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Last Updated: 15 March, 2021

End-User Privacy Policy Statement

Inclusive Innovations Incorporated is committed to protecting your privacy. This Privacy Policy Statement (the “Privacy Statement”) illustrates the Inclusive Innovations Incorporated. (referred to as “Inclusive Innovations Inc.”, “we”, “our” or “us”) privacy practices.


This Privacy Policy explains how we collect, use, and share end user information in our possession to operate, improve, develop, and protect our services, and as otherwise outlined in this Policy. It also explains what your choices are regarding the collection, use and sharing of your information and that of your End Users is collected and used by Inclusive Innovations Inc. when you use our website, services, tools and application program interface (API) (collectively, “Services” ) or otherwise interact with us. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. We may check the details you provide with fraud prevention agencies and share your information with them if we suspect fraud. It is important that you do not provide false, inaccurate information or impersonate another individual. This Privacy Statement applies to employees of our company, contractors, consultants, Business Partners, Data Subjects and any other external entity.

Generally, our Privacy Statement refers to Services owned and or operated by Inclusive Innovations Inc. either on its own behalf (as data controller in terms of data provided through our platform) or on behalf of Relying Parties (as data processor in terms of verification services through our platform).

Inclusive Innovations Inc. provides online identity verification services for:

  • You, (the "Data Subject") (via the registration platform); or

  • Relying parties (via the identity verification platform) and their users or customers. A Relying Party or Relying parties refers to businesses that require identify verification services and who share your information with us through our platform through a formal agreement with Inclusive Innovations Inc. (the "Relying Parties").

Collection of Personal Information

Personal information is data that can be used to identify or contact an individual.

By using Inclusive Innovations Inc.. Services, you consent to the storage, usage and disclosure of your personal information including your nonpublic personal information (collectively referred to as “Personal Information”) either as Data Controller or in our capacity as Data Processor. Inclusive Innovations Inc. is based in Ghana and the information we collect is governed by Ghanaian law. By accessing or using the Services or otherwise providing information to us, you consent to the control and processing of the information by Inclusive Innovations Inc. and Relying Parties.

We collect Personal Information from you for a number of reasons including processing or registering you as a user of a Relying Party's service through the API platform or providing services on our own behalf through our Services. Your Personal Information is either supplied by the Relying Party to us, or captured through our Services, where you enter these details directly. If you provide Personal Information about other individuals (such as employees, dependents, etc.), you must obtain their consent prior to your disclosure to Inclusive Innovations Inc.. Any Personal Information we collect will be used strictly in accordance with current data protection legislation and this Privacy Statement.

Information You Provide to Us Directly

Personal data of the relevant customers and partners can be processed in order to establish, execute and terminate a contract. Prior to a contract or during the contract initiation phase, personal data shall be processed to fulfill customer due diligence requirements prior to the contract conclusion.

Information We May Collect From Other Sources

When a Data Subject or a Relying Party creates an Inclusive Innovations Inc. account, we may collect information, including Personal Information, about you or your data subjects from nonaffiliated third-party service providers and statutory authorities in order to verify identities and for fraud prevention, including prior addresses, names and consistency of information across other identity documents. Personal Information collected may come directly from you, or through our affiliates or other third parties (such as employers, statutory authorities, etc.).

When we collect information from a Relying Party we ask them to ensure that they have the Data subjects consent to share the Personal Information and that they ensure compliance with this Privacy Statement.

Information We May Collect When You Visit our Websites

For purposes of this Privacy Statement, "website" includes our mobile applications.

By using Inclusive Innovations Inc. websites and associated microsites, you agree to the processing of your Personal Information as explained in this Privacy Statement, including the placement of cookies on your device.

Personal information is collected to fulfill your requests for products and services and to improve your online experience. Inclusive Innovations Inc. takes steps to limit the amount of Personal Information collected to what is required to support the intended purpose of the collection.

Inclusive Innovations Inc. may ask you for some or all of the following types of information when you register for events, promotions, request services, manage accounts, access various content and features or directly visit our websites. The information includes, but is not limited to:

  • contact information, such as name, e-mail address, postal address, phone number and mobile number;

  • user name, password, password reminder questions and password answers;

  • communication preferences, such as which newsletters you would like to receive;

  • search queries;

  • contact information about others when you refer a friend to a particular site or service; and

  • information posted in community discussions and other interactive online features.

In some instances, Inclusive Innovations Inc. will automatically collect certain types of information when you visit our websites and through e-mails exchanged between Inclusive Innovations Inc. and the customer, or through our customer service chat. Automated technologies may include the use of web server logs to collect IP addresses, "cookies" and web beacons. The collection of this information will allow us to improve the effectiveness of Inclusive Innovations Inc. websites and our marketing activities.

Mobile Devices: If you access our websites on your mobile device, Inclusive Innovations Inc. may collect your unique device identifier and mobile device IP address, as well as information about your device's operating system, mobile carrier and your location information.

When you provide us your mobile phone number as your contact phone number, you consent to the use of your mobile phone number for the purposes identified in this Privacy Statement. If you choose to receive notifications from us on your mobile device (e.g. text notifications), you also consent to the use of your mobile phone number for that purpose.

Location Information: We may obtain your location information from our Business Partners, or otherwise on our Services. We may also incorporate geo mapping into our Services, and you may consent to the collection of location information by the third party geo mapping service provider in connection with your use of the geo mapping service. Any information collected via your use of the geo mapping service should be transmitted directly through the geo mapping service provider and is not through Inclusive Innovations Inc.. Please refer to the geo mapping service provider' privacy policy for details about their collection, use and sharing of this information.

Cookies: Inclusive Innovations Inc. collects information during your visit to the Inclusive Innovations Inc. website through the use of cookie technology. A cookie is a piece of programming information contained in a very small text file that is placed in your internet browser or elsewhere on your hard drive. You can control acceptance of cookies by modifying your internet browser preferences. You have the ability to accept all cookies, to be notified when a cookie is set or to reject all cookies. Please note that, if you choose to block all cookies (including essential cookies) you may not be able to access all or part of our site and may be unable to use those services or engage in activities that require the placement of cookies. Inclusive Innovations Inc. uses cookies to distinguish you from other users of our website and also provide us with aggregated website usage statistics.

In addition, on some occasions, Inclusive Innovations Inc. may use tracking technologies such as web beacons, to collect information about your visits to Inclusive Innovations Inc. websites. These are small electronic images embedded in web content or e-mail messages and are ordinarily not visible to users. Like cookies, this tracking technology enables us to track pages and content accessed and viewed by users on Inclusive Innovations Inc. websites. The use of these technologies also helps us to provide you with a positive experience when you browse our websites, and it also helps refine our content and personalize your experience.

Links to Other websites: Inclusive Innovations Inc. websites may contain links to other sites which are outside our control and are not covered by this Privacy Statement. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policies. Inclusive Innovations Inc. is not responsible for the content or privacy practices of linked sites or any use of those sites.

Please be aware that Inclusive Innovations Inc. websites may contain links to sites maintained by other Inclusive Innovations Inc. entities that are not governed by this Privacy Statement but by other privacy policies that may differ slightly from this Privacy Statement. We encourage you to review the privacy policy of each website you visit.

Information We Collect When You Engage With Us on Social Media

You can engage with Inclusive Innovations Inc. through social media websites or applications or through features such as plug-ins or applications on Inclusive Innovations Inc. websites that integrate with social media sites. You may also choose to link your account with Inclusive Innovations Inc. to third party social media sites. When you link your social media account, or engage with Inclusive Innovations Inc. on or through third party social media sites, plug-ins, or applications, you may allow Inclusive Innovations Inc. to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the 'likes' you make).

If you post information when you interact with our Services through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. You can control what information you share through privacy settings available on some social media sites. For more information about how you can customize your privacy settings and how third party social media sites handle your personally identifiable information, please refer to their privacy help guides, privacy policies and terms of use.

Information We May Collect Through Third Party Advertising

We may allow others to provide analytics services on our behalf and to serve advertisements on our behalf across the internet. These Third Party Advertising Partners may use cookies, web beacons and other technologies to display advertisements of our products to you when you are on other, third-party websites that are affiliated in some way with the advertising partners. The information collected and shared via cookies may contain Personal Information.

The Third Party Advertising Partners may collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by Inclusive Innovations Inc. and others, to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests and better understand your online activity.

To Process Your Requests

As part of our verification process we will obtain electronic copies of your documents, financial data and credit reference files and this will be stored in a private area accessible only by Inclusive Innovations Inc. and to the extent that is necessary, the Relying Party .

This information may be disclosed to authorised Relying Parties through our credit referencing, fraud prevention, risk assessment and identification products. Personal Information in our possession shall only be used in accordance with this Policy Statement, in performing statistical analysis of users’ behaviour as a whole; and to help in the creation of anonymised statistical data which we may use at our discretion (including licensing to third parties).

Inclusive Innovations Inc. collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply:

Our data will be:

  1. Accurate and kept up-to-date;

  2. Collected fairly and for lawful purposes only;

  3. Processed by Inclusive Innovations Inc. within its legal and moral boundaries; and

  4. Protected against any unauthorized or illegal access by internal or external parties.

Our data will not be:

  1. Communicated informally;

  2. Transferred to organizations, states or countries that do not have adequate data protection policies; and

  3. Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities).

Inclusive Innovations Inc. Business Partners are encouraged to:

  1. Let people know which of their data is collected;

  2. Inform people about how Inclusive Innovations Inc. will process their data; and

  3. Inform people about who has access to their information.

Inclusive Innovations Inc. is the sole owner of the information collected on our Services.

Sharing of the Information

We may disclose any information we collect as follows:

  1. The Reporting Entity with whom you are establishing a relationship, applying for a financial product or service with and other similar organisations, or those that are nominated by you;

  2. Government entities and other external data providers that hold information on you in order to verify that the information provided by you is consistent with the records held by such entities;

  3. To financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your Inclusive Innovations Inc. account;

  4. To another user, when you sign up for Inclusive Innovations Inc.’s services via a referral link. The user that referred you may receive information indicating that you have enrolled with Inclusive Innovations Inc.. You may avoid this sharing by not using a referral link to enroll;

  5. To another user, when you sign up for an Inclusive Innovations Inc. shared account with that user;

  6. To Business Partners, affiliated companies and authorized service providers, we disclose Personal Information to as is necessary to provide our Services. These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. We do not rent, sell or otherwise disclose Personal Information about our online visitors with unaffiliated third parties for their own marketing use;

  7. With a non-affiliated third-party to access and transmit your personal and financial information from a relevant financial institution. You grant the third-party the right, power, and authority to access and transmit this information according to terms of their privacy policy;

  8. With other non-affiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:

    1. In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process; With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud; If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Inclusive Innovations Inc. or others; and

    2. In connection with, or during negotiations of, any merger, sale of Inclusive Innovations Inc.’s assets, financing or acquisition of all or a portion of our business to another company; and with your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information; and

  9. We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you. For example, we may share transaction zip codes and merchant names with third parties to improve our accuracy in geo-locating transactions and to improve the clarity of transaction descriptions.

Inclusive Innovations Inc. takes reasonable steps to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure.

Control of Your Personal Information

Information on the Inclusive Innovations Inc. Database

For a fee you may request to see what information Inclusive Innovations Inc. has about you. You can do so by contacting us via the email address on our website. You may also request to:

  • Change or correct any data Inclusive Innovations Inc. has about you; and

  • Express any concern you have about our use of your data.

Promotional Communications

You may opt out of receiving promotional emails and text messages from Inclusive Innovations Inc. by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, relating to your account or our ongoing business relations.

Location Information

If you initially consent to the collection of location information by Inclusive Innovations Inc. or the geo-mapping service within our mobile application, you may be able to subsequently stop this collection through your device operating system settings or through your online account settings. If either of these opt-out options are not available to you, then you may also disable location information by following the standard uninstall process to remove our mobile application from your device.


Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Social Sharing Features

Our Services include social sharing features for common social networks to let users share content. These features are served from third-party services that may serve their own cookies. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

You can control what information you share through privacy settings available on some social media sites. For more information about how you can customize your privacy settings and how third party social media sites handle your personally identifiable information, please refer to their privacy help guides, privacy policies and terms of use.

Analytics and Advertising Services Provided by Others

We may allow others to provide analytics services on our behalf and to serve advertisements on our behalf across the internet. These entities may use cookies, web beacons and other technologies to collect information. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit.

Third Party External Websites

We may provide links to third-party external websites. If you follow links to websites not affiliated or controlled by Inclusive Innovations Inc., you should review their privacy and security policies and other terms and conditions, as they may be different from ours. Inclusive Innovations Inc. does not guarantee and is not responsible for the privacy or security of these third-party external websites, or for any information represented in these websites.

Storage and Security


Inclusive Innovations Inc. takes reasonable precautions to protect your Personal Information. When you submit Personal Information via our Services, your information is protected both online and offline. Inclusive Innovations Inc. has implemented reasonable physical, technical and administrative security standards to protect Personal Information from loss, misuse, alteration or destruction.

All Relying Parties and agents are contractually bound to maintain the confidentiality of Personal Information and may not use the information for any unauthorized purpose.

Inclusive Innovations Inc. is committed to:

  1. Restricting and monitoring access to sensitive data;

  2. Developing transparent data collection procedures;

  3. Training employees in online privacy and security measures;

  4. Building secure networks to protect online data from cyber attacks; and

  5. Establishing data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.).

Only employees who need the information to perform a required process are granted access to personally identifiable information to the extent that is necessary. The computers and hardware in which Inclusive Innovations Inc. stores personally identifiable information are kept in a secure environment.

We follow best practice industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. When you enter sensitive information (bank credentials, credit and card number) you should always use encrypted secure socket layer technology (SSL).

Data Retention

When we receive information regarding the customers (“Customers”) of a Relying Party and from verification of Business Partners in order to perform our Services. We shall do as follows:

Information received from Relying Party

Inclusive Innovations Inc. will obtain information from Relying Parties. Inclusive Innovations Inc. will use this data to verify the information provided by a Data Subject. Subsequent to the verification process, Inclusive Innovations Inc. will dispose of the data provided by the Relying Party.

Information Received From Data Subjects

Inclusive Innovations Inc. will collect information from Data Subjects on behalf of Relying Parties. Inclusive Innovations Inc. may use this information to query a Relying Party and verify the information against data provided by the Relying Party.

Inclusive Innovations Inc. may provide a copy of the information obtained from a Data Subject on behalf of a Relying Party to a Reporting Entity if required in accordance with identity verification reporting. Inclusive Innovations Inc. may retain information collected from the Data Subject for a brief period to enable auditing, after which Inclusive Innovations Inc. will remove the data from its systems.

Information Received From Reporting Entities

Inclusive Innovations Inc. will collect a Data Subject's information from Reporting Entity. Inclusive Innovations Inc. may use this information to query Data Subject and verify the information against data provided by a Reporting Entity. The comparison may be done by Inclusive Innovations Inc. or the Reporting Entity.

Inclusive Innovations Inc. may retain information collected from Reporting Entities for the period allowed based on the statute of limitation of the jurisdiction or as is necessary to enable auditing. Following the brief period, Inclusive Innovations Inc. will remove the data from its systems.

Updates to this End-User Privacy Policy

Our End-User Privacy Policy may change from time to time and all updates will be posted on this page. We encourage you to periodically review this Privacy Policy so that you will be aware of our privacy practices. This End-User Privacy Policy was last updated in January 2020.

If you feel that Inclusive Innovations Inc. are not abiding by this Privacy Statement, you should contact us immediately via email at