Privacy Notice

This Privacy Notice explains how Be Free, Inc. ("we", "our", "us") collects, uses, stores, and protects personal data in alignment with the Ghana Data Protection Act, 2012 (Act 843) and other applicable regulations.

1. Who we are

Be Free, Inc. is a behavioral finance facilitation company operating under the domain impulserift.com. We design habit-building interventions for individuals and organizations across Ghana. Our registered correspondence address is 154 Crane Meadow Road Marlborough, Massachusetts 01752. You can contact us at [email protected] or +233 50 688 2041 for all privacy-related inquiries.

2. Personal data we collect

We collect personal data directly from you, from your organization, and through our digital properties. Depending on the engagement, this may include:

  • Identification details such as full name, job title, and organization.
  • Contact information including phone numbers, email addresses, and preferred communication channels.
  • Financial behavior insights shared voluntarily during workshops, surveys, or reflective exercises. We anonymize or pseudonymize this data whenever possible.
  • Technical data such as device type, browser, IP address, and engagement metrics collected through functional and analytical cookies.

We do not intentionally collect special categories of personal data unless you provide explicit consent for a defined purpose.

3. Purpose and lawful basis

We process personal data for the following purposes:

  • Service delivery: Facilitate workshops, coaching, diagnostics, and follow-ups. Lawful basis: performance of a contract or legitimate interest.
  • Communication: Respond to inquiries, share program materials, and provide post-session resources. Lawful basis: consent or legitimate interest.
  • Improvement and analytics: Analyze anonymized engagement data to enhance our offerings. Lawful basis: legitimate interest.
  • Legal compliance: Maintain records required by Ghanaian authorities and fulfill legal obligations. Lawful basis: legal obligation.

Where we rely on consent, you may withdraw it at any time by contacting us.

4. Data sharing and transfers

We do not sell personal data. We may share personal data with trusted partners strictly for service delivery, including:

  • Facilitators and consultants under confidentiality agreements.
  • Secure cloud service providers that host our data within jurisdictions offering adequate protection.
  • Legal or regulatory authorities when required by law.

When transferring data outside Ghana, we conduct risk assessments and use contractual safeguards compatible with Act 843.

5. Data retention

We retain personal data only as long as necessary for the purposes described above. Typically, this means:

  • Contact inquiries: up to 12 months.
  • Workshop and coaching records: up to 24 months unless a longer period is agreed for continuity.
  • Financial behavior summaries: anonymized within 90 days of program completion unless participants request otherwise.

We securely delete or anonymize data once retention periods expire.

6. Your rights

Under the Ghana Data Protection Act, you have rights to:

  • Request access to your personal data and receive a copy in a usable format.
  • Request correction or update of incomplete or inaccurate data.
  • Request deletion of data where processing is no longer necessary or consent is withdrawn.
  • Object to processing based on legitimate interests and request restriction where applicable.
  • Lodge a complaint with the Data Protection Commission of Ghana.

To exercise your rights, contact [email protected]. We will respond within 21 days as mandated by law.

7. Security measures

We implement physical, organizational, and technical controls including access restrictions, encryption, secure storage, and regular policy reviews. Staff and contractors undergo confidentiality training and sign binding agreements before handling data.

8. Updates to this notice

We review this Privacy Notice annually or when regulatory guidance changes. Updates will be published on impulserift.com with a revised effective date. Significant changes will be communicated directly to active clients.

Last updated: January 18, 2026

9. Contact us

For privacy questions, requests, or concerns, please email [email protected] or call +233 50 688 2041. We can also facilitate meetings with the Ghana Data Protection Commission upon request.