purposes and in accordance with our instructions.

How and for What Purposes Doxa Might Use Your Information

Doxa might use your personal data when the law allows us to. This can be for a number of reasons; but those which are most common are set out below.

  • Where you have consented before the processing.
  • Where the need arises to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of third parties), and your interests and fundamental rights do not override those interests.
  • Where the need to comply with a legal or regulatory obligation arises.

It is really important for you to understand that, in general, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. And remember, you are in charge and so you have the right to withdraw consent to marketing at any time by contacting us.

Concerning our purpose in all this, just have a look below at the description of the ways in which we plan to use your personal data, and which of the legal bases we rely on to do so, together with our legitimate interests are where appropriate. We are permitted to process your personal data for more than one lawful ground, and for this, we will look at the specific purpose for which we are using your data.  Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the subsequent table.

Why We Need Your Personal Data

Without your data, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case. So let us do what we need to do to get your contracts performed, and give us the details that we need now that you know how we keep them safe and what we need them for. Also remember to tell us about the changes.

Marketing Efforts

It should be kept in mind that we may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you—what we refer to as marketing.  We will not bombard you. We will rather send you marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-Party Marketing

We just do not do it. You can be sure that when you give us your personal data, we keep it personal. We will never share your personal data with any third party for marketing purposes.

Opting Out

You can ask us at any time to stop sending you marketing messages by contacting us.

Cookies

You are permitted to set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. But remember that if you want to look at everything on our website, you may find that you are restricted if you disable or refuse cookies.

Change of Purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will tell you and explain the legal basis of this. While we may process your personal data without your knowledge or consent, we will only do so in compliance with the above rules and where this is required or permitted by law.

International Transfers

Your personal data will not be transferred or stored outside the EEA or the country where you and your authorized users are located save that your personal data may be transferred to the United States of America. This is allowed because the United States has had an adequacy decision which has been made in accordance with GDPR Article 4.5. 

Security and Retention

We promise to store your information on secure services. However, you have your part to play too; and if we have given you a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. Please do not share your password with anyone.  On our part, we will use strict procedures and security features to try and prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. In addition to this, we have procedures to deal with any suspected personal data breach which include notifying you and any applicable regulator where the law says we must.

The law also requires us to do other things. For instance, we will keep basic information about our clients (including contact, identity, financial and transaction data) for six years after they cease being clients for tax, regulatory, and insurance purposes. We might anonymise your personal data so that it can no longer be associated with you for research or statistical purposes. We may use this information indefinitely without further notice to you.

Your Rights in Connection with Personal Information- Access, Correction, Erasure and Restriction

The law gives you the right to take certain actions. More specifically, you have the right to do the following:

  • Request access to your personal information: This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you: This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information: This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to it being processed (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restrictions of processing of your personal information: This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or for the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request the erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing.

No Fee Usually Required

You will not have to pay a fee to access your personal data or to exercise any of the other rights. But if your request is clearly unfounded, repetitive or excessive, we can ask you to pay or refuse to comply with our request.

What We May Require From You

Doxa may need to request specific information from you to help us to confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up your response.

Time Limit to Respond

We try our best to respond to all legitimate requests within 30 days. Occasionally, it might take us longer than that time if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.