Privacy Policy

1. Introduction

1.1 This Privacy Policy describes how personal data is collected, processed, stored, and protected in connection with the use of the EyeFocus mobile application (the “App”).

1.2 The App is developed and owned by Feyenally Sp. z o.o., a company duly incorporated under the laws of the Republic of Poland, with its registered office at ul. Stanisława Leszczyńskiego 4, 50-078 Wrocław, Poland (“Feyenally”).

1.3 AccessPlus Communications Limited, a company incorporated under the laws of the Republic of Ghana, with its registered office at 28 Djanie Ashie Road, East Legon, Accra, Ghana (“AccessPlus”), acts as the local implementation partner for the EyeFocus App in certain jurisdictions and may act as a Data Controller for limited personal data processed in connection with local program implementation, training, operational support, customer support, and program administration.

1.4 Feyenally may act as a Data Processor on behalf of AccessPlus in relation to limited Technical Data processing required for application maintenance, error monitoring, security monitoring, performance optimization, and technical support. Feyenally may also act as a Data Controller where required by law in relation to certain infrastructure, security, and platform-related processing activities.

1.5 The App has been designed and developed in accordance with the principles of privacy by design and data minimization as set out in Article 25 of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

1.6 Vision test results and other health-related data generated by the App are processed exclusively locally on the user’s device and are not transmitted to Feyenally, AccessPlus, or any external servers.

1.7 The App is a vision screening and informational tool only and does not provide medical diagnosis, medical advice, or medical treatment.

1.8 By downloading, installing, accessing, or using the App, the User confirms that they have read, understood, and agree to this Privacy Policy.

2. DEFINITIONS

For the purposes of this Privacy Policy, the following definitions apply:

2.1 “Personal Data” means any information relating to an identified or identifiable natural person.

2.2 “Processing” means any operation performed on Personal Data, whether or not by automated means, including collection, recording, storage, organization, structuring, use, disclosure, restriction, or deletion.

2.3 “Data Controller” means the entity that determines the purposes and means of processing Personal Data.

2.4 “Data Processor” means an entity that processes Personal Data on behalf of the Data Controller.

2.5 “Data Subject” means the individual whose Personal Data is processed.

2.6 “Consent” means any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes.

2.7 “Health Data” means Personal Data related to a person’s physical or mental health, including vision test results.

2.8 “Technical Data” means device information, application logs, crash reports, error logs, diagnostic information, and security-related data.

2.9 “App” means the EyeFocus mobile application.

2.10 “User” means any individual who installs, accesses, or uses the App.

2.11 “Device” means a smartphone, tablet, or other mobile device on which the App is installed.

2.12 “GDPR” means Regulation (EU) 2016/679.

3. ROLES AND RESPONSIBILITIES

3.1 Local Health Data

The User acts as the Data Controller in respect of Personal Data and Health Data stored locally on the User’s Device.

3.2 Technical Data

AccessPlus acts as the Data Controller for Technical Data processed for application functionality, maintenance, security, performance monitoring, and operational support.

3.3 Data Processing by Feyenally

Feyenally acts as a Data Processor on behalf of AccessPlus and processes Technical Data solely for the purpose of providing development, maintenance, hosting support (where applicable), security monitoring, troubleshooting, and technical support services.

3.4 No Access to Health Data

Feyenally and AccessPlus do not process, collect, store, transmit, or have access to Health Data or vision test results stored locally on the User’s Device.

3.5 Data Processing Agreement

Where Feyenally processes Technical Data on behalf of AccessPlus, such processing shall be governed by a separate Data Processing Agreement in accordance with Article 28 of the GDPR.

3.6 Third-Party Platforms

Apple App Store, Google Play Store and third-party payment providers act as independent Data Controllers in relation to personal data processed through their own platforms.

4. Categories of Data Processed

4.1 Data Stored Locally on the User’s Device

4.1.1 The EyeFocus Application stores certain data locally on the User’s Device. This data is not transmitted to AccessPlus, Feyenally, or any external servers.

4.1.2 The data stored locally on the User’s Device may include:

1. a) Name or identifier provided by the User (optional), used solely for the personalization of reports;
2. b) Vision test results generated by the Application;
3. c) Test history and previous test results for the purpose of tracking changes in vision over time;
4. d) PDF reports generated by the Application and saved on the User’s Device;
5. e) Application settings and preferences.

4.1.3 Vision test results and test history may constitute Health Data within the meaning of Article 9 of the GDPR.

4.1.4 All Health Data is stored exclusively on the User’s Device and is not transmitted, stored externally, or accessed by AccessPlus or Feyenally.

4.1.5 The User has full control over locally stored data and may delete such data at any time by deleting records within the Application or uninstalling the Application.

4.2 Technical Data Processed for Application Functionality

4.2.1 Limited Technical Data may be processed for the purpose of ensuring the proper functioning, maintenance, security, and performance of the Application.

4.2.2 Technical Data may include:

1. a) Device type and device model;
2. b) Operating system type and version;
3. c) Application version;
4. d) Crash logs and error reports;
5. e) Performance and diagnostic data;
6. f) Security-related logs.

4.2.3 Technical Data does not include vision test results, Health Data, names, or PDF reports generated by the User.

4.2.4 Technical Data is used solely for technical, diagnostic, security, and performance monitoring purposes and is not used for profiling, marketing, advertising, or automated decision-making.

4.3 Data Not Collected

4.3.1 The Application does not collect or process the following data:

1. a) Vision test results on external servers;
2. b) Medical records;
3. c) Biometric identifiers;
4. d) Location data (unless required for a specific program and explicitly disclosed);
5. e) Contacts, photos, or other personal files stored on the User’s Device.

5. Purposes of Processing

5.1 Technical Data is processed solely for the purpose of ensuring the proper functioning, security, maintenance, and improvement of the Application.

5.2 In particular, Technical Data may be processed for the following purposes: a) Ensuring the proper operation and functionality of the Application;

1. b) Detecting, diagnosing, and fixing technical errors, bugs, and system failures;
2. c) Maintaining the security, integrity, and stability of the Application and its infrastructure;
3. d) Monitoring application performance and improving stability, reliability, and user experience;
4. e) Preventing fraud, unauthorized use, misuse of the Application, or violations of the Terms of Service;
5. f) Complying with legal and regulatory obligations;
6. g) Maintaining internal records related to technical maintenance and security.

5.3 Technical Data is processed only to the extent necessary for the purposes listed above and is not used for marketing, advertising, profiling, or automated decision-making.

5.4 Health Data, including vision test results and test history, is processed exclusively locally on the User’s Device for the sole purpose of:

1. a) Displaying vision screening results to the User;
2. b) Allowing the User to monitor changes in vision over time;
3. c) Generating reports in PDF or other format at the User’s request.

5.5 Health Data is not transmitted to AccessPlus, Feyenally or any external servers and is not used for analytics, profiling, or research purposes by AccessPlus or Feyenally.

5.6 AccessPlus and Feyenally do not use Health Data to make automated decisions about Users and do not use such data for marketing, advertising, or commercial profiling.

6. Legal Basis for Processing

6.1 The processing of Personal Data in connection with the use of the Application is carried out in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and, where applicable, the Ghana Data Protection Act, 2012 (Act 843).

6.2 Personal Data is processed on the following legal bases under Article 6 of the GDPR:

6.2.1 Consent (Article 6(1)(a) GDPR)

Processing may be based on the User’s consent where the User voluntarily provides Personal Data within the Application, including where the User chooses to enter their name or identifier for the purpose of personalizing reports.

6.2.2 Performance of a Contract (Article 6(1)(b) GDPR)

Processing is necessary for the performance of a contract, namely the provision of the Application’s functionality, including generating vision screening results, displaying results, generating reports, and providing access to Application features.

6.2.3 Legitimate Interests (Article 6(1)(f) GDPR)

Processing of Technical Data is necessary for the purposes of the legitimate interests pursued by AccessPlus and Feyenally, including ensuring the security, stability, maintenance, and proper functioning of the Application, provided that such interests are not overridden by the fundamental rights and freedoms of the User.

Processing of Health Data

6.3 Vision test results and related information may constitute Health Data within the meaning of Article 9 of the GDPR.

6.4 Health Data is processed on the basis of the User’s explicit consent in accordance with Article 9(2)(a) of the GDPR.

6.5 Such processing of Health Data occurs exclusively locally on the User’s Device and is not transmitted to AccessPlus, Feyenally, or any external servers.

6.6 The User may withdraw consent at any time by deleting their data from the Application or uninstalling the Application from their Device.

Ghana Law

6.7 Where the Application is used in Ghana, Personal Data shall also be processed in accordance with the Ghana Data Protection Act, 2012 (Act 843).

7. Data Sharing and Disclosure

7.1 Vision test results, Health Data, and any Personal Data stored locally on the User’s Device are not transmitted to, accessed by, or shared with AccessPlus, Feyenally, or any third party.

7.2 All Health Data generated by the Application remains under the control of the User and is stored exclusively on the User’s Device unless the User chooses to export or share such data.

7.3 The User may voluntarily export reports generated by the Application and share them with third parties, including but not limited to optometrists, ophthalmologists, schools, employers, or family members. Any such sharing is done solely at the User’s discretion and under the User’s responsibility.

7.4 AccessPlus and Feyenally do not sell, rent, trade, or otherwise commercially distribute Personal Data or Health Data.

7.5 Limited Technical Data may be processed by Feyenally strictly on behalf of AccessPlus for the purpose of:

1. a) Application maintenance;
2. b) Technical support;
3. c) Error detection and correction;
4. d) Security monitoring;
5. e) System performance monitoring.

7.6 Technical Data shall be processed only to the extent necessary for the purposes listed above and shall not be used for marketing, advertising, profiling, or commercial data exploitation.

7.7 Personal Data or Technical Data may be disclosed where required to do so by law, regulation, court order, or lawful request by a public authority.

7.8 AccessPlus and Feyenally may also disclose limited information where necessary to:

1. a) Enforce the Terms of Service or Privacy Policy;
2. b) Protect the rights, property, or safety of AccessPlus, Feyenally, Users, or third parties;
3. c) Detect, prevent, or address fraud, security, or technical issues.

7.9 In the event of a merger, acquisition, restructuring, or sale of all or part of the business, Personal Data and Technical Data may be transferred to the acquiring entity, subject to the same data protection obligations described in this Privacy Policy.

7.10 Under no circumstances do AccessPlus or Feyenally maintain a central database of Users’ Health Data or vision test results.

8. Third-Party Services

8.1 The Application may be distributed, made available, or accessed through third-party platforms and services, including but not limited to:

1. a) Apple App Store;
2. b) Third-party payment providers;
3. c) Third-party hosting or technical service providers where applicable.

8.2 These third parties may collect and process personal data in connection with:

1. a) Application distribution and installation;
2. b) Payment processing and subscription management;
3. c) Device security and fraud prevention;
4. d) Platform analytics and performance monitoring;
5. e) Compliance with their legal and regulatory obligations.

8.3 Such processing is carried out independently by these third parties in accordance with their own terms of service, privacy policies, and legal obligations.

8.4 AccessPlus and Feyenally do not control, influence, or assume responsibility for the data processing practices of these third parties.

8.5 These third parties act as independent Data Controllers with respect to the personal data they collect and process through their own platforms and services.

8.6 AccessPlus and Feyenally do not receive, store, or process users’ payment card details or financial information. AccessPlus and Feyenally only receive confirmation that a payment has been successfully completed.

8.7 Users are encouraged to review the privacy policies and terms of service of these third-party providers before using the Application.

8.8 Third-party services are responsible for the security, processing, and storage of personal data collected through their platforms.

8.9 Under no circumstances do AccessPlus or Feyenally store or process users’ payment card information.

9. Payments

9.1 Certain features of the Application may require payment. Payments are processed securely by third-party payment providers, including but not limited to Apple App Store, PayPal, Paystack, or other authorized payment processors.

9.2 AccessPlus and Feyenally do not process, collect, store, or have access to users’ payment card details, bank account information, or other financial information.

9.3 AccessPlus and Feyenally only receive confirmation that a payment has been successfully completed in order to activate features, generate reports, or provide access to paid services within the Application.

9.4 Payment providers act as independent data controllers for payment transactions and process personal data in accordance with their own privacy policies, terms, and legal obligations.

9.5 Users agree that all payment disputes, chargebacks, refunds, and payment-related claims shall be handled in accordance with the terms and policies of the relevant payment provider through which the payment was made.

9.6 AccessPlus and Feyenally shall not be liable for:

1. a) Payment processing errors caused by third-party payment providers;
2. b) Payment failures, declined transactions, or billing errors caused by third-party platforms;
3. c) Unauthorized transactions resulting from the User’s failure to protect their payment credentials;
4. d) Any fees, exchange rate differences, or additional charges imposed by payment providers, banks, or mobile money operators.

9.7 Refunds, where applicable, may be subject to the refund policies of the relevant payment provider or platform through which the payment was made.

9.8 Nothing in this section affects any mandatory consumer protection rights that may apply under applicable law

10. Data Storage and Retention

10.1 Health Data Stored Locally

10.1.1 Vision test results and other health-related data generated by the Application are stored exclusively on the User’s Device and are not transmitted to Feyenally, AccessPlus, or any external servers.

10.1.2 Feyenally and AccessPlus do not collect, store, access, or otherwise process Health Data generated by the Application on their servers.

10.1.3 All Health Data remains under the control of the User and is stored locally on the User’s Device.

10.2 Retention of Health Data

10.2.1 Health Data stored locally on the User’s Device shall be retained only for as long as the User chooses to keep the Application installed or the data stored on the Device.

10.2.2 Health Data may be deleted by:

1. a) The User deleting the data within the Application;
2. b) The User uninstalling the Application;
3. c) The User resetting, replacing, or losing the Device.

10.2.3 Deletion of the Application may result in the permanent deletion of all locally stored data, unless the User has exported or backed up such data.

10.2.4 The User is solely responsible for retaining copies of any reports or data they wish to keep.

10.3 Technical Data Retention

10.3.1 Limited Technical Data, including device information, system logs, crash reports, and error reports, may be processed and stored for the purpose of application maintenance, security, troubleshooting, and performance improvement.

10.3.2 Technical Data shall be retained only for as long as necessary to:

1. a) Maintain and improve the Application;
2. b) Ensure security and prevent misuse;
3. c) Comply with legal and regulatory obligations;
4. d) Resolve technical issues, errors, or disputes.

10.3.3 Technical Data shall not be retained for longer than is necessary for the purposes for which it was collected.

10.4 Deletion and Anonymization of Technical Data

10.4.1 Technical Data may be periodically deleted, anonymized, or aggregated when it is no longer required for the purposes described in this Privacy Policy.

10.4.2 Where possible, Technical Data shall be anonymized so that it can no longer be associated with an identifiable individual.

10.5 No Central Health Database

10.5.1 AccessPlus and Feyenally do not maintain a central database of Users’ Health Data or vision test results.

10.5.2 All vision test results are stored exclusively on the User’s Device and are not accessible to AccessPlus or Feyenally.

11. User Rights

11.1 Rights Under Applicable Data Protection Laws

11.1.1 Under applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Ghana Data Protection Act, 2012 (Act 843), Users have the following rights in relation to their Personal Data:

1. a) The right to access Personal Data held about them;
2. b) The right to rectify or correct inaccurate or incomplete Personal Data;
3. c) The right to request the erasure of Personal Data, where applicable;
4. d) The right to restrict the processing of Personal Data in certain circumstances;
5. e) The right to withdraw consent at any time, where processing is based on consent;
6. f) The right to data portability, where applicable;
7. g) The right to object to processing, where processing is based on legitimate interests;
8. h) The right to lodge a complaint with a competent supervisory authority.

11.1.2 The exercise of these rights may be subject to limitations as provided under applicable law.

11.2 Health Data Stored Locally on the User’s Device

11.2.1 Vision test results and other health-related data are stored exclusively on the User’s Device and are not transmitted to or accessible by the Service Provider.

11.2.2 Because such data is stored locally and is not controlled or accessed by the Service Provider, Users may access, correct, delete, or export this data directly within the Application or by deleting the Application from their Device.

11.2.3 Requests relating to Health Data stored locally on the Device must be exercised by the User directly on their Device, as the Service Provider does not have access to such data.

11.3 Technical Data

11.3.1 Limited Technical Data related to application performance, security, and error monitoring may be processed by Feyenally on behalf of AccessPlus.

11.3.2 AccessPlus acts as the Data Controller for such Technical Data.

11.3.3 Users may exercise their rights relating to Technical Data by contacting AccessPlus using the contact details provided in this Privacy Policy.

11.4 Response Time

11.4.1 Requests relating to Personal Data shall be handled within the timeframes required under applicable data protection laws.

11.5 Supervisory Authority

11.5.1 Users have the right to lodge a complaint with a competent data protection authority, including:

1. a) A Data Protection Authority in a Member State of the European Union; or
2. b) The Data Protection Commission of Ghana.

11.6 Withdrawal of Consent

11.6.1 Where processing is based on consent, Users have the right to withdraw their consent at any time.

11.6.2 Withdrawal of consent shall not affect the lawfulness of processing carried out before the withdrawal of consent.

12. Data Security

12.1 Security Measures

12.1.1 The Service Provider implements appropriate technical and organizational measures designed to protect Technical Data against unauthorized or unlawful access, alteration, disclosure, loss, or destruction.

12.1.2 Such measures shall be appropriate to the nature of the data processed and the risks associated with such processing.

12.2 Types of Security Measures

12.2.1 Security measures implemented by the Service Provider may include, where appropriate: a) Secure communication channels and encryption where applicable;

1. b) Access controls and authentication mechanisms;
2. c) System monitoring, logging, and error reporting;
3. d) Regular software updates and security patches;
4. e) Limiting access to Technical Data to authorized personnel only;
5. f) Internal procedures for handling security incidents.

12.3 Data Stored on User Devices

12.3.1 Vision test results and Health Data are stored locally on the User’s Device and are not transmitted to the Service Provider.

12.3.2 The User is responsible for securing their Device using appropriate security measures, including passwords, screen locks, encryption, and biometric protection where available.

12.3.3 The Service Provider is not responsible for unauthorized access to data stored on a User’s Device where such access results from:

1. a) Loss or theft of the Device;
2. b) Failure by the User to secure their Device;
3. c) Malware, spyware, or unauthorized third-party access to the Device;
4. d) Use of the Device by unauthorized persons;
5. e) Other circumstances beyond the reasonable control of the Service Provider.

12.4 Limitation of Security

12.4.1 While the Service Provider implements reasonable and appropriate security measures, no method of electronic storage, transmission, or processing is completely secure.

12.4.2 Accordingly, the Service Provider cannot guarantee absolute security of any data.

13. Children’s Privacy

13.1 Use by Minors

13.1.1 The Application may be used by minors; however, where required by applicable law, the use of the Application by minors must be supervised by a parent, legal guardian, school, or other authorized institution.

13.1.2 The Service Provider does not knowingly collect or solicit Personal Data directly from minors through external servers.

13.2 Use in Schools and Institutional Programs

13.2.1 Where the Application is used in connection with schools, screening programs, or other institutional programs, the school, institution, program organizer, parent, or legal guardian is responsible for obtaining any required parental or guardian consent in accordance with applicable data protection laws.

13.2.2 The school, institution, or program organizer acts as the Data Controller for any personal data they collect, manage, or store outside the Application, including consent forms, student lists, or screening records.

13.2.3 The Service Provider acts only as a provider of the Application and does not control or determine how schools or institutions manage personal data collected outside the Application.

13.3 Children’s Data Stored on Device

13.3.1 Vision test results and Health Data generated by the Application remain stored locally on the device used for the test and are not transmitted to the Service Provider.

13.3.2 The Service Provider does not maintain a central database of children’s Health Data or vision test results.

13.4 Responsibility of Parents and Institutions

13.4.1 Parents, guardians, schools, and institutions are responsible for:

1. a) Supervising the use of the Application by minors;
2. b) Obtaining any required parental or guardian consent;
3. c) Managing any data stored on the device used by the minor;
4. d) Deciding whether to share reports with third parties such as doctors, schools, or parents.

13.4.2 The Service Provider shall not be responsible for the collection, use, disclosure, or management of children’s personal data by schools, institutions, parents, or guardians outside the Application.

14. Medical Disclaimer

14.1 Informational and Screening Tool Only

14.1.1 The EyeFocus Application is a vision screening and informational tool only and is not intended to be used for medical diagnosis, medical treatment, or medical decision-making.

14.1.2 The Application is not a medical device unless explicitly stated otherwise in accordance with applicable laws and regulations.

14.2 No Medical Advice

14.2.1 The Application does not provide medical advice, medical diagnosis, or medical treatment of any kind.

14.2.2 Any information, results, or reports generated by the Application are provided for informational and screening purposes only.

14.3 Not a Substitute for Professional Examination

14.3.1 Vision test results provided by the Application are estimates and screening results only and are not a substitute for a comprehensive eye examination conducted by a qualified optometrist, ophthalmologist, or other licensed healthcare professional.

14.3.2 The Application cannot detect all vision problems, eye diseases, or medical conditions.

14.4 Seek Professional Advice

14.4.1 Users should seek professional medical advice from a qualified healthcare provider if they: a) Have concerns about their vision;

1. b) Experience vision problems;
2. c) Receive abnormal or concerning screening results;
3. d) Require a medical diagnosis or treatment.

14.5 No Responsibility for Medical Decisions

14.5.1 The Service Provider shall not be responsible for any medical decisions, treatment decisions, or health-related decisions made by the User or any third party based on the results generated by the Application.

14.6 Use at Own Risk

14.6.1 Use of the Application is at the User’s own risk.

14.6.2 The User assumes full responsibility for how they use the information and results generated by the Application.

15. Limitation of Liability

15.1 To the maximum extent permitted by applicable law, AccessPlus and Feyenally shall not be liable for any damages, losses, or claims arising out of or in connection with the processing of personal data in accordance with this Privacy Policy.

15.2 This includes, but is not limited to:

1. a) Unauthorized access to data stored on a user’s device where such access results from loss, theft, or failure to secure the device;
2. b) Data loss resulting from device failure, device damage, software issues, operating system issues, or deletion of the Application;
3. c) Actions taken by third parties to whom the user has chosen to disclose their data or exported reports;
4. d) Temporary technical issues affecting the Application, including bugs, interruptions, or errors;
5. e) Processing of data by third-party platforms such as Apple App Store, or payment providers acting as independent data controllers.

15.3 While AccessPlus and Feyenally implement appropriate technical and organizational measures to protect Technical Data, no method of electronic storage, transmission, or device security is completely secure, and absolute security cannot be guaranteed.

15.4 Nothing in this Privacy Policy excludes or limits liability where such exclusion or limitation is not permitted by applicable law, including under the GDPR or the Ghana Data Protection Act, 2012 (Act 843).

16. International Data Transfers

16.1 Technical Data may be processed within the European Economic Area (EEA), including by Feyenally in the Republic of Poland.

16.2 Vision test results and Health Data are stored locally on the user’s device and are not transmitted to AccessPlus, Feyenally, or any external servers. As a result, such data is not subject to international data transfers by the Service Providers.

16.3 Where Technical Data is transferred outside the user’s country of residence, including transfers between Ghana and the European Economic Area (EEA), such transfers shall be carried out in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Ghana Data Protection Act, 2012 (Act 843).

16.4 Where required by law, appropriate safeguards shall be implemented for international data transfers, including:

1. a) Standard Contractual Clauses approved by the European Commission;
2. b) Transfers to countries recognized as providing an adequate level of data protection;
3. c) Other lawful transfer mechanisms permitted under applicable data protection laws.

16.5 Because Health Data and vision test results are stored locally on the user’s device and are not transmitted to external servers, risks associated with international transfer of sensitive health data are significantly minimized.

17. Governing Law

17.1 This Privacy Policy shall be governed by and interpreted in accordance with the laws of the Republic of Poland and applicable European Union data protection laws, including the General Data Protection Regulation (EU) 2016/679 (GDPR).

17.2 Where the Application is used in Ghana or in connection with programs operated in Ghana, applicable provisions of the Ghana Data Protection Act, 2012 (Act 843) shall also apply.

17.3 Nothing in this Privacy Policy shall limit or restrict the rights of data subjects under applicable data protection laws, including the right to lodge a complaint with a competent supervisory authority in their country of residence, place of work, or place of the alleged infringement.

17.4 Subject to mandatory provisions of applicable data protection laws, any disputes arising in connection with this Privacy Policy shall be subject to the jurisdiction of the competent courts of the Republic of Poland

18. Changes to This Privacy Policy

18.1 We may update or modify this Privacy Policy from time to time to reflect changes in legal requirements, regulatory obligations, business operations, or application functionality.

18.2 Where changes are material, users may be notified through the Application or through other appropriate communication channels.

18.3 The updated version of this Privacy Policy will be indicated by the “Last Updated” date at the top of this document.

18.4 Continued use of the Application after any changes to this Privacy Policy constitutes acceptance of the updated Privacy Policy, to the extent permitted by applicable law.

19. Contact Information

19.1 Data Processor

Feyenally Sp. z o.o.

1. Stanisława Leszczyńskiego 4

50-078 Wrocław

Poland

Email: hello@feyenally.com

19.2 Data Controller

AccessPlus Communications Limited

28 Djanie Ashie Road

East Legon, Accra

Ghana

Email: office@accessplusgh.com

19.3 Data Protection Requests

Users who wish to exercise their data protection rights, including the right of access, rectification, erasure, restriction of processing, data portability, or withdrawal of consent, may contact the Data Controller using the contact details provided above.

19.4 Supervisory Authorities

Users have the right to lodge a complaint with a competent data protection authority, including:

• The Data Protection Commission of Ghana; or
• A Data Protection Authority within the European Union.