ICCKNet
Privacy Policy
Last updated: 26 October 2026
ICCKNet ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our platform at icckjobs.com and its subdomains.
1. Controller and Contact Details
ICCKNet operates the platform at icckjobs.com and its associated tenant subdomains.
| [email protected] |
2. Personal Data We Collect
2.1 Information You Provide to Us
| Category | Data Collected | Purpose |
|---|---|---|
| Organization Registration | Organization name, admin email, admin phone number | To create and manage your organization's account |
| Support & Communication | Email, phone, messages | To respond to inquiries and provide support |
| Payment Information | Limited: payment transaction reference from ICCKPay | Payment processing (not stored on our servers) |
| Push Notification Data | Browser push subscription tokens, where you opt in | Delivering dashboard alerts you've enabled |
2.2 Cookies and Similar Technologies
We use strictly necessary cookies to operate the platform: session cookies that keep you logged in, and CSRF (cross-site request forgery) tokens that protect your account from malicious requests. These are required for the service to function and are not used for advertising or cross-site tracking. We do not currently use analytics or advertising cookies on the platform. Our Cookie Policy lists each cookie, what it does and how long it lasts.
2.3 Customer Data Collected via Tenant Systems
When you use ICCKNet to provide Wi-Fi hotspot or PPPoE services to your own customers, your organization may collect:
| Data Type | Examples | Purpose |
|---|---|---|
| Customer Identifiers | Name, phone number, email | Voucher delivery and communication |
| Transaction Records | Voucher purchases, payment confirmations | Order fulfillment and record-keeping |
| Session Data | Device MAC addresses, IP addresses, connection timestamps | Network management and analytics |
| Usage Data | Data volume, session duration | Service delivery and billing |
Important: this customer data is controlled by your organization (the data controller). Each organization's data lives in its own isolated database. ICCKNet acts as a data processor and does not access, use, or share this data except as necessary to provide the service.
3. Legal Basis for Processing (Ghana Data Protection Act, 2012)
We process personal data based on the following legal grounds under Act 843:
| Legal Basis | When Applied |
|---|---|
| Consent | When you voluntarily provide information to create an account |
| Contractual Necessity | To perform our obligations under our Terms of Service |
| Legitimate Interest | To maintain, improve, and secure our services |
| Legal Obligation | To comply with applicable laws and regulations |
4. How We Use Your Personal Data
| Purpose | Legal Basis |
|---|---|
| Service Delivery | Contractual necessity |
| Account Management | Contractual necessity |
| Customer Support | Legitimate interest / Consent |
| Security & Fraud Prevention | Legitimate interest / Legal obligation |
| Service Improvement | Legitimate interest |
| Legal Compliance | Legal obligation |
5. Automated Decision-Making and Profiling
Our AI Insights feature computes fraud-risk signals and outage-risk flags from an organization's own operational data (e.g. repeated failed payments from the same phone number, a router's health trending downward). These are deterministic calculations over real data, presented to your organization's admins as a signal to review, not a fully automated decision that denies you service, access, or a benefit without human review. Under the Ghana Data Protection Act, 2012, you have the right to object to solely automated decision-making that produces legal or similarly significant effects; contact us using the details in Section 17 if you believe a decision affecting you was made this way.
6. Data Sharing and Disclosure
6.1 Third-Party Processors
| Third Party | Purpose |
|---|---|
| ICCKPay, with Paystack, Hubtel and SeevPlus | Payment processing and payouts |
| Arkesel, Twilio, Africa's Talking | SMS delivery |
| WhatsApp Business Platform (Meta) | WhatsApp notifications, where enabled |
| Our email provider (SMTP relay) | Transactional email delivery |
| Cloudflare | Content delivery network and reverse proxy for our website and platform |
| Our VPS hosting provider | Application and database hosting |
If we add or change a subprocessor with access to your organization's data, we will give reasonable advance notice (e.g. via email or a dashboard notice) before the change takes effect.
6.2 Data Retention and Deletion Requests
For customer data collected through your organization's tenant system:
| Party | Responsibility |
|---|---|
| ICCKNet | Provides tools for data management |
| Your Organization (Data Controller) | Responsible for responding to customer data requests, including access, correction, deletion, and portability requests |
Customer deletion requests should be submitted to the organization that provided the Wi-Fi or internet service.
6.3 Data Isolation
- Tenant data is strictly isolated per organization, in a separate database per organization
- Data is not shared across organizations
- ICCKNet does not sell or rent personal data
6.4 Data Processing Agreements
If your organization needs a signed Data Processing Agreement (DPA) formalizing ICCKNet's role as processor for your customer data (for your own compliance records or a customer's due-diligence request), contact us via the details in Section 17 (Contact Us) and we will provide one.
7. Data Breach Notification
If we become aware of a security incident that compromises personal data we control, we will notify the Ghana Data Protection Commission and affected individuals without undue delay, as required under the Ghana Data Protection Act, 2012. Where a breach affects data within your organization's own isolated database, we will notify your organization promptly so you can meet your own notification obligations to your customers and, where applicable, the Commission.
8. International Data Transfers
Our infrastructure and some third-party processors listed above may be located outside Ghana. Where personal data is transferred internationally, we rely on:
- Standard Contractual Clauses (SCCs), where applicable
- Data Processing Agreements (DPAs) with our processors
- Adequacy decisions, where applicable
9. Data Security Measures
| Security Type | Measures |
|---|---|
| Technical | Encryption in transit (TLS), firewalls, per-tenant database isolation, access controls |
| Organizational | Data minimization, access restrictions, staff training |
| Procedural | Ongoing security review, incident response process |
10. Data Retention Periods
| Data Type | Retention Period |
|---|---|
| Account Information | For as long as your account remains active |
| Transaction Records | 6 years (Ghana tax law requirement) |
| Session & Network Logs | Up to 12 months for security and analytics |
| Customer Data | As determined by your organization's own policies |
11. Your Rights Under the Ghana Data Protection Act, 2012
| Right | Description |
|---|---|
| Right to Access | Request a copy of your personal data |
| Right to Correction | Request correction of inaccurate data |
| Right to Deletion | Request deletion of your personal data |
| Right to Restrict Processing | Request restriction of processing |
| Right to Object | Object to processing, including direct marketing and automated decision-making |
| Right to Data Portability | Request transfer of your data |
| Right to Opt Out of Marketing | Every promotional SMS/email includes an opt-out method; transactional messages (e.g. voucher codes, OTP codes, invoice reminders) are not promotional and can't be opted out of while your account is active |
How to Exercise Your Rights
- For your organization's own data: contact us via the details in Section 17 (Contact Us)
- For customer data: contact the organization that provided your Wi-Fi or internet service
12. Law Enforcement and Government Requests
We may disclose personal data if required to do so by a valid court order, subpoena, or other lawful request from a Ghanaian law enforcement or regulatory authority. Where the data requested belongs to a specific organization's isolated tenant database, our practice is to direct the request to that organization (the data controller) wherever legally permitted, since they are best placed to respond. Where we are legally required to respond directly, we will notify the affected organization unless we are prohibited by law from doing so (for example, a court-ordered non-disclosure requirement). We do not voluntarily disclose personal data to any government authority absent a legal requirement to do so.
13. Children's Privacy
We do not knowingly collect personal data from children under the age of 13. If you believe we have collected data from a child, please contact us immediately.
14. Changes to This Policy
We may update this policy from time to time. We will notify you of material changes by:
- Posting the updated policy on our website
- Sending an email notification, where applicable
- Displaying a notice in your dashboard
15. Complaints and Regulatory Oversight
If you believe your data protection rights have been violated, you may lodge a complaint with:
Ghana Data Protection Commission
Website: dataprotection.org.gh
16. Governing Law
This Privacy Policy is governed by and construed in accordance with:
- The Ghana Data Protection Act, 2012 (Act 843)
- The ECOWAS Supplementary Act on Data Protection
- Any other applicable laws of the Republic of Ghana
17. Contact Us
| Website | icckjobs.com |
|---|---|
| [email protected] |