Privacy Notice

GTI Holding Limited ("GTI Holding", “we”, “us” or “our") is committed to maintaining the highest standards of data privacy and protection.

This Website Privacy Notice (“Notice”) sets out the basis on which we collect, process, store, disclose, and safeguard personal data obtained from users (“you” or “data subjects”) who access or interact with our website and associated digital platforms.

This Notice is issued in accordance with applicable data protection laws, including the Data Protection Act, 2012 (Act 843) of Ghana, and any relevant international standards governing the collection and use of personal data.

This Notice applies to all personal data collected through GTI Holding’s website, including but not limited to data collected via contact forms, subscription mechanisms, career applications, cookies, analytics, and any other digital interactions between you and GTI Holding. This Notice does not extend to third-party websites, plug-ins, or applications that may be linked from our website; we encourage you to review their respective privacy policies.

GTI Holding collects personal data through direct and indirect interactions, including but not limited to:

A. Data Provided Voluntarily:

• Contact information (e.g., name, email address, telephone number)
• Professional information (e.g., company name, role, CV submissions)
• Any other information submitted via contact forms, job applications, service inquiries, or subscriptions

B. Data Collected Automatically:

• Internet protocol (IP) address
• Browser type and version
• Device identifiers and operating system
• Geolocation data
• Usage data (e.g., pages visited, time spent, referral URLs)
• Cookies and tracking technologies (in accordance with our Cookie Policy)

Such data is collected to facilitate user experience, conduct analytics, and ensure operational efficiency of our website.

Personal data is processed in compliance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

Specifically, GTI Holding processes personal data under the following lawful bases and for the purposes outlined below:

• Consent: Where explicit consent is obtained, we process personal data to communicate with you, provide requested information, and deliver newsletters or marketing content. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.
• Performance of Contract: We process personal data necessary to fulfil pre-contractual and contractual obligations, including processing job applications, partnership requests, or service agreements submitted via our website.
• Legitimate Interests: We process personal data to pursue our legitimate interests in improving service delivery, enhancing user experience, conducting website analytics, managing business operations, and safeguarding our digital infrastructure.
• Compliance with Legal Obligations: Personal data may be processed and disclosed to fulfil statutory obligations under applicable laws and regulatory frameworks, including disclosures required by law enforcement agencies, financial regulatory authorities, or judicial processes.

Where processing is based on consent, GTI Holding shall obtain affirmative, informed consent at the point of data collection. By using our website, you consent to the collection and use of personal data in accordance with the provisions of this Notice.

You may revoke your consent at any time by contacting our Head of Information Technology using the details provided in Section 9.

GTI Holding does not sell or license personal data to third parties for commercial gain. However, we may share personal data under the following controlled circumstances:

• With subsidiaries and affiliated entities within the Golden Tintona Investment Holding group for internal operational purposes
• With third-party processors or service providers under contractual obligations to provide IT, analytics, communications, legal, or support services
• With regulatory bodies or government agencies to comply with legal obligations
• In connection with a business transfer, merger, or acquisition, subject to confidentiality agreements

Where personal data is transferred outside of Ghana, we ensure appropriate safeguards are in place, including standard contractual clauses or data protection agreements consistent with applicable cross-border transfer requirements.

GTI Holding adopts a layered security approach comprising physical, administrative, and technical controls to protect personal data from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption and pseudonymization
• Secure access controls and authentication
• Firewall and intrusion detection systems
• Data minimisation protocols
• Periodic security audits and penetration testing

Our staff and third-party processors are subject to strict confidentiality obligations and trained on data protection best practices.

In accordance with applicable data protection laws, you have the following rights regarding your personal data:

• The right to request access to the personal data we hold about you.
• The right to request rectification or correction of inaccurate or incomplete data.
• The right to withdraw your consent where processing is based on consent.
• The right to request the erasure or deletion of your personal data, subject to legal exceptions.
• The right to object to or restrict the processing of your personal data.
• The right to object to automated decision-making, where applicable.
• The right to request data portability, where feasible.

To exercise any of these rights, or to make an inquiry or lodge a complaint regarding our data processing activities, please contact our Data Protection Officer (DPO) using the details provided in the next section. You also have the right to lodge a complaint with the Ghana Data Protection Commission or other relevant supervisory authority if you believe your rights have been violated.

To exercise your rights or obtain additional information regarding this Notice, please contact:

Head, Information Technology
GTI Holding Limited
H P Nyemitei Street f809/1

Email: Cio@gtiholding.com
Phone: +233202021810

This Notice is subject to periodic review and may be updated to reflect changes in legal, regulatory, or operational requirements. Any material revisions will be communicated via our website. Continued use of our website following such updates constitutes acknowledgment of the modified terms.