Privacy Policy

JL Properties Ghana Limited (“JL Properties,” “we,” “us,” or “our”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, share, and safeguard your information when you visit our website (jlpropertiesgh.com), interact with our services, or engage with us in connection with our real estate development, sales, and estate management activities.

This policy has been drafted in compliance with the Data Protection Act, 2012 (Act 843) of the Republic of Ghana and applicable international data protection principles.

1. Information We Collect

1.1 Personal Information You Provide

We collect personal data that you voluntarily provide to us, including:

• Contact Details: Full name, email address, phone number, and mailing address.
• Property Enquiries: Property preferences, budget range, intended purchase timeline, and messages submitted through enquiry forms.
• Purchase & Transaction Data: Identification documents (e.g., national ID, passport), payment details, bank information, and records related to property reservation and sales agreements.
• Job Applications: Curriculum vitae (CV), cover letters, educational qualifications, work experience, references, and any other information submitted through our careers portal.
• Newsletter Subscriptions: Email address and communication preferences.
• Contact Form Submissions: Name, email, subject, and message content.
• Testimonials & Feedback: Reviews, ratings, and feedback you choose to share about our properties or services.

1.2 Information Collected Automatically

When you visit our Platform, we may automatically collect:

• Device Information: IP address, browser type and version, operating system, device type, and screen resolution.
• Usage Data: Pages visited, time spent on pages, click patterns, referring URLs, and navigation paths.
• Location Data: Approximate geographic location inferred from your IP address.
• Cookies & Tracking Technologies: Data collected through cookies, web beacons, pixels, and similar technologies (see Section 9 below).

1.3 Information from Third Parties

We may receive information about you from third-party sources, including real estate agents, referral partners, social media platforms (when you interact with our profiles), and analytics providers.

2. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Consent: When you opt in to receive newsletters, marketing communications, or submit enquiry forms.
• Contractual Necessity: When processing is required to fulfil a property purchase agreement, reservation, or service contract.
• Legal Obligation: When processing is necessary to comply with applicable laws, tax requirements, or regulatory obligations.
• Legitimate Interests: When processing is necessary for our legitimate business interests, such as improving our services, preventing fraud, and ensuring platform security, provided these interests do not override your fundamental rights.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Property Services: To process property enquiries, facilitate property viewings, manage reservations, and execute sale and purchase agreements.
• Communication: To respond to your questions, provide customer support, send appointment confirmations, and deliver transactional updates.
• Marketing: With your consent, to send newsletters, property alerts, promotional offers, blog updates, and event invitations.
• Recruitment: To assess and process job applications submitted through our Platform.
• Platform Improvement: To analyse usage patterns, diagnose technical issues, personalise your experience, and develop new features.
• Safety & Security: To protect against fraud, unauthorized transactions, and other illegal activities, and to ensure the security of our Platform.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
• Analytics & Reporting: To generate aggregated, anonymised insights about how users interact with our Platform and services.

4. Data Sharing & Disclosure

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

• Service Providers: Trusted third parties who assist with website hosting, email delivery, analytics, payment processing, and customer relationship management, bound by contractual obligations to protect your data.
• Legal Advisors & Conveyancers: Solicitors and conveyancing firms involved in property transactions, as necessary to complete your purchase.
• Financial Institutions: Banks and mortgage providers when processing property payments or verifying financial information.
• Government Authorities: Tax authorities, the Lands Commission, and other regulatory bodies as required by Ghanaian law.
• Business Partners: Subsidiaries and affiliated companies within the JL Properties group (e.g., Bentum Williams, Lindsay Hospitality) for coordinated service delivery.
• With Your Consent: Any other third party where you have provided explicit consent for such sharing.

5. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Property Transaction Records: Retained for a minimum of 10 years following the completion of a transaction, in accordance with Ghanaian tax and land registration requirements.
• Enquiry Data: Retained for up to 3 years from the date of your last interaction, unless you request earlier deletion.
• Newsletter Subscriptions: Retained until you unsubscribe or request removal.
• Job Applications: Retained for up to 12 months after the conclusion of the recruitment process, unless you consent to longer retention for future opportunities.
• Website Analytics Data: Retained in anonymised or aggregated form for up to 26 months.

6. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption of data in transit using SSL/TLS protocols.
• Encryption of sensitive data at rest.
• Access controls and authentication mechanisms to restrict data access to authorised personnel.
• Regular security assessments and vulnerability testing.
• Staff training on data protection responsibilities.
• Secure data backup and disaster recovery procedures.

While we take all reasonable precautions, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

7. Your Rights

Under the Data Protection Act, 2012 (Act 843) of Ghana, you have the following rights:

• Right of Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data where there is no compelling reason for continued processing.
• Right to Restrict Processing: You may request that we limit how we use your data in certain circumstances.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: You may request to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us using the details in Section 13 below. We will respond to your request within 30 days.

8. Children’s Privacy

Our Platform is not directed at children under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately and we will take steps to delete such information promptly.

9. Cookies & Tracking Technologies

9.1 What Are Cookies

Cookies are small text files stored on your device when you visit a website. They help us recognise your device, remember your preferences, and understand how you interact with our Platform.

9.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly (e.g., session management, security).
• Analytics Cookies: Help us understand how visitors interact with the Platform, which pages are most popular, and how users navigate (e.g., Google Analytics).
• Functional Cookies: Remember your preferences and settings to enhance your experience.
• Marketing Cookies: Used to deliver relevant advertisements and track campaign effectiveness across platforms.

9.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or alert you when a cookie is being set. However, disabling cookies may affect the functionality of certain parts of the Platform.

10. Third-Party Services

Our Platform may integrate or link to third-party services, including:

• Google Analytics — for website usage analysis.
• Tidio — for live chat support.
• YouTube — for embedded video content.
• Social Media Platforms — links to our Facebook, Instagram, LinkedIn, and X (Twitter) profiles.

These third-party services have their own privacy policies. We encourage you to review their policies before interacting with them. We are not responsible for the privacy practices of third-party websites or services.

11. International Data Transfers

Your data may be processed or stored on servers located outside of Ghana, including in jurisdictions where our service providers operate. Where such transfers occur, we ensure appropriate safeguards are in place, including standard contractual clauses or other lawful transfer mechanisms, to protect your data in accordance with the Data Protection Act, 2012 (Act 843).

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Last updated” date at the top of this page and, where appropriate, notify you by email or through a notice on our Platform.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact our Data Protection Officer:

• Email: info@jlpropertiesgh.com
• Phone: +233 (0)302 449 037 / +233 501 551 200
• Address: Number 1 Lindsay Park, Achimota, Accra, Ghana

You also have the right to lodge a complaint with the Data Protection Commission of Ghana if you believe your personal data has been processed in violation of applicable data protection laws.