Ā Who We Are?

The Surest Way Guides, also known as TSWG, operates the website and platform available at The Surest Way Guides

For the purposes of applicable data protection laws, The Surest Way Guides is the data controller for the personal information collected through this website and platform, except where this policy states otherwise.

If we appoint a representative or Data Protection Officer where required by law, we will publish those contact details here. Privacy notices are generally expected to include the controller’s contact details and, where applicable, the contact details of a Data Protection Officer.

2. What Information We Collect

We may collect personal information directly from you, automatically from your use of the platform, and in some cases from third parties.

2.1 Information you give to us directly

We may collect information you provide when you:

create an account, complete your profile, purchase or sell products or services, publish content, join a community, contact support, submit a form, sign up for updates, or communicate with us.

This information may include:

name, username, email address, phone number, profile details, billing details, transaction-related details, messages you send through the platform, content you upload, and any other information you choose to provide.

2.2 Information collected automatically

When you use our website or platform, we may automatically collect certain technical and usage information, such as:

IP address, browser type, device type, operating system, pages viewed, links clicked, session information, referral URLs, approximate location data based on IP, and cookie or similar tracking data.

2.3 Information from third parties

We may receive personal information from third parties where necessary to operate the platform and related services. This may include:

payment providers, identity or fraud-prevention tools, analytics providers, marketing providers, login or authentication partners, and other service providers that support our platform.

2.4 Sensitive personal data and financial data

We do not intend to collect sensitive or special category personal data unless there is a clear lawful reason to do so.

Where financial transactions are processed, payment card details and similar payment credentials are usually handled by our payment service providers rather than stored directly by us, unless we clearly state otherwise. We may still receive limited payment-related data such as transaction status, billing identifiers, payout details, or records needed for accounting, fraud prevention, support, and compliance.

3. How We Use Personal Information

We use personal information to operate, improve, secure, and support The Surest Way Guides.

Depending on how you use the platform, we may use your personal information to:

create and manage user accounts, provide access to platform features, process subscriptions and purchases, support creator services, process payouts, deliver customer support, manage communities, display user profiles and content, personalise platform content and user experience, send service updates and account notifications, provide marketing communications where permitted, conduct surveys, improve our products and services, perform analytics, detect fraud, secure the platform, enforce our terms, meet legal obligations, and maintain internal records, audits, and business operations.

We will only use personal information in ways that are consistent with this policy and applicable law.

4. What Legal Basis We Have for Processing Your Personal Data

Under GDPR-style data protection rules, personal data must be processed on at least one lawful basis. The six recognised lawful bases are consent, contract, legal obligation, vital interests, public task, and legitimate interests.

Depending on the situation, we may rely on one or more of the following:

4.1 Contract

We process personal information where it is necessary to provide the services you request, create and manage your account, process purchases, enable creator features, deliver digital products, and otherwise perform our contract with you. Contract is a recognised lawful basis where processing is necessary for a contract or steps requested before entering into one.

4.2 Consent

We may rely on your consent for certain activities, such as optional marketing communications, certain cookies, or other uses where consent is required by law.

Where we rely on consent, you can withdraw it at any time. Withdrawal does not affect processing already carried out lawfully before withdrawal.

4.3 Legitimate Interests

We may process personal information where it is reasonably necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms.

These legitimate interests may include operating and improving the platform, preventing fraud, securing our systems, supporting users, analysing service performance, and conducting ordinary business administration. Legitimate interests is a recognised lawful basis, but it requires balancing the organisation’s needs against the individual’s rights and expectations.

4.4 Legal Obligation

We may process personal information where necessary to comply with legal or regulatory obligations, including recordkeeping, responding to lawful requests, fraud prevention, tax compliance, and dispute handling. Legal obligation is a recognised lawful basis under GDPR-style rules.

4.5 Vital Interests or Public Task

These lawful bases generally apply only in limited situations. We would rely on them only where they are genuinely relevant and lawful.

4.6 Special category or sensitive personal data

If we ever need to process special category or sensitive personal data, we will do so only where an additional lawful condition applies under applicable law, and we will explain that processing where required.

5. When We Share Personal Data

We treat personal information as confidential and do not sell it as a general business model unless we clearly state otherwise.

We may share personal information only where reasonably necessary, including with:

service providers and contractors who help us operate the website and platform, payment processors, hosting providers, analytics providers, communication tools, fraud-prevention services, professional advisers, auditors, legal or regulatory authorities, and other parties where disclosure is required by law or necessary to protect rights, safety, or platform integrity.

We may also share information as part of a merger, acquisition, restructuring, financing, or sale of assets, subject to appropriate safeguards.

When we share personal data, we aim to do so under suitable confidentiality, security, and data processing arrangements.

6. Where We Store and Process Personal Data

We may store and process personal information in the country where we operate and in other countries where our service providers operate.

Where personal information is transferred across borders, we will take reasonable steps to ensure it remains protected in a manner consistent with this policy and applicable law.

Where laws such as the GDPR apply, international data transfers should be protected by appropriate safeguards, which can include contractual clauses or similar transfer mechanisms.

7. How We Secure Personal Data

We use reasonable technical, organisational, and administrative measures to protect personal information against loss, misuse, unauthorised access, alteration, disclosure, or destruction.

These measures may include access controls, password protections, encryption where appropriate, monitoring, backups, vendor reviews, staff awareness measures, and other security procedures designed to reduce risk and support business continuity.

However, no internet-based system or storage method can be guaranteed to be completely secure. For that reason, we cannot promise absolute security, but we do work to protect personal information in a responsible and proportionate way.

8. How Long We Keep Personal Data

We keep personal information only for as long as it is reasonably necessary for the purposes described in this policy, including providing services, maintaining records, resolving disputes, enforcing agreements, meeting legal obligations, and preventing fraud.

Retention periods may vary depending on the type of data and why we collected it. When we no longer need personal information, we will securely delete it, anonymise it, or otherwise dispose of it in a safe manner, unless we are required or permitted by law to keep it longer.

If a specific retention period is not stated, we determine the retention period based on the nature of the data, the purpose of processing, legal requirements, security needs, and operational necessity.

9. Your Rights in Relation to Personal Data

Where applicable law gives you these rights, you may have the right to:

access your personal data, correct inaccurate data, request deletion of your data, restrict certain processing, object to certain processing, receive a portable copy of certain data, withdraw consent where consent is the basis for processing, and complain to a relevant supervisory authority.

European Commission guidance lists rights including access, rectification, erasure, restriction, objection, and the right to be informed, while portability and related rights are also part of GDPR protections.

Some rights are not absolute and may depend on the legal basis for processing or other lawful exceptions. The European Data Protection Board notes that some rights do not apply in all situations.

To exercise your rights, contact us using the contact details in this policy. We may ask you to verify your identity before responding. In some cases, we may refuse or limit part of a request where the law allows us to do so, including where the request would affect the rights of another person or where we are legally required to keep certain records.

If you are in the United Kingdom, you may also complain to the Information Commissioner’s Office. If you are elsewhere, you may complain to your local data protection authority where applicable.

10. Use of Automated Decision-Making and Profiling

We may use automated tools to help us improve security, reduce fraud, personalise content, recommend content, moderate activity, or improve the user experience.

Where we use profiling or automated processing in a way that has legal or similarly significant effects on an individual, we will provide additional information about the logic involved, the likely significance of that processing, and any rights available to the individual, where required by law. GDPR-style rules recognise a right not to be subject, in certain circumstances, to automated decision-making with significant effects.

11. Use of Cookies and Similar Technologies

We may use cookies, pixels, local storage, analytics tags, and similar technologies to remember preferences, maintain sessions, improve performance, understand usage, support security, and where permitted, support advertising or marketing.

You can usually control cookies through your browser settings and, where applicable, through our cookie consent tools.

If we use non-essential cookies, we will aim to provide appropriate notice and choices in line with applicable law.

12. Links to Other Websites and Third-Party Content

Our website or platform may contain links to third-party websites, tools, or content.

We are not responsible for the privacy practices, security, or content of third-party services that we do not control. A link to another website does not necessarily mean we endorse that website or everything on it.

We encourage users to read the privacy policies of any third-party websites they visit.

13. Children’s Privacy

The platform is not intended for use by children where prohibited by applicable law, and we do not knowingly collect personal information from children in violation of applicable legal requirements.

If you believe a child has provided personal information to us unlawfully, please contact us so we can review and take appropriate action.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, business operations, legal requirements, or privacy practices.

When we make material changes, we will update the revised date and, where appropriate, provide additional notice.

Your continued use of the platform after an updated version is posted may mean you accept the updated policy, to the extent allowed by law.

15. How to Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or your personal information, you can contact us using the details below:

The Surest Way Guides
Website: thesurestwayguides.com
Call or WhatsApp: +233596352938
Email: business@thesurestwayguides.com

Address: business@thesurestwayguides.com