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DESIGNED WITH GHANA DATA PROTECTION ACT, 2012 (ACT 843) CONSIDERATIONS

Privacy & Personal Data Protection Framework

Draft Framework • Status: Pending Formal Legal Review • Target Controller: EzyTravels Ghana Limited

Legal Review Status: This privacy documentation represents an engineering baseline structured around the core principles of the Ghana Data Protection Act, 2012 (Act 843). Formal statutory certification and Data Protection Commission (DPC) registration will be finalized upon corporate legal cutover.

1. Overview & Commitment to Your Privacy

EzyTravels Ghana Limited (“EzyTravels”, “we”, “our”, or “us”) is designed to protect passenger personal information in alignment with the Ghana Data Protection Act, 2012 (Act 843).

This policy explains how passenger data will be collected, stored, processed, and safeguarded when reserving intercity bus tickets, creating an account, booking through station agents, or using our mobile clients.

2. Information We Collect

To deliver transport booking and passenger manifest services, we collect:

  • Passenger Identity Data: Full legal name, Ghana Card (NIA number) or passport number (where required by carriers), gender, and date of birth.
  • Contact Information: Active Ghanaian mobile phone number (for SMS ticket dispatch and USSD Mobile Money prompts) and email address.
  • Journey & Itinerary Details: Departure city, destination city, travel date, seat selection, bus operator (STC, VIP, OA), and digital boarding barcode.
  • Financial Transaction Records: Mobile Money network provider (MTN, Telecel, AT), masked account identifier, transaction reference, and double-entry ledger entries. Note: EzyTravels never stores Mobile Money PINs or full bank payment card CVVs.

3. Purpose & Legal Basis for Processing

Under Act 843, we process your personal data under the following legal bases:

Contractual NecessityTo issue your bus reservation, process seat concurrency locks, and transmit passenger manifests to licensed bus operators.
Legal ObligationCompliance with Ghana National Road Safety Authority guidelines and emergency transit manifest regulations.
Legitimate InterestsPlatform security, double-entry financial reconciliation, fraud prevention, and ticket barcode authenticity verification.

4. Data Sharing & Third-Party Processors

We only share passenger data strictly as required to fulfill travel services:

  • Licensed Bus Operators (STC, VIP Jeoun, OA Travel, VVIP): Provided with official departure manifests containing passenger names, phone numbers, and assigned seat numbers for conductor boarding.
  • Payment Processors & Gateways (Hubtel Ghana / Mobile Money): Provided with telephone numbers, payment amounts, and order references to process automated USSD billing.
  • SMS & Email Gateways: Provided with recipient phone numbers and emails solely for instant delivery of digital tickets and schedule alerts.

5. Technical & Organizational Security Measures

EzyTravels employs enterprise-grade defensive architecture to protect personal data:

  • Encryption in Transit: All web and mobile communications enforce TLS 1.3 with strict HTTP Strict Transport Security (HSTS).
  • Encryption at Rest: Supabase PostgreSQL databases and backup snapshots are encrypted with AES-256.
  • Cryptographic Digital Signatures: Boarding barcodes use Ed25519 asymmetric cryptography with managed key IDs to prevent ticket forgery.
  • Zero-Trust Cloudflare Hyperdrive: Database queries route over private encrypted connections with prepared parameterized SQL queries to prevent SQL injection.

6. Your Rights Under Ghana Act 843

As a data subject under Ghanaian law, you possess enforceable rights:

  • Right of Access: You may request a copy of all personal records and travel bookings associated with your account.
  • Right to Rectification: You may update or correct inaccurate passenger or contact details via your Customer Account Portal.
  • Right to Erasure: You may request the deletion of your account and saved passenger profiles, subject to statutory financial retention requirements.
  • Right to Object: You may opt out of marketing communications at any time.

7. Data Protection & Privacy Point of Contact

To exercise data protection rights, request profile erasure, or raise inquiries regarding personal data processing, please contact the platform data privacy desk:

Designated Privacy Contact: Data Protection Desk (Interim Staging Representative)
Inquiry Email: privacy@ezytravels.com
Operating Address: EzyTravels Ghana, Accra Central HQ, Greater Accra Region, Ghana
* Statutory DPO registration with the Ghana Data Protection Commission will be finalized upon live commercial cutover.