PRIVACY POLICY FOR GLOW UP

1. Introduction

This document is the official Privacy Policy of Astrum Group Ltd. trading as Glow Up (hereinafter referred to as Glow Up), a company incorporated under the laws of the Republic of Ghana with its registered address at MVQ9+7FM Madina, Accra, Ghana, and company registration number +233505994542, outlining how Glow Up collects, uses, and shares your personal information when you visit or make a booking through our website: www.glowupgh.com ('the Site').

2. Data Controller

The data controller is:

Astrum Group Ltd.
Registered Address: MVQ9+7FM Madina, Accra, Ghana
Company Registration Number: +233 50 599 4542
Email: info@glowupgh.com
Data Protection Officer: Not Appointed

3. Personal Information Collected by Glow Up

Glow Up may collect and process the following types of personal data:

  • Device Information: including browser types, IP addresses, time zones, cookies, referring/exit pages, and interactions with the Site.
  • Booking Information: including names, phone numbers, email addresses, locations (however so provided), service preferences, and payment details.

We do not knowingly collect information from persons under the age of 18 without verifiable parental consent.

4. How Glow Up Collects Information

Information is collected via:

  • Cookies (see www.allaboutcookies.org)
  • Log files
  • Web beacons, tags, and pixels
  • Any other means by which information is subsequently collected

5. Legal Basis for Processing

Glow Up processes personal data under the following legal bases:

  • Consent (e.g., for marketing communications)
  • Performance of a Contract (e.g., booking fulfillment)
  • Legal Obligations (e.g., fraud prevention)
  • Legitimate Interest (e.g., analytics and service improvement)

6. How Glow Up Uses Client Information

Client data is used to:

  • Process and confirm bookings
  • Communicate with you about appointments or account status
  • Detect and prevent fraud or misuse
  • Send marketing communications (with consent)
  • Improve services and website performance
  • Comply with legal obligations

7. Sharing Your Information

Client information may be shared with:

  • Payment processors such as Paystack
  • Analytics providers such as Google Analytics
  • Government authorities where legally required

Glow Up ensures third-party service providers adhere to strict data processing agreements, policies, and guidelines in compliance with Ghana's Data Protection Act, 2012 (Act 843).

8. Marketing & Behavioural Advertising

(a) Where the Client opts-in, Glow Up may send:

  • Promotional emails or SMS
  • Targeted ads (e.g., via Google or Facebook)

(b) The Client may opt-out via:

9. SMS & Notifications

With the Client’s consent, Glow Up may send:

  • Appointment confirmations or reminders
  • Service updates or offers

Clients may Opt-out by replying 'STOP' to any SMS or by emailing Glow Up at info@glowupgh.com.

10. Data Protection Rights

Under Ghana’s Data Protection Act, 2012 (Act 843), Clients have the right to:

  • Access your personal data
  • Request correction or deletion
  • Object to or restrict processing
  • Lodge a complaint with the Data Protection Commission

Requests will be responded to within 30 days in accordance with Act 843. Please email info@glowupgh.com to exercise these rights.

11. Data Retention

Glow Up may retain booking data for up to five (5) years, or as may be required by law. Data may be deleted earlier upon Client’s request.

12. International Data Transfers

Client data may be transferred outside Ghana, including to the United States. Glow Up ensures appropriate safeguards such as contractual clauses are in place to comply with Act 843 and industry best practices.

13. Do Not Track Signals

Glow Up does not currently respond to “Do Not Track” browser settings. This practice is consistent with industry standards.

14. Changes to This Policy

Glow Up may update this Privacy Policy periodically. Any significant changes will be communicated by email (where available) or via notice on the Site.

15. Contact Us

For questions, concerns, or data access requests, please contact:

Astrum Group Ltd.
Email: info@glowupgh.com
Postal Address: MVQ9+7FM Madina, Accra, Ghana

This Privacy Policy forms part of the legal terms governing your use of Glow Up services.

Last Updated: 9th July 2025