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VIEW REPORTSPrivacy Policy - ZEN Loyalty Program (MyZEN Rewards)
Introduction
ZEN Petroleum Limited is committed to protecting your personal data. This Privacy Policy describes how we collect, use, share, and store information when you participate in the ZEN Loyalty Program or use our digital platforms.
INFORMATION WE COLLECT
Personal Information
- First Name
- Last Name
- Mobile number
- Date of birth
- Ghana Card Number (Optional) - collected solely for the purpose of identity verification and fraud prevention; ZEN will not use your Ghana Card Number for any other purpose without your separate consent
- Email Address (Optional)
- Vehicle details (Optional)
- Occupation/Industry (Optional)
- Customer Type (Optional)
Transaction Information
- Fuel purchases
- Points earned and redeemed
- Points gifted and points received (subject to the gifting conditions in the Terms & Conditions)
- Retail outlet visited
Technical Information
- Device identifiers
- App performance data
- IP address
- Cookies and usage analytics
HOW WE USE YOUR INFORMATION
- Administer and operate the loyalty program
- Award and redeem points
- Personalise offers and promotions
- Improve App, web, and customer experience
- Detect and prevent fraud
- Payment method (masked; no card details stored)
- Comply with legal obligations
SHARING OF INFORMATION
We may share data with:
- Capillary Technologies DMCC (Technology Partner and data processor) for system operation, data hosting, and analytics - your data may be transferred to and stored on servers located outside Ghana; see Section 7A below for further information on cross-border transfers
- Service providers performing analytics, SMS, customer support
- Regulators if required by law
- All third-party service providers are contractually bound to process your data only on ZEN’s instructions and to maintain appropriate confidentiality and security measures in accordance with the GDP Act.
DATA SECURITY
We implement technical and administrative measures to protect your data, including:
- Encryption
- Access controls
- Regular security audits
- Secure cloud hosting
YOUR RIGHTS UNDER THE GDP ACT
You may request to:
- Access your data
- Correct inaccurate personal information
- Delete your data (subject to legal/fraud controls)
- Opt out of marketing messages
- Withdraw consent at any time
- Lodge a complaint with the DPC if you believe your rights have been infringed
- Object to the processing of your personal data
- Object to further processing of your personal data
To exercise any of these rights, please contact ZEN’s DPS using the details in Section 10 below.
DATA RETENTION
Cross-Border Data Transfers
ZEN may transfer your personal data to countries outside Ghana for the purposes described in this Policy, including to Capillary in the United Arab Emirates. The GDP Act requires a data controller to ensure that a data processor not domiciled in Ghana complies with the relevant laws of Ghana. ZEN has implemented a data processing agreement with Capillary that includes security measures, confidentiality obligations, and restrictions on further processing consistent with the GDP Act. By using the Program, you acknowledge and consent to the transfer of your personal data to Capillary in the UAE for the purposes set out herein. If you wish to obtain further details about the safeguards in place, please contact the DPS.
Security Breach Notification
In the event of a security breach involving your personal data, ZEN will notify you and the DPC in accordance with the GDP Act.
CHILDREN'S PRIVACY
The Program is not intended for individuals under 18 years. The GDP Act prohibits the processing of personal data relating to a child under parental control, except where specific exemptions apply. ZEN does not knowingly collect personal data from children. If we become aware that we have collected personal data from a person under 18 years, we will take steps to delete that information promptly. If you believe that a child under 18 years has provided personal data to ZEN, please contact our DPS immediately.
UPDATES TO THIS POLICY
Changes will be communicated through our app, website, or SMS.
CONTACT US
ZEN Petroleum Limited
Data Protection Supervisors (DPS)
Name: Confidence Hommey / Katherine Osei
Email: dps@zenpetroleum.com
Phone: 0593834754 / 0593799075
Address: 13 Patrice Lumumba Road,
Airport Residential Area,
P.O. Box CT 3695, Cantonments,
Accra, Ghana
You may also lodge a complaint with the DPC: Data Protection Commission, No. 12 Starlets '91 Road, Accra, Ghana; Email: info@dataprotection.org.gh; Website: www.dataprotection.org.gh.
Cross-Border Data Transfers
Customer Consent Clause (Compliant with the GDP Act)
By enrolling in the ZEN Loyalty Program (MyZEN Rewards) or using any ZEN digital platform, I hereby acknowledge and provide my freely given, specific, informed, and unambiguous consent to the following, in accordance with the GDP Act
1. Consent to the Collection and Processing of Personal Data
I consent to ZEN Petroleum Limited (“ZEN”), a registered Data Controller under the GDP Act, collecting and processing my personal data for specific, explicit, and lawful purposes related to the operation and improvement of the ZEN Loyalty Program, including customer identification, account management, points accrual and redemption, fraud prevention, identity verification (including through my Ghana Card number, if provided), and service communications.
I understand that the GDP Act requires data controllers to collect personal data for a specific, explicit, and lawful purpose.
2. Consent to Data Sharing with Registered Processors
I understand and consent that ZEN may share my personal data with verified data processors, including Capillary, solely for delivering loyalty services, analytics, system integrations, and customer engagement. I acknowledge that this involves the transfer of my personal data to servers located outside Ghana. Under the GDP Act, data processors may only process personal data on documented instructions from the data controller and under conditions ensuring confidentiality and appropriate security measures.ZEN has entered into a data processing agreement with Capillary that includes such safeguards, and the GDP Act requires ZEN to ensure that Capillary complies with the relevant laws of Ghana.
3. Service Communications and Consent to Receive Marketing Communications
ZEN will send you operational and service communications that are necessary to administer your account and your participation in the Program, including:
- Loyalty program updates
- Points balances and expiry alerts
- Service announcements
- Surveys relating to your experience of the Program or ZEN’s products and services, used solely to maintain and improve service quality (excluding any survey that itself contains or is used to deliver advertising or marketing material, which is treated as a marketing communication below)
These service communications are necessary for the operation of the Program and do not constitute direct marketing. They will continue to be sent to you even if you opt out of receiving promotional and marketing communications under this clause.
In addition, I expressly consent to receive promotional and marketing communications from ZEN via SMS, email, mobile app notifications, and other digital channels regarding:
- Rewards, offers, and promotions
- Surveys or research used to deliver or support advertising or promotional material (as opposed to the service-quality surveys described above)
Ghanaian law requires consent for direct marketing, and data subjects must be able to opt out of promotional and marketing communications at any time. This does not affect the service communications described above, which are necessary for the operation of the Program and do not constitute advertising or marketing material.
4. Right to Withdraw Consent & Object to Processing
I understand that I may withdraw my consent or object to the processing of my personal data at any time, in whole or in part, by following the opt‑out instructions provided or by contacting ZEN’s DPS.
Under the GDP Act, data subjects have the right to object, correct, access, and request deletion of their personal data, subject to legal limitations.
5. Acknowledgement of Transparency Requirements
I acknowledge that ZEN has informed me of:
- The purpose(s) of data collection
- The lawful basis for processing
- The categories of data processed
- Any third parties involved in processing
- My rights under the GDP Act
6. Security and Cross-Border Transfer Consent
I consent to ZEN implementing appropriate technical and organizational measures to secure my data in compliance with the GDP Act. I also consent to the transfer of my personal data outside Ghana, including to Capillary in the United Arab Emirates, in accordance with the GDP Act and the safeguards described in the Privacy Policy. I understand that I may request further information about these safeguards from ZEN’s DPS.
7. Acceptance
By clicking “Agree,” submitting my registration, or using the ZEN Loyalty Program, I confirm that I understand and voluntarily consent to the data processing and communication practices described above, in compliance with the GDP Act.
