Communora360
Effective date: 4 November 2026
This policy explains how Communora360 handles personal information. Communora360 is a membership, dues, welfare, loans, events, elections and engagement platform that organisations (associations, professional societies, churches, welfare groups and similar) use to serve their members. It is provided by EBITS Co. Limited ("EBITS", "we"), the developer listed on Google Play and the App Store as EBITS.
It covers the Communora360 mobile app for Android and iPhone, the member portal and staff website at communora360.com, and the USSD service. Your organisation may have its own privacy notice for its membership; please read it too.
1. Who is responsible for your information
- Your organisation decides who its members are, what is recorded about them, what members pay and which elections and events it runs. For your membership record it is the data controller.
- EBITS runs Communora360 for your organisation and processes your member record on its instructions (as a data processor). EBITS is also responsible for operating the service itself: sign-in, security, notifications and the records needed to run the platform.
EBITS is registered with the Data Protection Commission of Ghana (registration number C0008835497) and handles personal information under the Data Protection Act, 2012 (Act 843).
2. Information we handle
Provided by your organisation when it adds you as a member: your name, member number, phone number, email address, gender, date of birth, membership group and status, the date you joined, and location. Depending on the organisation, it may also include professional details (title, cadre, specialty, licence number, facility, region and district) or church details (congregation, family, envelope number). Your organisation's staff may also record payments you made outside the app (cash, bank, salary deduction), sometimes from a bank statement or spreadsheet, and loans or welfare benefits paid to you.
Provided by you when you use Communora360:
- changes you make to your profile, and your privacy choices (whether to appear in rankings and whether to share your birthday);
- payments you make: the amount, what it is for, and the Mobile Money number and network used;
- welfare claims, where your organisation runs a welfare scheme: the benefit, the date of the event, your relationship to the person concerned and their name, what happened, and any documents you send as evidence (for example a death certificate, a medical report or a photo of one). These can include information about health or a death; see "Sensitive information" below;
- loans, where your organisation offers them (on its website or by USSD, never in the app): your application and its purpose, the amount, the repayment schedule, your repayments and any arrears, and the guarantors you name;
- guarantees: if a member names you as a guarantor, your organisation records your name, the amount you are asked to stand behind and your answer (given by you in the member portal, or on a signed form your organisation keeps a copy of);
- event registrations, quiz answers and scores, and your participation in elections (see section 5 for ballot secrecy);
- messages you send us for support.
Collected automatically to run and protect the service:
- sign-in records: when you signed in, the device name you gave, and your sign-in tokens;
- a notification token for your phone, so we can send you notifications;
- the app version and basic technical logs (such as IP address and errors), kept for security and troubleshooting;
- crash reports from the app: when the app fails, what went wrong and where in the app's code, the app version and your phone's model and system version. They contain no name, phone number or anything you typed, and are not linked to your account;
- records of the SMS and USSD sessions sent or used for your account.
Camera and photos. The app uses the camera in two places, and only when you choose to: staff scan event badges at the door (the badge code is read on the phone; no photo or video is stored or sent), and members can photograph a document, or choose a photo or file already on the phone, to send as evidence for their own welfare claim. Only the photo or file you choose is sent, and nothing else on your phone is read.
Sensitive information. Welfare evidence and claim details can show information about someone's health or a death. Under Ghana's Data Protection Act this is special personal information. It is used only to decide and pay the claim, is kept in private storage that is never public, is seen only by your organisation's staff who handle welfare, and each time staff open a document it is recorded. Send only what your organisation asks for.
What we do not collect: we do not collect your location or contacts, and we read no photos or files on your phone other than the ones you choose to send. We use no advertising, no advertising identifiers and no third-party analytics or tracking tools (crash reports are used only to fix the app). We never sell personal information.
3. How we use it
- To let you sign in and keep your account secure (SMS codes, passwords, optional two-step verification).
- To show you your membership, dues, receipts, events, badges, quizzes, awards and notifications.
- To process payments to your organisation and confirm them, and to record payments your organisation received outside the app.
- To run your organisation's welfare and loan schemes as it has set them up: to check whether a claim or a loan meets its rules, have it decided by its staff (more than one person, where its rules say so), record what is paid out and repaid, and tell you the decisions and reminders (in the app inbox, and by SMS where your organisation switches that on).
- To send you notifications, reminders and SMS that your organisation or the service sends (for example sign-in codes, receipts and event reminders).
- To run elections and events for your organisation as it has set them up.
- To provide support, prevent fraud and misuse, keep audit records, and meet legal obligations.
We rely on the performance of the service your organisation and you use, on your consent where it is needed (such as appearing in rankings or sharing your birthday, which you can change at any time in the app), on our legitimate interest in keeping the service secure, and on legal obligations.
4. Who we share it with
- Your organisation and its authorised staff, according to the permissions it gives them.
- Guarantors: if you name someone as a guarantor for your loan, they see your name, the loan amount and the part they are asked to stand behind, so they can decide.
- An association your organisation belongs to, only if your organisation chooses to share: totals and counts (for example how much was contributed or lent), never names or other details about members. Your organisation can stop sharing at any time.
- Payment processors: Hubtel and Moolre, and the Mobile Money networks, to process the payments you make. We do not receive or store your Mobile Money PIN.
- Google Firebase Cloud Messaging, to deliver notifications to your phone (it receives the notification token and the notification).
- Google Firebase Crashlytics, to tell us when the app crashes so we can fix it (it receives the crash reports described above).
- SMS and USSD: sign-in codes and messages are sent through the EBITS SMS gateway and the mobile networks; USSD sessions run through our USSD provider and the mobile networks.
- Email: when email is used, through our email service provider.
- AI writing assistance: staff may use OpenAI to draft quiz questions and daily messages from a topic they type. No member's personal information is sent.
- Hosting: our servers are run by our hosting provider, EBITS COMPANY LIMITED.
- Authorities, when the law requires it, or to protect the rights, safety and property of members, organisations or EBITS.
Each service provider may use the information only to provide its service to us. Some (such as Google and OpenAI) may process information outside Ghana; we use them only with appropriate safeguards and only for the purposes above.
5. Elections and ballot secrecy
Your vote is a secret ballot. A ballot records only the election and the choices; it contains no voter, no time and no other link to you. We record only that you took part, so you cannot vote twice. Nobody, including your organisation and EBITS, can see how you voted.
6. How long we keep it
We keep your information for as long as your organisation uses Communora360 and you are its member, and for as long as needed afterwards for the purposes above. In particular:
- payment and receipt records, and the figures of loans and welfare benefits (amounts, dates, repayments, references), are kept for 5 years because they are financial records;
- welfare evidence documents are kept as long as your organisation needs them for the claim and its records, and are deleted when you ask us to delete your account;
- security and audit records are kept for as long as needed to protect the service and investigate misuse;
- anonymous ballots are kept with the election's record and cannot be linked to you.
When you ask us to delete your account (section 8), we delete or anonymise the rest.
7. Security
Connections to Communora360 are encrypted (HTTPS). Sign-in tokens are kept in your phone's secure storage. Welfare evidence and signed guarantee forms are kept in private storage, checked when they are uploaded, and every time staff open one it is recorded. Sign-in codes are stored only in scrambled (hashed) form, expire after a few minutes and allow only a few tries. You can turn on two-step verification. Staff access is limited by roles and permissions, and important actions are kept in an audit trail. No system is perfectly secure: keep your codes and password to yourself, and tell us at once if you think your account was misused.
8. Your rights and deleting your account
Under Ghana's Data Protection Act you may ask to see the personal information held about you, to correct it, to object to some uses, and to have it deleted. Many details (such as your name or membership group) are managed by your organisation, so you can also ask it directly.
To delete your Communora360 account and its data, use the account deletion page, or the option under Profile in the app (in recent versions). We confirm the request by SMS and complete it within 30 days. The page explains exactly what is deleted and what must be kept.
You may also complain to the Data Protection Commission of Ghana (dataprotection.org.gh).
9. Children
Communora360 is meant for members of organisations and is not directed at children under 13. An organisation that records members under 18 is responsible for having a parent's or guardian's consent.
10. Changes to this policy
We may update this policy. We will change the effective date above, and tell you in the app or by SMS when a change matters for you.
11. Contact us
EBITS Co. Limited
P. O. Box 3572. Atwereboana Ave. Adum, Kumasi - Ghana
Privacy enquiries: privacy@ebitsgh.com
Support: support@ebitsgh.com
Phone: +233204093530