Privacy Policy — HotSpot Billing Platform

    We respect your privacy. We only collect data that is necessary to provide the service,
    and we never sell your personal information to third parties.
  

1. Who We Are

HotSpot Billing Platform is a WiFi voucher management platform operated by BGV Internet Services, based in Ghana. When we refer to "we", "us" or "our", we mean BGV Internet Services.

Data controller contact: info@mycaptiveportal.com

2. What Data We Collect

Data Type	What We Collect	Why
Account data	Name, email address, phone number, organisation name	To create and manage your account
Router data	Router IP, credentials, configuration settings	To configure and manage your MikroTik hotspot
Transaction data	Payment amounts, voucher codes, withdrawal requests	To process payments and calculate earnings
Customer data	Customer email/phone (if provided at purchase)	To deliver voucher credentials to end users
Usage data	Login times, IP addresses, pages visited	Security monitoring and fraud prevention
Device data	Browser type, operating system, user agent	Security logging and rate limiting

3. How We Use Your Data

We use your data to:

Provide and operate the HotSpot Billing Platform platform
Process voucher sales and calculate commissions
Send transactional emails (voucher credentials, password resets, withdrawal notifications)
Detect and prevent fraud, abuse, and security threats
Comply with legal obligations
Improve the platform based on usage patterns

We do not use your data for advertising or sell it to third parties.

4. Legal Basis for Processing

We process your data under the following legal bases:

Contract: Processing necessary to provide the service you signed up for
Legitimate interests: Security monitoring, fraud prevention, and platform improvement
Legal obligation: Compliance with applicable Ghanaian law
Consent: Marketing emails, where we ask for your permission first

5. Data Sharing

We share your data only with:

Payment gateways (Paystack, Flutterwave, Hubtel) — to process transactions
SMS providers (Arkesel, Africa's Talking, Twilio) — to deliver voucher credentials
Email providers — to send transactional emails
Legal authorities — if required by law or court order

All third-party providers are required to handle your data securely and in accordance with their own privacy policies.

6. Data Retention

We retain your data for as long as your account is active. When you close your account:

Personal data is deleted within 30 days
Transaction records are retained for 7 years for legal and tax compliance
Login attempt logs are deleted after 7 days

7. Security

We protect your data with:

HTTPS encryption for all data in transit
Bcrypt password hashing (cost factor 12)
IP-based rate limiting and automatic blocking of brute force attempts
CSRF token protection on all forms
Session management with automatic expiry

No system is 100% secure. If you discover a security vulnerability, please report it to us immediately at info@mycaptiveportal.com.

8. Your Rights

You have the right to:

Access — request a copy of the personal data we hold about you
Correction — ask us to correct inaccurate data
Deletion — request deletion of your personal data (subject to legal retention requirements)
Portability — receive your data in a machine-readable format
Objection — object to processing based on legitimate interests
Unsubscribe — opt out of marketing emails at any time via the unsubscribe link in any email

To exercise any of these rights, contact us at info@mycaptiveportal.com. We will respond within 30 days.

9. Cookies

We use essential cookies to keep you logged in and protect against CSRF attacks. We do not use advertising or tracking cookies. See our Cookie Policy for details.

10. Children's Privacy

HotSpot Billing Platform is not directed at children under 18. We do not knowingly collect data from minors. If you believe a minor has registered, please contact us and we will delete the account immediately.

11. Changes to This Policy

We may update this Privacy Policy occasionally. We will notify you of significant changes by email. The "last updated" date at the top of this page will always reflect the most recent version.

12. Contact Us

For privacy-related questions or to exercise your rights:

Email: info@mycaptiveportal.com

Website: https://mycaptiveportal.com