Privacy Policy — Transparent Turtle

1. Information We Collect

We collect information you provide directly, including:

Review submissions: Name and phone number (used for display and to prevent duplicate reviews).
Scam reports: Phone numbers, descriptions, and optionally your contact details.
Business claims: Owner name, email, phone, and uploaded verification documents.
Business owner accounts: Email address and encrypted password.
Third-party verification data: We use third-party financial services (such as Paystack) to resolve and verify the registered account names associated with reported phone numbers. This is done solely to ensure the accuracy of information in our public scam database and is processed under the legitimate interest basis of fraud prevention as recognised under the Ghana Data Protection Act, 2012 (Act 843).

2. How We Use Your Information

To display business reviews and scam reports on the public directory.
To verify business ownership claims and notify you of claim status.
To process subscription payments via Paystack.
To send transactional emails (account notifications, billing receipts, security alerts).
To detect and prevent abuse of the platform.
To resolve and display account names associated with reported numbers for fraud prevention purposes.

3. Data Sharing

We do not sell your personal information. We share data only with:

Supabase — our database and storage provider.
Paystack — for payment processing and account name verification (they receive your payment details directly).
Resend — our transactional email provider.
Law enforcement when required by Ghanaian law.

4. Phone Numbers and Public Visibility

Phone numbers associated with scam reports are displayed publicly to warn other users. Where available, the registered account name associated with a reported number is retrieved from third-party payment processors and displayed alongside the report to aid identification. This name reflects the official account holder on record with the relevant financial institution and is not a judgement of guilt by Transparent Turtle.

If you believe a phone number or associated name has been incorrectly reported, you may submit a formal Dispute Request. See Section 10 (Right to Rectification) for details.

5. Data Retention

Reviews and scam reports are retained indefinitely to serve the platform's public safety purpose. Business owner account data is retained while the account is active and for a reasonable period thereafter. Data that is successfully disputed under Section 10 will be corrected or removed within 7 business days of the dispute being upheld.

6. Security

We use industry-standard security practices including encrypted passwords, HTTPS, and access-controlled databases. No system is completely secure; we encourage you to use strong, unique passwords.

7. Your Rights Under Act 843

Under the Ghana Data Protection Act, 2012 (Act 843), you have the right to:

Request access to personal data we hold about you.
Request correction of inaccurate personal data.
Request deletion of your personal data, subject to our public safety obligations.
Object to the processing of your data where we rely on legitimate interest as our legal basis.

To exercise any of these rights, contact us at privacy@transparentturtle.com. Note that some data (such as verified scam reports) may be retained for public safety even after a deletion request, consistent with Act 843.

8. Cookies

We use session cookies for authentication purposes only. We do not use tracking or advertising cookies.

9. Contact

Privacy enquiries: privacy@transparentturtle.com

10. Right to Rectification — Dispute Procedure

If you believe your name or phone number has been incorrectly listed in a scam report, you have the right to submit a formal Dispute Request. This right is distinct from a business review and applies specifically to fact-based scam report data.

To raise a dispute, contact us at disputes@transparentturtle.com with:

A copy of a government-issued ID matching the name on the report.
The specific phone number or listing in question.
A written explanation of why the report is factually incorrect.

We will acknowledge your request within 2 business days and resolve it within 7 business days. Where a dispute is upheld, the relevant data will be corrected or removed. This procedure is provided in compliance with the right to rectification under the Ghana Data Protection Act, 2012 (Act 843).