Privacy Policy

1. Who We Are (Data Controller)

liflio.com.gh ("Liflio Ghana") is operated by LIFLIO SAS, a simplified joint-stock company (société par actions simplifiée) incorporated in France, registered with the Bordeaux Trade and Companies Register (RCS Bordeaux 930 697 339), VAT number FR88930697339, registered office 18 rue Eugène Le Roy, 33800 Bordeaux, France. LIFLIO SAS is the controller of the personal data described in this policy. "Liflio Ghana" is a trading name of LIFLIO SAS; we have no establishment in Ghana.

• Email: [email protected] (subject "Privacy")
• Post: LIFLIO SAS, 18 rue Eugène Le Roy, 33800 Bordeaux, France

We have not appointed a Data Protection Officer because we are not required to.

2. Personal Data Collected

In the course of using our Service, Liflio may collect the following categories of personal data:

• Identification data: name, email address, password (encrypted)
• Usage data: browsing history on the platform, catalogues viewed, coupons used, shopping preferences
• Technical data: IP address, browser type and version, operating system, device identifier
• Analytical data: usage statistics, click-through rates, session duration, pages visited
• Location data: approximate geolocation (only with your explicit consent), to offer you relevant deals nearby
• Affiliate clicks: when you follow a link to a retailer, we record the click (the page, the retailer, the time, your browser type and a one-way hash of your IP address) so that the retailer can pay us a commission

Where the data comes from: from you, from your device, and, if you choose "Continue with Google", from your Google profile (name, email address and profile picture).

Do you have to give it? An email address is needed to create an account. Everything else is optional: you can browse deals and catalogues without an account and without accepting any non-essential cookies.

3. Purposes and Legal Basis

Your personal data is processed for the following purposes:

• Performance of contract: managing your account and providing the features you ask for (shopping lists, favourites, deal alerts)
• Legitimate interest: keeping the Service secure and preventing fraud and abuse, improving the Service, personalising the deals we show you, and recording affiliate clicks so retailers can pay us. We have balanced these interests against your rights, and you can object at any time (section 6)
• Consent: sending marketing communications, geolocation, non-essential cookies, sharing data with partners
• Legal obligation: retention of data required under the Data Protection Act, 2012 (Act 843) and applicable legislation, responding to requests from competent authorities

You can object at any time, without giving a reason, to the use of your data for direct marketing, and we will stop. We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you.

4. Who Receives Your Data

We use the following providers, who act on our instructions (or, for advertising and analytics tools, only once you have accepted that cookie category):

• Hostinger International Limited: website and database hosting (servers in France)
• Cloudflare, Inc. and jsDelivr: content delivery and network security
• Google (Analytics, Tag Manager, Firebase Cloud Messaging, Google sign-in, Google Fonts): analytics after consent, push notifications if you enable them, sign-in if you choose it
• Microsoft (Clarity): audience analysis and session replay, only after analytics consent
• Ahrefs (Web Analytics): cookieless audience measurement, no personal profile
• Meta Platforms (Meta Pixel): advertising measurement, only after marketing consent
• Brevo: sending account and alert emails
• Retailers and affiliate networks (such as Awin, CJ and Effiliation): when you click through to a retailer, they receive the click and a reference number, never your name or email address
• Authorities: when the law requires it

We do not sell your personal data for money.

5. International Transfers

Your data is hosted in France, in the European Union.

Some of our providers (Google, Microsoft, Meta and Cloudflare) also process data in the United States. For those providers we rely on the EU-US Data Privacy Framework, under which they are certified, and otherwise on standard contractual clauses. You can ask us for a copy of the safeguards.

6. Your Data Protection Rights

In accordance with the Data Protection Act, 2012 (Act 843), you have the following rights:

• Right of access: obtain confirmation that your data is being processed and receive a copy
• Right to rectification: request the correction of inaccurate or incomplete data
• Right to erasure: request the deletion of your personal data
• Right to data portability: receive your data in a structured, commonly used and machine-readable format
• Right to object: object to the processing of your data on grounds relating to your particular situation
• Right to restriction of processing: request the suspension of processing in certain cases
• Right to withdraw consent: at any time, without affecting the lawfulness of processing based on consent before its withdrawal

To exercise your rights, contact us at [email protected]. We undertake to respond to your request within one month.

You also have the right to lodge a complaint with the Data Protection Commission of Ghana.

7. Security and Retention

We protect your data with HTTPS encryption across the whole site, hashed passwords, access limited to the people who need it, and regular backups.

Data	How long we keep it
Account data	Until you delete your account; erased within 30 days of deletion unless the law requires us to keep it
Affiliate click records	13 months with the hashed IP address and browser details, then kept only as anonymous counts
Analytics data (Google Analytics)	13 months
Server logs	12 months
Your cookie choice	13 months
Push notification token	Until you turn notifications off or the token expires

8. Third-Party Links and Updates

The Service may contain links to third-party websites. Liflio is not responsible for the privacy practices of those sites. We encourage you to review the privacy policies of any third-party site you visit.

Liflio reserves the right to modify this Privacy Policy at any time. In the event of a substantial change, we will notify you by email or by notification on the platform. The date of the last update is shown at the bottom of this page.

Contact

For any questions regarding this Privacy Policy or the protection of your personal data:

• Email: [email protected]
• Post: LIFLIO SAS, 18 rue Eugène Le Roy, 33800 Bordeaux, France

Any disputes arising from this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Ghana.