Data Protection Act 843 (2012) Compliant

Privacy & Data Protection

Waltergates Ghana Limited — Commitment to transparency, security, and individual privacy rights

At Waltergates Ghana Limited, we are committed to protecting your privacy and ensuring lawful processing of personal data. This comprehensive policy outlines our practices in accordance with the Ghana Data Protection Act, 2012 (Act 843).

This Privacy Policy establishes the rules and commitments governing how Waltergates Ghana Limited collects, uses, stores, shares, secures, retains, and disposes of personal data. It is intended to support lawful and responsible processing of information relating to clients, prospective clients, website users, employees, applicants, contractors, suppliers, and other business contacts.

This policy applies across all business units, information systems, software platforms, development environments, communication channels, paper files, cloud services, and third-party arrangements used by or on behalf of Waltergates Ghana Limited.

Personal Data: information relating to an identified or identifiable natural person.

Sensitive Personal Data: special categories of information requiring enhanced protection, such as health, religious belief, ethnicity, biometric data, or criminal-related information, where applicable.

Data Subject: the individual to whom personal data relates.

Data Controller: the person or organisation that determines the purpose and means of processing personal data.

Data Processor: a person or service provider that processes personal data on behalf of a controller.

Processing: any activity involving personal data, including collection, recording, storage, retrieval, analysis, disclosure, transfer, deletion, or destruction.

Personal Data Breach: an actual or reasonably suspected event involving unauthorised access, disclosure, alteration, loss, destruction, or unavailability of personal data.

The company shall process personal data only where at least one lawful condition applies. Depending on the context, Waltergates Ghana Limited may rely on one or more of the following grounds:

• the data subject has provided clear and informed consent;

• processing is necessary to enter into, perform, or manage a contract;

• processing is required to comply with a legal or regulatory obligation;

• processing is necessary for legitimate business interests that are not overridden by the rights and freedoms of the data subject;

• processing is necessary to protect a vital interest or to perform a public or lawful function where applicable.

Sensitive personal data shall be processed only where strictly necessary, lawful, proportionate, and subject to enhanced safeguards, documented approvals, and restricted access.

Waltergates Ghana Limited recognises the rights of data subjects, subject to applicable legal conditions and exemptions. Individuals may request:

• confirmation of whether the company holds personal data about them; • access to the personal data and related information about the processing; • correction, completion, update, restriction, or deletion of inaccurate, excessive, irrelevant, or unlawfully held data; • objection to certain forms of processing, including direct marketing; • withdrawal of consent where processing relies on consent, without affecting prior lawful processing; • information about recipients or categories of recipients and, where applicable, transfer arrangements.

Requests shall be submitted through the company's designated privacy contact channel or other approved communication channel. The company shall verify identity where necessary, log the request, assess any applicable legal limitations, and respond within the timeframe required by law or within a reasonable documented period if the law does not specify a fixed deadline for the scenario concerned.

© 2026 Waltergates Ghana Limited. All rights reserved. This policy is effective as of February 2026.