1. Who is the controller
The controller of personal data collected through toivoo.com and through our engagement work is Toivo Investment, 6 Scarlet Avenue, New Achimota, Accra, Ghana. Our data-protection contact is contact@toivoo.com.
2. What we collect
From visitors to the site:
- Information you submit on the inquiry form (name, email, phone, message, country of residence, budget range, timeline).
- Server logs (IP address, user agent, referrer, timestamps) — retained for 30 days for security purposes.
From clients on engagement:
- Identification documents required for KYC under Ghana’s Anti-Money Laundering Act and our partner law firm’s onboarding requirements.
- Bank, payment, and tax-residency information needed to operate the engagement.
- Communications and project records for the duration of the engagement and statutory retention periods.
3. How we use it
- To respond to your inquiry, confirm fit, and produce a written investment or build brief.
- To execute the engagement we sign with you (sourcing, vetting, acquisition, build management, property management, reporting).
- To comply with anti-money-laundering, tax, and real-estate-licensing obligations in Ghana.
- To send the quarterly statement and any other reports specified in the engagement letter.
We do not use your data for marketing without your explicit consent. We do not sell or rent your data to anyone.
4. Legal basis
Where Ghana’s Data Protection Act 2012 and / or the EU GDPR apply, we rely on these legal bases:
- Contract — to perform the engagement we have signed with you.
- Legal obligation — for KYC, anti-money-laundering, tax, and licensing compliance.
- Legitimate interests — for security logs, replying to unsolicited inquiries, and improving the website (we keep this minimal).
- Consent — for any optional newsletter or marketing communications.
6. How long we keep it
- Inquiry-form submissions: 24 months unless you become a client.
- Server logs: 30 days.
- Client engagement records: 7 years after engagement close, the standard for tax and AML retention.
- KYC files: 5 years after engagement close, per Ghanaian law.
After these periods, we delete or irreversibly anonymise the data.
7. Your rights
- Access — request a copy of the personal data we hold about you.
- Correction — have inaccurate data corrected.
- Erasure — have your data deleted, subject to our statutory retention obligations.
- Objection — object to processing based on legitimate interests.
- Portability — receive your data in a machine-readable format where applicable.
- Withdraw consent — for any processing based on consent.
To exercise any of these rights, email contact@toivoo.com. We respond inside 30 days. If you are unsatisfied, you may complain to the Ghana Data Protection Commission, or to your local supervisory authority where one applies.
9. Contact
Email contact@toivoo.com or write to: Toivo Investment, 6 Scarlet Avenue, New Achimota, Accra, Ghana.