Effective date: 19 March 2026
1. Who We Are
Savannah Impact Advisory Ltd ("SIA", "we", "us", "our") is a limited liability company incorporated under the laws of Ghana and licensed by the Securities and Exchange Commission (SEC) of Ghana. Our registered office is at No. 22 Justice E. P Sowah Avenue, East Legon, Accra, Ghana.
This Privacy Policy explains how we collect, use, disclose, and protect personal data when you visit siaghana.com (the "Site") or interact with us. We are committed to protecting your privacy and handling your data responsibly, in accordance with the Ghana Data Protection Act, 2012 (Act 843) and, where applicable, the EU General Data Protection Regulation (GDPR).
2. Data We Collect
We may collect the following categories of personal data:
(a) Identity and contact data: name, email address, phone number, job title, and organisation, provided when you complete a contact form, funding application, or subscribe to communications.
(b) Usage data: information about how you use the Site, including your IP address, browser type and version, operating system, referring URLs, pages viewed, and time spent on each page, collected automatically via cookies and analytics tools.
(c) Communication data: the content of any messages, emails, or enquiries you send us.
(d) Financial and investment data: where provided through a funding application or investor engagement process, information about your organisation, fund strategy, investment track record, and financial position.
3. How We Collect Data
We collect data: (a) directly from you when you complete forms on the Site, apply for funding, contact us, or attend our events; (b) automatically via cookies, web beacons, and analytics technologies when you browse the Site; and (c) from third parties, such as referrals, professional networks, or publicly available sources, where relevant to an investment or advisory engagement.
4. How We Use Your Data
We use your personal data to: (a) respond to your enquiries and manage our communications with you; (b) process and evaluate funding applications from fund managers and institutional investors; (c) provide investment advisory and fund management services; (d) improve and maintain the Site, monitor usage patterns, and diagnose technical problems; (e) send you information about SIA's activities, events, or the Ci Gaba Fund where you have consented or where we have a legitimate interest; (f) comply with our legal and regulatory obligations as an SEC-licensed investment advisor; and (g) protect the rights, property, or safety of SIA, our clients, or the public.
5. Legal Basis for Processing
We process your personal data on the following legal bases:
(a) Consent: where you have given us explicit consent (e.g., subscribing to communications, accepting non-essential cookies).
(b) Contractual necessity: where processing is required to fulfil a contract with you or to take pre-contractual steps at your request.
(c) Legal obligation: where we are required to process your data to comply with applicable laws and regulations.
(d) Legitimate interests: where we have a legitimate interest that is not overridden by your rights, such as improving our services, managing our investor relationships, and operating our business.
6. Sharing Your Data
We do not sell your personal data to third parties. We may share your data with: (a) service providers who process data on our behalf (e.g., website hosting, analytics, email delivery) under appropriate data processing agreements; (b) professional advisors, including lawyers, auditors, and consultants, bound by confidentiality obligations; (c) regulatory authorities, government bodies, or law enforcement where required by law; and (d) potential investors, co-investors, or fund managers in the context of a specific transaction or engagement, with your knowledge.
7. International Transfers
Some of our service providers may process your data outside of Ghana. Where this occurs, we take steps to ensure that appropriate safeguards are in place, including the use of standard contractual clauses or other mechanisms recognised under applicable data protection law.
8. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. The retention period depends on the type and context of the data. In general: contact and communication data is held for up to 3 years after your last interaction with us; investment application data is held for up to 7 years for regulatory compliance; and analytics data is held in aggregated or anonymised form indefinitely.
9. Your Rights
Under the Ghana Data Protection Act and, where applicable, the GDPR, you have the right to: (a) access the personal data we hold about you; (b) request correction of inaccurate or incomplete data; (c) request erasure of your data where there is no compelling reason for continued processing; (d) object to or restrict processing in certain circumstances; (e) data portability where processing is based on consent or contract; and (f) withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, please contact us at info@siaghana.com. We will respond within 30 days of receipt.
10. Cookies
We use cookies and similar tracking technologies on the Site. For full details of the cookies we use, their purposes, and how to manage your preferences, please see our Cookie Policy.
11. Security
We implement appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, disclosure, alteration, or destruction. However, the transmission of data over the internet is not completely secure, and we cannot guarantee the security of data transmitted to the Site. Any transmission is at your own risk.
12. Children
The Site is not directed at children 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 and we will promptly delete it.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post the revised policy on this page with an updated effective date. We encourage you to review this policy periodically.
14. Contact and Complaints
If you have any questions, concerns, or complaints about how we handle your personal data, please contact our Data Protection Officer at: Savannah Impact Advisory Ltd, No. 22 Justice E. P Sowah Avenue, East Legon, Accra, Ghana. Email: info@siaghana.com.
If you are not satisfied with our response, you have the right to lodge a complaint with the Data Protection Commission of Ghana or, where the GDPR applies, with your local supervisory authority.
