1. Scope
2. Personal Information We Collect
3. How We Use Your Personal Information
4. How We Disclose Your Personal Information
5. Your Privacy Choices and Rights
6. Security of Your Personal Information
7. International Data Transfers / Applicable Data Protection Laws
8. Retention of Personal Information
9. Supplemental Notice for Ghana Residents
10. Children’s Information
11. Other Provisions
12. Contact Us

1. Scope

This Privacy Policy applies to personal information processed by Excelsa, including on our website, through our project intake and farmer and landowner engagement activities, our field and survey operations, our community integration and green skills training programmes, and other online or offline offerings that we own or control and which incorporate by reference or link to this Privacy Policy. These are collectively referred to as the “Services”.

Information that we collect or process in connection with our project agreements, carbon credit arrangements, or due diligence on forestry, agro-forestry, and cocoa rehabilitation projects may be governed by separate terms executed between Excelsa and you, and are not subject to this Privacy Policy except to the extent expressly stated in the separate terms applicable to you.

As used in this Privacy Policy, “personal information” means information that can be used to identify you under applicable data protection laws, including the Data Protection Act, 2012 (Act 843) of Ghana. Personal information can include your name, address, telephone number, and email address, as well as indirect identifiers such as your IP address, device identifier, and farm or land location data. Unless otherwise stated, all references to “information” and “your information” should be read as references to personal information. We may also process data in relation to your use of the Services which does not identify you and is not directly linked to your personal information. Such data is not personal information and is not subject to the terms addressing personal information in this Privacy Policy.

2. Personal Information We Collect

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect personal information that you provide to us directly, personal information we obtain automatically when you use our Services, and information from other sources such as partner organisations and public registers, as described below.

Information You Provide to Us Directly

We may collect the following categories of personal information that you provide to us directly:

• Contact and identity information, such as your name, national identification details, telephone number, email address, and postal address.
• Farm and land ownership information, including records of land tenure, farm ownership, lease or sharecropping arrangements, and consent to access and manage farmland.
• Agro-forestry and project data, including cocoa farm details, history of Cocoa Swollen Shoot Viral Disease (CSSVD) rehabilitation, coppice management and plantation records, and soil and water resource information relevant to our restoration and maintenance services.
• Community and employment information, such as data relating to local community members, women-led farm groups, and field workforce participants engaged in our operations.
• Financial and contract information, such as payment details and records required to administer service agreements, carbon credit arrangements, and training programmes.

Information We Obtain Automatically

When you visit our website or use our Services, we may automatically collect information such as your IP address, browser type, device identifiers, pages visited, and other usage data. We and our service providers may use cookies and similar technologies to support the operation and improvement of the Services, consistent with your consent where required by applicable law.

Information We Collect From Other Sources

We may receive personal information about you from other sources, including the Forestry Commission of Ghana, COCOBOD and its divisions, project partners, local authorities, and other organisations with which we collaborate on natural resource and agro-forestry projects, where permitted by law and where you have consented where required.

3. How We Use Your Personal Information

We use your personal information for the following purposes:

• Providing and managing our Services, including forestry and agro-forestry engineering, restoration of degraded lands, cocoa rehabilitation, coppice management, and plantation carbon sink development and management.
• Community integration and engagement, including outreach to farmers, landowners, and community stakeholders in line with our modified community integration approach.
• Surveying and mapping, including the collection and processing of GPS and GIS farm and land location data to plan and manage restoration and maintenance activities.
• Carbon and sustainability projects, including assessing, documenting, and managing contributions to carbon cycles and the trading of carbon credits.
• Communication, including responding to your enquiries, providing updates on projects, and sending relevant information about our services.
• Legal and regulatory compliance, including complying with the Data Protection Act, 2012 (Act 843) of Ghana, and other applicable laws and regulations, and meeting our obligations to public authorities and partner institutions.
• Security and integrity, including protecting the safety and security of our operations, our personnel, and the communities and ecosystems we serve.

4. How We Disclose Your Personal Information

We may disclose your personal information in the following circumstances:

• Public and regulatory bodies, such as the Forestry Commission of Ghana, COCOBOD and its divisions, and the Data Protection Commission of Ghana, where required or permitted by law and in connection with project approvals, coppice management targets, and compliance.
• Project partners and contractors, who support our restoration, maintenance, survey, and training activities, and who process your information on our behalf subject to appropriate safeguards.
• Service providers, such as IT, hosting, payment, and analytics providers who assist us in operating our Services.
• Professional advisers and authorities, including legal, accounting, and other professional advisers, and government authorities in response to lawful requests.
• Business transactions, in connection with a merger, acquisition, or transfer of all or part of our business, where the recipient agrees to protect your personal information in a manner consistent with this Privacy Policy.

Except as described in this Privacy Policy, we do not sell your personal information, and we do not share it with third parties for their own direct marketing purposes.

5. Your Privacy Choices and Rights

Subject to applicable law, including the Data Protection Act, 2012 (Act 843) of Ghana, you may have the following rights in respect of your personal information:

• The right to request access to the personal information we hold about you.
• The right to request that we correct any inaccurate or incomplete personal information.
• The right to request the deletion or erasure of your personal information, subject to legal and contractual obligations.
• The right to withdraw your consent at any time where we rely on consent to process your information.
• The right to object to, or request restrictions on, certain processing of your personal information.
• The right to lodge a complaint with the Data Protection Commission of Ghana or another competent supervisory authority.

To exercise any of these rights, please contact us using the details in the “Contact Us” section below. We may need to verify your identity before responding to your request and will respond within the timeframes required by applicable law.

6. Security of Your Personal Information

We use appropriate technical and organisational measures designed to protect your personal information against unauthorised access, disclosure, alteration, and destruction, taking into account the sensitivity of the information and the risks associated with its processing. No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

7. International Data Transfers / Applicable Data Protection Laws

Your personal information may be transferred to, and processed in, countries other than the one in which you reside, including where our service providers or partners are located. Where such transfers occur, we take steps designed to ensure that your personal information receives an appropriate level of protection and that the transfer is carried out in accordance with applicable data protection laws, including the Data Protection Act, 2012 (Act 843) of Ghana.

8. Retention of Personal Information

We retain your personal information for as long as necessary to fulfil the purposes described in this Privacy Policy, to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our agreements. When we no longer need your personal information, we will delete, anonymise, or securely dispose of it in accordance with applicable law.

9. Supplemental Notice for Ghana Residents

If you reside in Ghana, your personal information is protected by the Data Protection Act, 2012 (Act 843) of Ghana, which is administered by the Data Protection Commission of Ghana. Under this Act, you may have additional rights and remedies in respect of your personal information, including the right to seek the enforcement of your rights through the Data Protection Commission or a court of competent jurisdiction. Nothing in this Privacy Policy limits any rights you may have under Ghanaian law.

10. Children’s Information

Our Services are directed to individuals involved in, or interested in, forestry, agro-forestry, and natural resource management activities and are not directed to children. We do not knowingly collect personal information from children, and we request that children do not submit any personal information to us. If we become aware that we have collected personal information from a child in a manner that is not permitted by applicable law, we will take reasonable steps to delete it.

11. Other Provisions

Changes to this Privacy Policy: We may update this Privacy Policy from time to time to reflect changes in our practices, the law, or our industry. We will indicate the date of the most recent revision at the top of this Privacy Policy and, where appropriate, notify you of material changes. We encourage you to review this Privacy Policy periodically.

Third-party links: Our Services may contain links to third-party websites and services that are not governed by this Privacy Policy. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies.

Compliance with the Sustainable Development Goals (SDGs): In line with our commitment to natural resource management and sustainable community development, we process personal information responsibly and in support of the environmental and social objectives of our forestry and agro-forestry operations.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our privacy practices, or if you wish to exercise your privacy rights, please contact us at:

• Excelsa Forestry Renewables Ghana Ltd
• GA-361-9901, Kwashieman Street, Mataheko
• P.O. Box GP 2099, Accra – Ghana
• Email: info@excelsagh.com
• Phone: +233 (0) 246 468 108 | +233 (0) 246 422 924

You may also contact the Data Protection Commission of Ghana to lodge a complaint if you are not satisfied with how we have handled your personal information.