This Privacy Policy explains how Tunnelo collects, uses, stores, and protects your personal data when you use our website, the Tunnelo SU SMS & USSD platform, or engage us for software development services. We are committed to handling your data responsibly and in compliance with applicable data protection law.
Data Controller: Tunnelo
Location: Accra, Ghana
Contact: hello@tunnelo.click
Tunnelo is the data controller for personal data processed through this website and our services. Where we process data on behalf of our clients (for example, contact lists uploaded to the SMS platform), we act as a data processor for that client's data.
| Data | Purpose | Legal Basis |
|---|---|---|
| Name, email address, company name, project description | To respond to project enquiries submitted via the contact form | Your consent (submitting the form) |
| Browser type, device type, page views (anonymised) | To understand how the site is used and improve it | Legitimate interest |
| Data | Purpose | Legal Basis |
|---|---|---|
| Name, email address, phone number | Account registration and authentication | Performance of contract |
| Business name and type | Account management and compliance | Performance of contract |
| Contact lists (phone numbers) uploaded by you | To deliver SMS messages to the recipients you designate | Performance of contract; you are responsible for the lawful basis for processing your recipients' data |
| Message content composed by you | To transmit SMS/USSD messages on your behalf | Performance of contract |
| Payment information (billing details) | To process SMS bundle purchases and other payments | Performance of contract; legal obligation |
| SMS delivery logs and campaign reports | To provide delivery reporting and platform analytics | Performance of contract; legitimate interest |
| USSD menu configurations | To host and serve your USSD sessions | Performance of contract |
| Data | Purpose | Legal Basis |
|---|---|---|
| Name, email, phone number, company information | To manage the client relationship and project delivery | Performance of contract |
| Project requirements and technical specifications | To deliver the agreed software product | Performance of contract |
| Payment and billing information | To invoice for services rendered | Performance of contract; legal obligation |
| Access credentials to client systems (where required for development) | To access environments necessary for development and deployment | Performance of contract — handled under strict confidentiality |
When you upload a contact list to the Tunnelo SU platform, you are uploading third-party personal data (phone numbers and names of your recipients). As the data controller for that data, you are responsible for ensuring you have a lawful basis to process that data and to send communications to those individuals.
Tunnelo processes recipient data solely to deliver the messages you instruct us to send. We do not use recipient contact data for any purpose other than message delivery and delivery reporting. We do not sell or share recipient data with any third party except as required to route messages through mobile network operators.
You must ensure that:
Payments on the Tunnelo SU platform are processed by third-party payment processors. We do not store full payment card numbers on our systems. The following billing data is retained:
Our payment processors are subject to their own privacy policies and PCI-DSS compliance requirements. By making a payment, you acknowledge that your payment data will be processed by these providers.
We do not sell your personal data. We share data only in the following circumstances:
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or alteration, including:
No system is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify affected users and the relevant authorities as required by law.
Under the Ghana Data Protection Act, 2012 (Act 843), you have the following rights with respect to your personal data:
To exercise any of these rights, email us at hello@tunnelo.click. We will respond within 30 days. We may need to verify your identity before processing your request.
You also have the right to lodge a complaint with the Data Protection Commission of Ghana.
Our website uses minimal cookies essential to its operation. We do not use advertising trackers, third-party analytics cookies, or cross-site tracking technologies.
The Tunnelo SU platform uses session cookies to keep you logged in during your session. These are deleted when you close your browser or log out.
Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately at hello@tunnelo.click and we will delete it promptly.
Where personal data is transferred to cloud infrastructure or third-party service providers outside Ghana, we ensure appropriate safeguards are in place — including contractual data processing agreements — to provide an equivalent level of data protection.
We review this Privacy Policy on the first day of each month. The "Last updated" date at the top of this page always reflects the first day of the current month. Material changes will be communicated to registered users via email where reasonably practicable.
Your continued use of our services after a policy update constitutes acceptance of the revised policy.
For privacy-related questions, data subject requests, or complaints:
If you are not satisfied with our response, you may contact the Data Protection Commission of Ghana.