Privacy Policy

1. Introduction

Welcome to BEX, a digital building-materials marketplace and commerce platform operated by Mjay Building Hardware Retail and Supply ("Mjay", "we", "us", or "our").

BEX is designed to make the buying, selling, sourcing and planning of building-material purchases more convenient by connecting customers, building-material suppliers, traders, delivery providers and other participants within the construction and building-materials ecosystem.

The BEX platform may facilitate, among other things:

• the purchase of building materials;
• delivery of purchased products;
• peer-to-peer trading and listings;
• forward-purchase arrangements;
• savings or purchase-planning features;
• customer and supplier interactions;
• order and transaction management;
• payment processing;
• notifications and customer support; and
• other services introduced through the BEX platform from time to time.

This Privacy Policy explains how we collect, use, disclose, store, protect and otherwise process personal information when you use the BEX mobile application, website, services or related platforms.

By using BEX, you acknowledge that you have read and understood this Privacy Policy.

Where applicable law requires your consent to a particular processing activity, we will obtain that consent separately.

2. Who This Policy Applies to

This Privacy Policy applies to all individuals and organisations who interact with BEX, including:

2.1 Customers and Buyers

Individuals or organisations who use BEX to search for, purchase, reserve, save towards, or otherwise acquire building materials and related products.

2.2 Sellers and Suppliers

Individuals, businesses, merchants, manufacturers, distributors, retailers and other parties who offer products through BEX.

2.3 Peer-to-Peer Users

Users who use BEX to list, offer, purchase or trade products directly with other users.

2.4 Forward-Purchase and Savings Users

Users who participate in BEX programmes that allow them to make payments over time or plan and accumulate funds toward future purchases.

2.5 Delivery and Logistics Partners

Third-party delivery providers, drivers, logistics companies and other service providers who may receive information necessary to fulfil an order.

2.6 Business and Institutional Customers

Companies, contractors, developers, professionals and other organisations using BEX for procurement or building-material purchases.

2.7 Visitors and Prospective Users

Individuals who visit BEX websites, social-media pages, promotional platforms or other BEX services without creating an account.

2.8 Other Stakeholders

This Policy may also apply to individuals whose information is provided to us in connection with an order or service, including authorised representatives, employees of business customers, designated recipients and customer-support contacts.

3. Information We Collect

We collect information that is necessary to provide, operate, secure and improve BEX.

The information we collect depends on how you use the platform.

3.1 Information You Provide Directly

When you create an account or use BEX, we may collect:

• full name;
• username;
• phone number;
• email address;
• password or authentication credentials;
• residential, business or delivery address;
• billing information;
• organisation or company name;
• business registration or verification information where applicable;
• profile photograph, where you choose to provide one;
• preferred delivery information;
• communication preferences;
• customer-service information;
• information contained in messages or enquiries sent to us; and
• other information you voluntarily provide.

We may also collect information you provide when creating product listings, including:

• product descriptions;
• product photographs;
• product quantity;
• price;
• location;
• availability;
• product specifications; and
• other information relating to a listing.

4. Order and Transaction Information

When you purchase or sell products through BEX, we may collect information relating to the transaction, including:

• products purchased or listed;
• quantities;
• prices;
• order numbers;
• transaction dates and times;
• delivery details;
• payment status;
• refunds;
• cancellations;
• discounts, promotions or applicable fees;
• seller and buyer information;
• transaction history; and
• communications relating to a transaction.

We use this information to process transactions, maintain records, provide customer support, resolve disputes and comply with applicable legal and regulatory requirements.

5. Payment Information

BEX may facilitate payments through third-party payment service providers.

Depending on the payment method used, payments may involve:

• mobile money;
• bank payments;
• debit or credit cards;
• electronic payment services; or
• other payment methods made available through BEX.

Where payment processing is provided by a third party, your payment information may be processed directly by that provider in accordance with its own privacy policy and security practices.

Where possible, BEX does not unnecessarily retain complete payment-card information.

We may retain transaction-related information such as:

• payment status;
• transaction reference;
• amount paid;
• payment date;
• payment method;
• refund status; and
• other information necessary for accounting, reconciliation, customer service and dispute resolution.

6. Forward Purchase and Savings Information

Where BEX offers forward-purchase or savings-related services, we may collect information necessary to administer those services.

This may include:

• target product or purchase;
• target amount;
• contributions or payments made;
• payment dates;
• outstanding balance;
• purchase status;
• fulfilment information;
• transaction references; and
• related communications.

Such information will be used to administer the relevant programme, maintain accurate financial records, provide account information, facilitate fulfilment and prevent fraud or misuse.

7. Information From Device and App Usage

When you use BEX, we may automatically collect certain technical information, such as:

• device type;
• operating system;
• app version;
• unique app or device identifiers where permitted and necessary;
• IP address;
• network information;
• language and regional settings;
• crash reports;
• diagnostic information;
• log information;
• session information;
• information about how features of the app are used; and
• information relating to app performance and security.

We use this information to:

• operate and secure the app;
• identify technical problems;
• improve performance;
• prevent fraud and abuse;
• understand how users interact with BEX; and
• improve our products and services.

We will not collect device information that is unnecessary for the operation of BEX.

8. Location Information

BEX may use location information where it is necessary to provide a particular feature, such as:

• identifying an approximate delivery area;
• assisting with delivery;
• identifying nearby sellers or products;
• improving delivery coordination; or
• providing location-based services.

Where BEX requires access to precise device location, we will request permission where required by the relevant operating system or applicable law.

You may control location permissions through your device settings.

Unless expressly disclosed and permitted, BEX will not use precise location information for unrelated purposes.

9. Contacts, Camera, Photos and Other Device Permissions

Certain BEX features may request access to device functions such as:

• camera;
• photo library;
• notifications;
• contacts; or
• other device functionality.

For example, camera or photo access may be required if you choose to upload photographs of products for a listing.

We will only request permissions that are reasonably necessary for the relevant feature.

Where a permission is optional, you may decline it, although doing so may prevent you from using the associated feature.

10. Communications

If you contact BEX through:

• the app;
• email;
• telephone;
• SMS;
• social media;
• customer support;
• messaging features; or
• other communication channels,

we may retain information necessary to respond to you and maintain a record of the interaction.

Where BEX provides messaging between buyers and sellers, information necessary to facilitate the transaction may be made available to the relevant parties.

Users should not share passwords, payment credentials, identity documents or other highly sensitive information through ordinary messaging channels unless specifically requested through an authorised BEX process.

11. How We Use Personal Information

We may use personal information for the following purposes:

11.1 Providing BEX Services

To:

• create and manage accounts;
• process orders;
• facilitate purchases and sales;
• process forward purchases;
• facilitate delivery;
• manage listings;
• process payments;
• provide customer support; and
• provide other services requested by users.

11.2 Account Management

To:

• authenticate users;
• maintain account security;
• verify accounts where necessary;
• communicate account information; and
• administer user preferences.

11.3 Payments and Financial Administration

To:

• process transactions;
• reconcile payments;
• issue refunds;
• maintain financial records;
• administer fees and commissions; and
• detect suspicious transactions.

11.4 Security and Fraud Prevention

To:

• prevent fraud;
• detect suspicious activity;
• investigate abuse;
• protect accounts;
• protect BEX systems;
• enforce our terms and policies; and
• protect users and other stakeholders.

11.5 Customer Support

To:

• respond to enquiries;
• resolve complaints;
• investigate disputes;
• provide order updates; and
• improve customer-service operations.

11.6 Product and Service Improvement

We may use aggregated or appropriately de-identified information to understand:

• purchasing patterns;
• product demand;
• platform performance;
• feature usage;
• customer preferences; and
• marketplace trends.

11.7 Communications and Marketing

Subject to applicable law and your preferences, we may use contact information to provide:

• service notifications;
• order updates;
• promotional communications;
• product announcements;
• offers;
• BEX news; and
• information about related services.

You may opt out of promotional communications at any time.

Service-related communications may continue where necessary to operate your account or fulfil a transaction.

11.8 Legal and Regulatory Compliance

We may process and retain information where necessary to:

• comply with applicable laws;
• respond to lawful requests;
• meet accounting and tax requirements;
• prevent fraud;
• resolve disputes;
• establish or defend legal claims; or
• protect our legal rights.

12. Information We Share

We do not sell personal information to third parties for their independent marketing purposes.

We may share information where reasonably necessary to operate BEX.

12.1 Sellers and Buyers

Where necessary to complete a transaction, relevant information may be shared between buyers and sellers.

For example, a seller may need a buyer's name and delivery information to fulfil an order.

Similarly, a buyer may receive information about the seller or supplier relevant to the transaction.

Users should understand that information voluntarily provided in a public product listing may be visible to other users.

13. Delivery and Logistics Partners

Where an order requires delivery, we may provide relevant information to authorised delivery or logistics partners.

This may include:

• recipient name;
• telephone number;
• delivery address;
• order information;
• delivery instructions; and
• information necessary to complete the delivery.

Delivery partners may only use such information for authorised delivery and related purposes.

14. Payment and Financial Service Providers

We may share relevant information with payment processors, financial institutions and other authorised payment partners where necessary to:

• process payments;
• verify transactions;
• prevent fraud;
• process refunds;
• reconcile payments; and
• provide payment-related services.

These providers may process information according to their own privacy policies.

15. Technology and Service Providers

BEX may use third-party providers for services such as:

• cloud hosting;
• database management;
• payment processing;
• analytics;
• communications;
• SMS and email delivery;
• customer support;
• authentication;
• cybersecurity;
• crash reporting;
• software development and maintenance; and
• other technology services.

These providers may have access to information only to the extent reasonably necessary to perform services for BEX and subject to appropriate contractual or legal protections.

16. Business Transfers

If Mjay Building Hardware Retail and Supply or the BEX business is involved in:

• a merger;
• acquisition;
• restructuring;
• financing;
• sale of assets;
• transfer of ownership; or
• similar corporate transaction,

personal information may be transferred as part of that transaction, subject to applicable law and appropriate privacy protections.

17. Legal Disclosures

We may disclose information where required or permitted by law, including where necessary to:

• comply with a court order;
• respond to a lawful government request;
• investigate suspected fraud;
• prevent illegal activity;
• protect the safety of users;
• protect BEX's rights or property; or
• establish, exercise or defend legal claims.

18. Data Security

We take reasonable technical and organisational measures to protect personal information against:

• unauthorised access;
• loss;
• misuse;
• alteration;
• disclosure;
• destruction; and
• other forms of unauthorised processing.

Security measures may include:

• access controls;
• authentication mechanisms;
• encryption where appropriate;
• secure transmission protocols;
• system monitoring;
• backups;
• employee access controls; and
• security testing and maintenance.

However, no electronic system or internet transmission can be guaranteed to be completely secure.

Users are responsible for keeping their account credentials confidential and should notify BEX promptly if they believe their account has been compromised.

19. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law.

The retention period may depend on:

• the nature of the information;
• the purpose for which it was collected;
• whether an account remains active;
• transaction and accounting requirements;
• legal obligations;
• dispute-resolution requirements;
• fraud-prevention requirements; and
• legitimate business requirements.

When personal information is no longer required, we will take reasonable steps to delete, anonymise or securely dispose of it.

Certain transaction, financial, tax, accounting or legal records may need to be retained for longer periods where required by law.

20. Account Deletion

Users may request deletion of their BEX account and associated personal information through:

• Email: send a deletion request from your registered email or phone number to info@bexgh.com

Upon receiving a valid deletion request, we will process the request in accordance with applicable law and our retention obligations.

Where information must be retained for legal, regulatory, fraud-prevention, accounting or dispute-resolution purposes, that information may be retained for the required period and protected accordingly.

Account deletion may also result in the loss of access to:

• order history;
• saved information;
• active listings;
• forward-purchase records;
• rewards or promotional benefits; and
• other account-associated features.

Where an account has outstanding transactions, financial obligations, disputes or other unresolved matters, deletion may be subject to applicable legal and operational requirements.

21. Your Data Protection Rights

Subject to applicable law, you may have rights including the right to:

• know how your personal information is processed;
• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of personal information;
• object to certain processing;
• withdraw consent where processing is based on consent;
• request restriction of certain processing;
• request information concerning third parties with whom information has been shared, where applicable; and
• lodge a complaint with the relevant data protection authority.

Under Ghana's Data Protection Act, 2012 (Act 843), data subjects have rights including rights relating to access and objection.

Requests may be submitted to:

22. Ghana Data Protection Compliance

BEX is operated from Ghana and is intended to comply with applicable Ghanaian data protection requirements, including the Data Protection Act, 2012 (Act 843) and applicable guidance issued by the Data Protection Commission of Ghana.

Where required, Mjay Building Hardware Retail and Supply will maintain the necessary registrations, policies, controls and organisational arrangements for the lawful processing and protection of personal information.

The Data Protection Commission identifies principles including lawfulness, transparency, data minimisation, purpose limitation and accountability as part of compliance with Ghana's data protection framework.

23. International Data Transfers

Some BEX technology or service providers may operate outside Ghana.

Where personal information is transferred or processed outside Ghana, we will take reasonable steps to ensure that the information receives appropriate protection and that applicable legal requirements are observed.

Users acknowledge that international service providers may process information in jurisdictions different from the jurisdiction in which the user resides.

24. Children's Privacy

BEX is primarily intended for adults and businesses involved in the purchase, sale, distribution or use of building materials.

BEX does not knowingly seek to collect personal information from children where such collection is prohibited by applicable law.

If a parent or guardian believes that a child has provided personal information to BEX without appropriate authorisation, they should contact us at:

info@bexgh.com

We will take appropriate steps to investigate and, where required, delete the information.

25. Cookies and Similar Technologies

Where BEX operates websites or web-based services, we may use cookies, pixels, local storage and similar technologies to:

• maintain sessions;
• remember preferences;
• improve website functionality;
• understand usage;
• maintain security;
• analyse performance; and
• support relevant communications.

Users may be able to control cookies through their browser settings.

Where legally required, we will obtain appropriate consent before using non-essential cookies or similar technologies.

26. Analytics

BEX may use analytics services to understand how users interact with the platform and to identify technical problems and opportunities for improvement.

Analytics information may include:

• pages or screens viewed;
• features used;
• session information;
• device information;
• app performance;
• crash information; and
• general usage patterns.

27. Advertising and Marketing

BEX may from time to time display promotional content, offers or advertisements relating to BEX, its products, suppliers or partners.

Where third-party advertising technologies are used, their collection and use of information will be disclosed as required by applicable law and app-store requirements.

BEX will not knowingly permit third parties to use personal information for purposes inconsistent with this Privacy Policy.

Where applicable, users will be provided with choices regarding marketing communications and advertising-related processing.

28. User-generated Content

BEX may allow users to upload or submit:

• product photographs;
• listings;
• descriptions;
• reviews;
• comments;
• messages;
• ratings; or
• other content.

Users should not upload personal information belonging to another person unless they have a lawful basis or appropriate authority to do so.

Information included in public listings may be visible to other users.

BEX may remove content that violates applicable law, our Terms and Conditions, or platform rules.

29. Seller and Supplier Responsibilities

Sellers and suppliers using BEX are responsible for ensuring that information they provide about themselves, their businesses, employees, representatives and products is accurate and lawfully provided.

Sellers and suppliers must not:

• collect unnecessary personal information from customers;
• misuse customer information;
• sell or disclose customer information without lawful authority;
• use customer information for unrelated marketing without an appropriate legal basis; or
• retain customer information longer than reasonably necessary for authorised purposes.

Where BEX provides customer information to a seller for fulfilment, the seller must use that information only for authorised purposes.

30. Peer-to-peer Transactions

BEX may facilitate transactions between users rather than acting as the seller of every product listed on the platform.

In such cases, certain information may necessarily be exchanged between the parties to facilitate:

• communication;
• payment;
• collection;
• delivery;
• fulfilment; or
• resolution of a transaction.

Users should exercise appropriate caution when voluntarily sharing information with another user.

BEX does not authorise users to use another user's personal information for unrelated purposes.

31. Third-party Websites and Services

BEX may contain links or integrations to third-party websites, payment services, financial institutions, delivery providers or other services.

Once you leave BEX or interact directly with a third-party service, the third party's privacy policy may apply.

We encourage users to review the privacy policies of third-party services before providing personal information.

32. Fraud, Security and Abuse Monitoring

To protect the BEX ecosystem, we may monitor transactions and account activity for indicators of:

• fraud;
• account takeover;
• payment abuse;
• fake listings;
• suspicious transactions;
• scams;
• unauthorised access;
• misuse of promotional programmes; and
• other prohibited activity.

Such monitoring may involve automated systems and, where appropriate, human review.

Information may be retained or disclosed where necessary to investigate, prevent or respond to suspected fraud, abuse or unlawful activity.

33. Accuracy of Information

We rely on users to provide accurate and current information.

You should update your account information when it changes.

BEX may take reasonable steps to verify information where necessary for:

• account security;
• payment processing;
• fraud prevention;
• supplier verification;
• delivery;
• regulatory compliance; or
• other legitimate operational purposes.

34. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes to BEX;
• new features;
• changes in technology;
• changes in our data practices;
• changes in legal or regulatory requirements; or
• other operational developments.

When we make significant changes, we may provide notice through the app, website, email or other appropriate means.

The "Last Updated" date at the beginning of this Policy indicates when it was most recently revised.

35. Contact Us

If you have questions, concerns, complaints or requests regarding this Privacy Policy or your personal information, please contact us.

For data protection complaints relating to Ghana, users may also contact the Data Protection Commission of Ghana through its official channels.

36. Acceptance

By creating an account, accessing or using BEX, you acknowledge that you have had an opportunity to review this Privacy Policy.

Where applicable law requires consent, consent will be obtained through an appropriate affirmative action and will not be inferred merely from continued use of the application.

If you do not agree with the applicable processing of your personal information, you may discontinue use of the relevant BEX service and exercise any applicable privacy rights described in this Policy.