Privacy policy
PRIVACY POLICY
Netty & Nature
Last updated: 24 July 2026
DRAFT — for attorney review before publishing. Remove this line before the policy goes live.
1. WHO WE ARE
Netty & Nature ("we", "us", "our") operates this store and website, including all related content, features, tools, products and services (the "Services").
We are the data controller in respect of the personal information described in this Privacy Policy, for the purposes of the Data Protection Act 2012 (Act 843) of the Republic of Ghana. Netty & Nature is a registered trading name of a company incorporated under the laws of the Republic of Ghana; our full legal and registration details are set out in Section 16 (Contact Us).
Our Services are hosted and powered by Shopify Inc., which processes personal information on our behalf and, in certain respects, as an independent controller. This is explained further in Section 8.
If there is any conflict between our Terms of Service and this Privacy Policy, this Privacy Policy governs in respect of the collection, processing, and disclosure of your personal information.
Contact details for data protection matters:
Data Protection Contact, Netty & Nature
La-Bawaleshi Road, GA-414-4417, Accra, Ghana
Email: hello@nettyandnature.com
Telephone: +233 53 998 1261
2. YOUR RIGHTS UNDER GHANAIAN LAW
If you are in Ghana, the Data Protection Act 2012 (Act 843) gives you the following rights in respect of your personal information. These rights are not conditional on where you live or what you have purchased.
Right of access. You may request confirmation of whether we hold personal information about you, and a copy of that information.
Right to correction. You may request that we correct personal information that is inaccurate, misleading, incomplete, or out of date.
Right to erasure. You may request that we delete or destroy personal information we hold about you, where we no longer have a lawful basis to retain it.
Right to object to processing. You may object to our processing of your personal information, including processing for direct marketing purposes.
Right to prevent processing for direct marketing. You may require us to stop using your personal information for marketing at any time, and we will do so without charge.
Right to complain. You may lodge a complaint with the Data Protection Commission of Ghana (see Section 12).
To exercise any of these rights, contact us using the details in Section 1. We will respond within the period required by Act 843. We may need to verify your identity before acting on a request. We will not charge you for exercising your rights except where permitted by law, and we will never treat you less favourably for having done so.
If you are located outside Ghana, you may hold additional or different rights under the law of your own jurisdiction, and we will honour those rights where they apply to you.
3. PERSONAL INFORMATION WE COLLECT
"Personal information" means information that identifies you or can reasonably be linked to you. It does not include information that has been anonymised or de-identified so that it can no longer be linked to you. Depending on how you interact with the Services, we may collect and process the following:
Contact details — your name, billing address, shipping address, telephone number, and email address.
Payment information — payment card details, mobile money details, financial account information, transaction records, form of payment, and payment confirmations. We do not store full payment card numbers on our systems; these are processed directly by our payment providers.
Account information — your username, password, security questions, preferences, and settings.
Transaction information — items you view, add to your cart or wishlist, purchase, return, exchange, or cancel, and your order history.
Communications with us — the content of messages you send us, including customer support enquiries, product questions, and feedback.
Device and technical information — your device type, browser, network connection, IP address, and other unique identifiers.
Usage information — how and when you navigate and interact with the Services.
Sensitive personal information. Some of our products are formulated for particular skin concerns. If you voluntarily tell us about a skin condition, allergy, sensitivity, or other health matter — for example when asking for a product recommendation or reporting a reaction — that information is special personal data under Act 843. We process it only with your explicit consent, only for the purpose you provided it, and we do not use it for marketing or profiling. You may withdraw that consent at any time.
4. WHERE WE GET YOUR INFORMATION
Directly from you — when you create an account, place an order, contact us, subscribe to communications, or otherwise provide information.
Automatically through the Services — from your device when you visit or use the Services, including through cookies and similar technologies.
From our service providers — where we engage them to provide technology or services and they collect or process information on our behalf.
From our partners and other third parties — including delivery partners, payment providers, and marketing platforms.
5. HOW WE USE YOUR INFORMATION AND OUR LAWFUL BASIS
Under Act 843 we must have a lawful basis for processing your personal information. Our purposes and bases are as follows:
To provide the Services and fulfil your order. Processing payments, arranging delivery, managing returns and exchanges, maintaining your account, and sending you order and account notifications. Lawful basis: performance of our contract with you.
To communicate with you. Responding to enquiries, providing customer support, and maintaining our relationship with you. Lawful basis: performance of our contract with you, and our legitimate interests in operating our business.
To improve the Services. Understanding how customers use our store so we can improve products, content, and the shopping experience. Lawful basis: our legitimate interests, balanced against your rights.
Marketing and promotional communications. Sending you news, offers, product launches, and content by email, SMS, or post, and showing you advertisements for our products. Lawful basis: your consent. We ask for your consent before adding you to our marketing list. You may withdraw it at any time using the unsubscribe link in any message, or by contacting us. Withdrawing marketing consent does not affect service messages about orders you have placed.
Security and fraud prevention. Authenticating your account, securing payments, and detecting, investigating, or acting on fraudulent, unlawful, or malicious activity. Lawful basis: our legitimate interests in protecting our business and customers, and compliance with legal obligations.
Product safety. Where you report an adverse reaction to a product, investigating the report, contacting you about it, and meeting our obligations to the Ghana Food and Drugs Authority. Lawful basis: compliance with a legal obligation, and your explicit consent where health information is involved.
Legal and regulatory compliance. Meeting obligations under Ghanaian tax, company, consumer protection, and cosmetics regulation, responding to lawful requests from authorities, and establishing or defending legal claims. Lawful basis: compliance with a legal obligation, and our legitimate interests.
6. WHO WE SHARE YOUR INFORMATION WITH
We do not sell your personal information. We may disclose it in the following circumstances:
Service providers — Shopify and other providers who perform services on our behalf, including payment processing, IT and hosting, data analytics, customer support, cloud storage, order fulfilment, and delivery. These providers may only process your information on our instructions and must protect it.
Payment providers — banks, card processors, and mobile money operators, to process your payment.
Delivery partners — couriers and logistics providers, to deliver your order.
Marketing partners — where you have consented, platforms that help us deliver advertising and communications. These partners handle your information in accordance with their own privacy notices.
Regulators and authorities — including the Ghana Revenue Authority, the Ghana Food and Drugs Authority, and the Data Protection Commission, where required by law.
Professional advisers — our lawyers, accountants, and auditors, where necessary and subject to confidentiality.
In connection with a business transaction — such as a merger, acquisition, restructure, or insolvency, where your information may transfer as part of the business. We will notify you if this materially affects how your information is handled.
Where you direct us to — for example when you use a social media widget or login integration.
7. TRANSFERS OF YOUR INFORMATION OUTSIDE GHANA
Our store is hosted by Shopify, and some of our service providers operate outside Ghana. This means your personal information may be transferred to, stored in, and processed in countries other than Ghana, including Canada, the United States, and the European Union.
Section 18 of the Data Protection Act 2012 permits such transfers where appropriate safeguards are in place. Before transferring your information outside Ghana we satisfy ourselves that: the recipient is bound by contractual terms requiring a standard of protection comparable to that required under Act 843; and the transfer is necessary for the performance of our contract with you, or is made with your consent, or is otherwise permitted under Act 843.
By placing an order or creating an account, you acknowledge that your information will be transferred and processed as described in this section. If you would prefer your information not to be transferred outside Ghana, please contact us before placing an order — though in most cases we will not be able to provide the Services without such transfer.
8. OUR RELATIONSHIP WITH SHOPIFY
The Services are hosted by Shopify Inc. Information you submit through the Services is transmitted to and stored by Shopify in order to provide and improve the Services.
In addition, we use certain Shopify features that draw on data about your interactions with our store and with other merchants using Shopify. In respect of those features, Shopify acts as a controller of your personal information in its own right and is responsible for that processing, including for responding to requests you make about it.
To understand how Shopify uses your personal information and what rights you may have in respect of that use, see the Shopify Consumer Privacy Policy at privacy.shopify.com.
9. HOW LONG WE KEEP YOUR INFORMATION
We keep personal information only for as long as we need it. Our standard retention periods are:
| Information | Retention period |
|---|---|
| Order and transaction records | 6 years from the date of the transaction, to meet obligations under the Income Tax Act 2015 (Act 896) |
| Account information | For as long as your account is active, and 12 months after your last activity, after which we delete or anonymise it |
| Marketing contact details | Until you withdraw consent, or after 24 months of no engagement, whichever is earlier |
| Customer service correspondence | 3 years from the date of the last message |
| Abandoned cart data | 90 days |
| Adverse reaction and product safety reports | 10 years, as required for cosmetics safety records |
| Website analytics and usage data | 26 months |
Where we are required to retain information for longer by law, or need it to establish or defend a legal claim, we will keep it for that longer period and then delete it.
10. HOW WE PROTECT YOUR INFORMATION
We take reasonable technical and organisational measures to protect your personal information against loss, misuse, and unauthorised access, disclosure, alteration, or destruction. These include restricted access controls, secure payment processing, and staff confidentiality obligations.
No system is completely secure and information transmitted over the internet is never entirely risk-free. We recommend you do not send sensitive or confidential information to us through unsecured channels.
If a data breach occurs that is likely to affect your rights, we will notify you and the Data Protection Commission as required by Act 843.
You are responsible for keeping your account credentials secure. Do not share your username or password with anyone.
11. COOKIES AND SIMILAR TECHNOLOGIES
We use cookies and similar technologies to operate the store, remember your preferences, understand how the Services are used, and — where you consent — to deliver advertising. You can control cookies through your browser settings and through the cookie banner on our website. Blocking some cookies may affect how parts of the store work.
12. CHILDREN
The Services are not intended for children. In Ghana, a child is a person under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has given us their personal information, please contact us and we will delete it.
13. COMPLAINTS
If you are unhappy with how we have handled your personal information, please contact us first using the details in Section 1. We take complaints seriously and will investigate. If you are not satisfied with our response, you have the right to complain to:
Data Protection Commission of Ghana
Website: dataprotection.org.gh
If you are located outside Ghana, you may also have the right to complain to the data protection authority in your own country.
14. THIRD PARTY WEBSITES
The Services may link to websites operated by others. We are not responsible for the privacy practices, security, or content of those sites. Please review their own privacy policies before providing them with your information.
15. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices or for operational, legal, or regulatory reasons. We will post the updated policy on this website and change the "Last updated" date above. Where a change materially affects how we use your personal information, we will give you notice and, where required, ask for your consent.
16. CONTACT US
For any question about this Privacy Policy or to exercise your rights:
Nerture Labs Skincare Ltd. (Registration No. C0066500907), trading as Netty & Nature
La-Bawaleshi Road, GA-414-4417, Accra, Ghana
Email: hello@nettyandnature.com
Telephone: +233 53 998 1261