Privacy Policy

1. Who We Are

Step Network is an Internet and technology services organisation. Step Network is responsible for determining the purposes and manner in which personal information is processed in connection with our services.

Step Network's privacy contact details are:

• Email: [email protected]
• Telephone: +233-548-988-114
• Website: https://snetgh.org

2. Personal Information We May Collect

Depending on the service or interaction involved, Step Network may collect and process:

• Identification and contact information, such as name, telephone number, email address and service or installation location.
• Account information, such as username, account identifiers, subscription or package information and authentication information.
• Payment and transaction information, such as amount paid, date and time, transaction reference, payment status, service purchased and information needed to reconcile a payment.
• Internet and network information, such as IP address, device or network identifiers, authentication events, connection date and time, session duration, data usage and access-point information, where applicable.
• Website and technical information, such as browser type, device type, operating system, pages visited and technical or diagnostic information, where applicable.
• Information provided when you contact us, make an enquiry, submit a complaint, request support or otherwise communicate with Step Network.

3. How We Collect Personal Information

We may collect personal information through our website and online forms; customer registration and account-management systems; registration or payment applications; Internet hotspot login or access portals; voucher or access systems; telephone, email and customer-support communications; service installation and subscription processes; payment and transaction records; and technical, network and security systems.

4. Why We Collect and Use Personal Information

Step Network processes personal information for purposes that are necessary, relevant and appropriate to the service or relationship involved.

• Registering and managing customer accounts.
• Providing Internet connectivity, hotspot access and related services.
• Authenticating users and managing access.
• Processing, confirming and reconciling payments.
• Providing customer service, technical support and responding to complaints.
• Monitoring and maintaining network performance, availability and security.
• Detecting and preventing fraud, abuse and unauthorised access.
• Communicating service, account, maintenance and security information.
• Meeting legal, regulatory, accounting and other lawful obligations.

5. Lawful Processing

Step Network will process personal information on a lawful basis. Depending on the circumstances, processing may be necessary for providing a service requested by the customer, managing a customer relationship, complying with a legal or regulatory obligation, protecting our systems and services, or where consent is required and has been obtained.

Where processing is based on consent, consent may be withdrawn where the law permits. Withdrawal does not affect processing that was lawfully carried out before withdrawal.

6. Customer Registration

When registering for Step Network services, customers may be required to provide information necessary to establish and manage an account, including name, telephone number, email address, location or address, account credentials, service/package information and payment or transaction information.

Where information is necessary for service provision, legal compliance or account administration, failure to provide required information may prevent Step Network from providing the requested service.

7. Registration and Payment Application

Step Network may use electronic registration and payment applications to allow customers to register for services, manage accounts, purchase services, make payments, receive service information or access Internet services.

Where a third-party payment provider processes a transaction, that provider may process information under its own applicable privacy terms. Step Network may retain transaction information necessary to confirm and reconcile the payment.

8. Internet Hotspot and Network Usage Information

When you use a Step Network Internet hotspot or other managed Internet service, technical information relating to the connection may be processed. This can include login or voucher information, device or network identifiers, IP address, connection times, session duration, data usage and access-point information.

Such information may be used for authentication, billing, network administration, security, troubleshooting, service management and compliance with applicable requirements.

9. Cookies and Similar Technologies

Our website or applications may use cookies and similar technologies where applicable. These may support website functionality, preferences, security, performance and, where implemented, analytics.

Where consent is required for particular cookies or tracking technologies, appropriate mechanisms will be provided. Users may control cookies through browser settings, although disabling some cookies may affect functionality.

10. Sharing and Disclosure of Personal Information

Step Network does not ordinarily sell customers' personal information. Personal information may be disclosed where reasonably necessary for legitimate service, business, legal, security or regulatory purposes.

• Payment and transaction service providers.
• Technology, hosting, network and maintenance providers.
• Professional advisers and authorised service providers.
• Regulatory authorities and law-enforcement authorities where legally required or permitted.
• Courts or other lawful authorities.
• Other authorised recipients where disclosure is permitted by law or necessary to provide the requested service.

11. Disclosure Required by Law

Step Network may disclose personal information where required or authorised by applicable law, court order, lawful regulatory request, law-enforcement requirement or other legally recognised process. Where legally permitted, we will seek to limit disclosure to information reasonably necessary for the relevant purpose.

12. International Data Transfers

Some technology, hosting, cloud, payment or service providers may process information outside Ghana. Where personal information is transferred or made accessible outside Ghana, Step Network will take reasonable steps to apply appropriate safeguards and ensure that the transfer is consistent with applicable data-protection requirements.

13. Data Security

Step Network takes reasonable technical and organisational measures to protect personal information against unauthorised access, unauthorised disclosure, loss, destruction, damage, unlawful processing and other security threats.

• Access controls and authentication mechanisms.
• Password and account protection.
• Network security controls and firewalls.
• System monitoring and maintenance.
• Administrative and confidentiality controls.
• Backup and recovery measures.
• Security updates and appropriate staff awareness.

14. Data Retention

Step Network will retain personal information only for as long as reasonably necessary for the purpose for which it was collected or where retention is required or permitted by law.

Retention periods may depend on the type of information, the customer relationship, accounting and financial requirements, legal and regulatory requirements, security needs, dispute resolution and operational requirements.

When information is no longer required, Step Network will take reasonable steps to securely delete, destroy, anonymise or otherwise dispose of it, subject to applicable retention requirements.

15. Accuracy of Personal Information

Step Network aims to keep personal information accurate, complete and reasonably up to date. Customers should notify us if their personal information changes or is inaccurate. Customers may request correction or rectification of inaccurate or incomplete information.

16. Data Subject Rights

Under the Data Protection Act, 2012 (Act 843), individuals have rights concerning their personal information, including rights to be informed, access personal information, request correction or rectification, object to certain processing and prevent processing in circumstances recognised by law. Other rights may apply under the Act.

17. How to Exercise Your Privacy Rights

Privacy requests, access requests, correction requests, objections and privacy complaints may be submitted using Step Network's official contact details:

• Email: [email protected]
• Telephone: +233-548-988-114
• Website: https://snetgh.org

We may need to verify the identity of a requester before releasing or changing personal information. Requests will be handled within a reasonable period and in accordance with applicable legal requirements.

18. Direct Marketing

Where Step Network sends promotional or marketing communications, we will do so in accordance with applicable law. Customers may request not to receive promotional communications.

Opting out of marketing communications will not necessarily stop essential service-related communications such as payment notices, account notices, security alerts, maintenance information or service interruption notifications.

19. Children and Minors

Step Network does not knowingly seek to collect unnecessary personal information from children. Where services are provided to minors or a minor's information is processed, we will take reasonable measures appropriate to the circumstances and applicable law.

20. Third-Party Websites and Services

Our website or applications may contain links to third-party websites, platforms or services. Step Network is not responsible for the privacy practices of independent third parties. Users should review the privacy policies of third-party services before providing personal information to them.

21. Confidentiality

Step Network will take reasonable steps to keep customer information confidential. Personal information will only be accessed, used or disclosed by authorised persons or service providers where reasonably necessary for legitimate service, technical, business, legal, regulatory or security purposes.

22. Personal Data Breaches

If Step Network becomes aware of a personal-data security incident or breach, we will take appropriate steps to investigate, contain and mitigate the incident, assess risks, protect affected systems and information, make notifications required by applicable law or regulatory requirements, and implement corrective and preventive measures.

23. Changes to This Privacy Policy

Step Network may update this Privacy Policy from time to time to reflect changes in services, technology, legal requirements, regulatory guidance or privacy practices. The updated version will be published on our website with a revised Last Updated date.

24. Questions, Complaints and Privacy Enquiries

If you have questions, concerns, requests or complaints about how Step Network handles personal information, please contact us at [email protected] or +233-548-988-114, or visit https://snetgh.org.

We encourage individuals to contact Step Network first so that we can investigate and address privacy concerns. Nothing in this Policy limits a data subject's right to seek assistance from or make a complaint to the Ghana Data Protection Commission or exercise any other lawful right.

25. Privacy Commitment

Step Network is committed to handling personal information responsibly, transparently and securely. We will seek to ensure that personal information is processed for appropriate purposes, is relevant and not excessive, is protected against unauthorised access and misuse, is kept reasonably accurate, and is retained only as necessary or as required by law.