Cookie Policy

Last Updated: November 10, 2025

Complies with the Data Protection Act, 2012 (Act 843) of Ghana

About This Cookie Policy

This Cookie Policy explains how Locked ("we," "us," or "our") uses cookies and similar tracking technologies on our platform in compliance with the Data Protection Act, 2012 (Act 843) of Ghana and the Electronic Transactions Act, 2008 (Act 772).

Under Section 11 of the Data Protection Act, 2012 (Act 843), we require your informed consent before placing non-essential cookies on your device. By using Locked, you acknowledge that you have been informed about our cookie practices and provide consent as required by Ghanaian law.

For information about how we process your personal data, please see our Privacy Policy.

1. What Are Cookies?

Cookies are small text files that are placed on your device (computer, smartphone, or tablet) when you visit a website. They help websites remember your preferences and improve your browsing experience.

Under the Electronic Transactions Act, 2008 (Act 772) and the Data Protection Act, 2012 (Act 843) of Ghana, cookies may be used for legitimate purposes with your consent. Cookies contain information such as your language preferences, login status, and site settings.

Cookies do not contain personal information like your name or email address unless you explicitly provide it. When cookies do contain personal data, such data is processed in accordance with the Data Protection Act, 2012 (Act 843) and our Privacy Policy.

Your Rights Under Ghanaian Law: Under the Data Protection Act, 2012 (Act 843), you have the right to object to processing of your personal data (Section 33). Most modern web browsers allow you to control cookies through their settings. You can block or delete cookies, but this may affect your experience on Locked.

2. Why We Use Cookies

Locked uses cookies to:

  • Keep you signed in: Remember your login session so you don't have to sign in repeatedly
  • Enhance security: Protect your account from unauthorized access and prevent fraud
  • Remember preferences: Store your language, view modes, and other settings
  • Analyze usage: Understand how users interact with our platform to improve features
  • Provide personalized content: Show relevant events and recommendations based on your interests
  • Measure performance: Track which events and features are most popular
  • Support marketing: Deliver targeted content and measure campaign effectiveness

3. Types of Cookies We Use

3.1 Essential Cookies (Required)

These cookies are necessary for the platform to function. You cannot opt out of these cookies.

Cookie NamePurposeDuration
sb-access-tokenAuthentication and session management7 days
sb-refresh-tokenAutomatic login renewal30 days
csrf-tokenSecurity and CSRF protectionSession

3.2 Functional Cookies (Optional)

These cookies enhance your experience by remembering your preferences and settings.

Cookie/StoragePurposeDuration
eventsViewModeRemember grid/list view preferencePersistent
draftEventsViewModeRemember draft events view preferencePersistent
adminSidebarCollapsedRemember sidebar statePersistent
languageStore language preference1 year

3.3 Analytics Cookies (Optional)

These cookies help us understand how users interact with Locked so we can improve the platform.

ServicePurposeDuration
Vercel AnalyticsPage views, performance metrics, user flows24 hours
Vercel Speed InsightsWebsite performance and loading times24 hours
Custom AnalyticsEvent views, locks, clicks, and engagementSession

3.4 Marketing Cookies (Optional)

These cookies help us deliver relevant content and measure the effectiveness of our campaigns.

PurposeDescriptionDuration
Featured EventsTrack engagement with promoted events30 days
RecommendationsPersonalize event suggestions90 days
Campaign TrackingMeasure marketing campaign performance30 days

4. Local Storage and Session Storage

In addition to cookies, Locked uses browser local storage and session storage to enhance functionality:

4.1 Local Storage

Persistent data stored on your device that doesn't expire:

  • User Preferences: View modes, theme settings, sidebar states
  • Locked Events: List of events you've locked for quick access
  • Draft Data: Temporarily saves form data to prevent loss
  • Recent Searches: Your recent event and venue searches

4.2 Session Storage

Temporary data cleared when you close your browser:

  • Navigation State: Current page and scroll position
  • Form State: Temporary form data during multi-step processes
  • Filter Settings: Active filters on discover and search pages

5. Third-Party Cookies and Cross-Border Data Transfer

Locked uses third-party services that may set their own cookies. Under Section 40 of the Data Protection Act, 2012 (Act 843), cross-border transfers of personal data must comply with Ghanaian law. We ensure that third-party services provide adequate protection for your data.

Vercel (United States)

Hosting and analytics platform - Cross-border data transfer

  • Analytics cookies for page views and performance
  • Speed Insights cookies for performance monitoring
  • Data transferred with adequate safeguards per Act 843, Section 40
  • Privacy Policy: vercel.com/legal/privacy-policy

Supabase (United States)

Database and authentication platform - Cross-border data transfer

  • Authentication cookies for session management
  • Security cookies for CSRF protection (Cybersecurity Act, 2020 [Act 1038])
  • Data transferred with encryption and security measures
  • Privacy Policy: supabase.com/privacy

Hubtel (Ghana)

Payment processing platform - Licensed by Bank of Ghana

  • Payment session cookies
  • Fraud prevention and security cookies
  • Complies with National Payment Systems Act, 2003 (Act 662)
  • Subject to Bank of Ghana regulations
  • Privacy Policy: hubtel.com/privacy

Google Cloud (United States)

Vision API for image moderation - Cross-border data transfer

Important: By using Locked, you consent to these cross-border data transfers as permitted under Section 40 of the Data Protection Act, 2012 (Act 843). We ensure all third-party processors maintain adequate data protection standards comparable to Ghanaian law.

6. How to Manage Cookies - Your Rights Under Ghanaian Law

Under Section 33 of the Data Protection Act, 2012 (Act 843), you have the right to object to the processing of your personal data, including data collected through cookies. You have several options to control and manage cookies:

6.1 Browser Settings

Most browsers allow you to exercise your rights under Act 843 by:

  • Viewing and deleting existing cookies (Right of Access - Section 31)
  • Blocking third-party cookies
  • Blocking all cookies (not recommended for Locked functionality)
  • Clearing cookies when closing your browser

6.2 Platform Settings

Locked provides cookie preferences in your account settings (coming soon):

  • Enable/disable analytics cookies
  • Enable/disable marketing cookies
  • Clear local storage data

6.3 Impact of Disabling Cookies

If you disable cookies, some features may not work properly:

  • Essential cookies disabled: You cannot sign in or use authenticated features
  • Functional cookies disabled: Preferences won't be saved between visits
  • Analytics cookies disabled: We can't improve based on usage patterns
  • Marketing cookies disabled: You'll see less relevant event recommendations

7. Cookie Consent Under Data Protection Act, 2012 (Act 843)

Section 11 of the Data Protection Act, 2012 (Act 843) requires that we obtain your informed consent before processing personal data through non-essential cookies. When you first visit Locked, you'll see a cookie consent banner where you can:

  • Accept All: Provide consent for all cookies including optional ones (functional, analytics, marketing)
  • Reject Optional: Only essential cookies will be used (authentication, security)
  • Customize: Choose which types of cookies to allow based on your preferences

You can withdraw your consent at any time by changing your cookie preferences through your account settings. This right is protected under Section 33 of the Data Protection Act, 2012 (Act 843).

Essential cookies that are necessary for platform functionality do not require consent under Ghanaian law, as they are required for the legitimate performance of our services.

8. Cookie Security Under Ghanaian Law

We implement security measures for cookies in compliance with Section 19 of the Data Protection Act, 2012 (Act 843), the Electronic Transactions Act, 2008 (Act 772), and the Cybersecurity Act, 2020 (Act 1038):

  • Encrypted cookies: Sensitive cookies are encrypted to protect your data
  • Secure transmission: All cookies are transmitted over HTTPS as required by the Electronic Transactions Act
  • HttpOnly flag: Prevents JavaScript access to authentication cookies (CSRF protection)
  • SameSite attribute: Protects against cross-site request forgery attacks
  • Regular security audits: We conduct security assessments as required by the Cybersecurity Act, 2020 (Act 1038)
  • Data minimization: We only collect cookie data necessary for legitimate purposes (Section 14 of Act 843)
  • Access controls: Strict internal controls limit who can access cookie data

If you believe there has been a security breach affecting your cookie data, please contact our Data Protection Officer immediately at dpo@locked.com.

9. Do Not Track (DNT) Signals

Some browsers have a "Do Not Track" (DNT) feature that signals to websites you prefer not to be tracked.

Currently, there is no universal standard for how websites should respond to DNT signals. Locked respects your browser's DNT signal by:

  • Disabling non-essential analytics when DNT is enabled
  • Minimizing data collection to essential functions only
  • Not sharing data with third-party advertisers

10. Updates to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in our practices, technology, or legal requirements under Ghanaian law (including the Data Protection Act, 2012 [Act 843] and other applicable legislation). We will notify you of significant changes by:

  • Posting the updated policy on this page with a revised "Last Updated" date
  • Sending an email notification to your registered address for material changes
  • Displaying a prominent notification on the platform
  • Requesting renewed consent where required by the Data Protection Act

Under the Electronic Transactions Act, 2008 (Act 772), your continued use of the platform after notification of changes constitutes acceptance of the updated Cookie Policy. If you do not agree with the changes, you may withdraw consent and discontinue use of non-essential cookies.

We encourage you to review this policy periodically to stay informed about how we use cookies and your rights under Ghanaian law.

Contact Us About Cookies

If you have questions about our use of cookies or wish to exercise your rights under the Data Protection Act, 2012 (Act 843), please contact us:

Email

General cookie inquiries:

privacy@locked.com

Data Protection Officer:

dpo@locked.com

Phone

+233 XX XXX XXXX

Address

Accra, Ghana

Data Protection Commission of Ghana

If you are not satisfied with our response to your cookie-related concerns or wish to lodge a complaint under the Data Protection Act, 2012 (Act 843), you may contact:

Address: No. 18 Dr. Isert Road, North Ridge, Accra

Email: info@dataprotection.org.gh

Phone: +233 (0)302 971 370

Website: www.dataprotection.org.gh

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