Privacy notice for participants
What we collect when you answer a survey on WhatsApp, why, who sees it, how long we keep it, and how to see or erase it.
Version 2026-10-v1, in force from 2026-10-01. This is the notice the consent message in WhatsApp refers to.
1. Who we are
SurvRewards runs short surveys for brands in Ghana over WhatsApp and thanks the people who complete them with MTN data. SurvRewards is a product of Tian Afrik (tianafrik.com), which is the data controller for what you share with us in that conversation, under Ghana's Data Protection Act, 2012 (Act 843). You can write to us at [email protected].
You only hear from us after you message our WhatsApp number, scan a brand's code, or say yes to being invited to that brand's next survey. We never buy lists and we never message a number that has not written to us first.
2. What we collect
| Data | Why we need it |
|---|---|
| Your mobile number | To talk to you on WhatsApp, to credit the data reward to that number, and to stop one number taking the same survey twice. Stored as a one-way hash for lookup and encrypted for the few moments the clear number is needed. |
| Whether your number is an active MTN line | MTN tells us yes or no before the survey starts, so nobody answers for a reward that cannot be paid. |
| Your answers | They are the survey result the brand asked for. Choices, ratings and numbers are stored as option codes; anything you type in your own words is stored as text. |
| The messages between us | As sent and received, so we can answer a complaint about what was said and prove a message was or was not delivered. |
| Your language choice | To answer you in English or Twi. |
| Your consent | Which survey, when you said yes, which version of this notice, and when you withdrew. |
| The one-time code we text you | Only a hash of the 6-digit code, never the code itself, and whether it was entered correctly. |
| Reward records | What was credited to your number, when, and the reference MTN gave us, so you can ask for a RECEIPT and so we can settle with MTN. |
| Signals of misuse | How fast a survey was completed, whether every answer was the same, whether many numbers behave alike. A signal holds a reward for a person to look at; it never blocks you silently. |
| Problems you report | What you typed after HELP → Report a problem, so our team can put it right. |
We do not collect your name (other than the WhatsApp display name, which is encrypted and optional), your address, date of birth, ID numbers, location, device identifiers or payment details. A brand may ask a demographic question such as an age band or region; your answer is stored as an option code against an internal id, not against your number.
3. Why, and on what basis
- Running the survey and paying the reward — with your consent, asked in the first message of every survey with a Yes/No button, and withdrawable at any time with
STOP. - Checking your number (the text-message code and MTN's eligibility answer) — necessary to do what you asked for: a reward to this number.
- Preventing misuse — our legitimate interest, and MTN's, in not paying the same person twice or paying an automated farm. Named in the consent message. Any decision to withhold a reward is taken by a person.
- Keeping financial records — a legal obligation under the Companies Act, 2019 (Act 992) and the Revenue Administration Act, 2016 (Act 915), for six years. These records name brands and MTN, and refer to you only by an internal id.
- Answering MY DATA, DELETE, RECEIPT and complaints — our obligations under Act 843 and our own service promise.
- Inviting you to a brand's next survey — only if you said yes when we asked, after a survey you completed, and only for that brand.
No automated decision has a legal or similarly significant effect on you without a person involved. We do not seek sensitive personal data; a brand that writes a question touching health, religion, ethnicity or politics is refused at review.
4. Who sees what
| Who | What they see |
|---|---|
| The brand that ran the survey | Results in aggregate, and individual answers only under a pseudonym with contact details masked out of free text. Never your number, never your name. |
| MTN Ghana | Your number and the bundle size, to credit the reward. MTN already knows your number: you are its subscriber. MTN also sees counts, references and statements, never your answers. |
| Meta (WhatsApp) | The messages pass through the WhatsApp Business platform under Meta’s terms, as every WhatsApp message does. Meta does not see the reward, the ledger or anything stored on our side. |
| Our operations team | A masked number (first digits and last two) when handling a complaint or a reward under dispute. No screen in the system shows a full participant number. |
| Hosting | Our servers and database run with a hosting provider under a data-processing agreement. Backups are encrypted. |
We do not sell or share your data with anyone else.
5. How long we keep it
The schedule below is enforced by the system every night. Operations may adjust a period within the bounds shown, and every change is recorded. The MY DATA reply always tells you the periods currently in force.
| Records | Kept for | Then |
|---|---|---|
Chat messages Every WhatsApp message in and out, as received or sent. | 3 months from the date the message was received or sent (bounds 30 days – 1 year) | deleted |
Answers of unfinished surveys Answers given in a survey the person abandoned or that expired, and the working state of that session. | 3 months from the last message in that session (bounds 30 days – 1 year) | deleted |
Free-text answers of closed campaigns What people typed in their own words in a campaign that has ended. Choice, rating and number answers are not personal and stay. | 2 years from the campaign’s end (bounds 1 year – 5 years) | the text is removed; the answer count stays |
One-time codes Each SMS verification challenge: a hash of the code (never the code), when it expired, whether it was passed. | 400 days from the challenge’s creation (bounds 366 days – 800 days) | deleted |
People we have not heard from A participant’s encrypted number and everything that identifies them, once they have been silent for a long time. | 2 years from the last message from them (bounds 1 year – 5 years) | your number and anything that identifies you are erased |
Kept longer, and why:
- Ledger accounts, transactions and entries; top-ups; monthly balance statements; reconciliation findings. Financial records. Kept six years under the Companies Act, 2019 (Act 992) and the Revenue Administration Act, 2016 (Act 915). They name brands and MTN, never a participant.
- Reward attempts and their MTN references. The record that a credit happened and what MTN was paid for it, matched line by line against MTN’s own reports. Pseudonymous once the participant is tombstoned.
- The audit log. Append-only and hash-chained; removing an entry would break the chain MTN verifies. Entries name ids, never numbers or text.
- Consent records. Proof that consent was given, under which policy, and when it was withdrawn. Tombstoned with the participant.
- Campaigns, questions and the answers of completed surveys other than free text. The brand’s results, by option id. Not personal once the participant is tombstoned.
- Complaints and data-subject requests. Regulatory evidence of how a concern was handled and how fast. Tombstoned with the participant.
6. Your rights, from the chat
Everything below works by replying in the same WhatsApp conversation, even after STOP.
| Reply | What happens |
|---|---|
MY DATA | We answer immediately with what we hold about this number — surveys taken, rewards, messages, consents — the retention periods in force, and how to erase it. |
DELETE | After you confirm with a button, we erase your number and everything that identifies you within 30 days (an open dispute with MTN about a credit is settled first). Reward and financial records stay, under an internal id only. |
STOP | No further messages from us. You are removed from every brand’s invitation list. Reply START to change your mind. |
RECEIPT | Your own credits with the reference MTN’s customer desk asks for. |
HELP | A menu: your rewards, your surveys, report a problem. A problem report reaches our team, who respond within 60 minutes. |
You may also complain to the Data Protection Commission of Ghana. We would ask you to write to us first, at [email protected], so we can put things right.
7. How we protect it
Numbers are stored hashed and encrypted; the clear number is decrypted only on the server at the moment MTN is asked to credit it or a message is sent to you. Every action by our staff is written to an append-only, tamper-evident log. Staff accounts use two-step sign-in. Access is by role: a brand user cannot see another brand, and no role can read a participant's number from a screen. Backups are encrypted and restored regularly to prove they work.
8. Changes to this notice
When this notice changes in substance, its version number changes and the new version is what the consent message points to from then on. Your earlier consent stays recorded against the version you read. The version in force is at the top of this page.
See also the participant terms and how it works.