Privacy Policy

Effective date: August 5, 2026 · Last updated: August 5, 2026

This Privacy Policy explains how Bilo Tech Ltd ("Bilo Tech", "TurnUp", "we", "us", "our") collects, uses, shares, and protects personal data when you use the TurnUp Service, whether as a Business User, a Client, or a visitor to a TurnUp booking page. It should be read together with our Terms of Service and Cookie Policy.

1. Scope of this Policy

This Policy applies to personal data we process as a result of operating the Service — for example, data about Business Users and their staff, and data about Clients who book, or attempt to book, a service. Where a Business User uses TurnUp to collect and manage their own clients' data, the Business User is generally the party responsible for deciding how that data is used (a "controller" under data-protection law), and we act on their instructions to provide the Service (a "processor"), while also using certain data for our own purposes described below (for example, platform security and improving TurnUp) as an independent controller.

2. Who We Are

Bilo Tech Ltd is a company incorporated in Ghana under the Companies Act, 2019 (Act 992). For the purposes of this Policy, Bilo Tech Ltd is the data controller for personal data we process for our own purposes (such as account administration, platform security, billing, and direct marketing you opt into), and can be reached at support@turnup.show.

3. Information We Collect

3.1 Information you provide directly

WhoWhat we collect
Business UsersName, email address, password (stored as a salted hash, never in plain text), business name, booking-page URL, phone number, business address/location, opening hours, service listings and pricing, deposit settings, and payout/identity information collected on our behalf by Stripe or Paystack (we do not store full card or bank account numbers).
ClientsName, phone number, and (optionally) email address provided at booking or account sign-up; for account holders, booking history within the Service.
EveryoneAny information you include in messages sent through the Service, and any information you provide when you contact our support team.

3.2 Information collected automatically

When you use the Service, we and our infrastructure providers automatically collect limited technical information, including IP address, browser and device type, pages viewed, timestamps, and — where you enable push notifications — a device push-subscription identifier. See our Cookie Policy for details on cookies and similar technologies.

3.3 Information from third parties

If a Business User sets their location using our map-search feature, we receive place, address, and coordinate data from Google Maps/Places. If a payment is made or a payout account is set up, Stripe or Paystack shares limited information back with us (such as payment status, payout status, and verification status) — not full card, bank, or government-ID numbers.

3.4 Sensitive data

We do not intentionally collect sensitive categories of personal data (such as health data, racial or ethnic origin, or religious beliefs). Please do not include such information in booking notes, messages, or any other field within the Service unless it is strictly necessary and you have a lawful basis to share it (for example, a Client voluntarily telling a business about a relevant health consideration for a specific appointment).

4. How We Use Information

  • To create and administer accounts, and authenticate you when you sign in;
  • To operate Bookings — creating, confirming, reminding, rescheduling, and recording the status of appointments and class sessions;
  • To process Deposits and payouts through our payment processors, and to detect and prevent fraud;
  • To send transactional communications by SMS, WhatsApp, and email (see Section 5);
  • To operate the marketplace and location search, and to display verified-business badges;
  • To provide customer support and respond to your requests;
  • To maintain the security, integrity, and reliability of the Service;
  • To analyze usage in aggregate to understand and improve the Service; and
  • To comply with legal obligations, including tax, accounting, and anti-money-laundering requirements imposed on us or our payment processors.

Where the GDPR or a similar law applies, we rely on the following legal bases: performance of a contract (to provide the Service you or a Business User signed up for, including completing a Booking); legitimate interests (for example, preventing fraud, securing the Service, and improving it — balanced against your rights and interests); consent (for example, optional marketing communications or non-essential cookies, which you can withdraw at any time); and legal obligation (for example, retaining payment records as required by law).

6. SMS, WhatsApp & Email Communications

We use your phone number and/or email address to send booking confirmations, reminders, reschedule links, deposit notices, and — for Business Users — account and platform notifications. These are transactional messages tied to an account or a Booking, not unsolicited marketing. Message delivery is provided by Twilio (SMS and WhatsApp) and Twilio SendGrid (email); see Section 8 for more on these providers. You can manage communication preferences as described in our Terms of Service, Section 9.

7. Cookies & Tracking

We use a small number of strictly necessary cookies to keep you signed in and to protect the Service from abuse. We do not currently use advertising or cross-site tracking cookies. Full details, including cookie names and durations, are in our Cookie Policy.

8. How We Share Information

We do not sell personal data. We share personal data only in the following circumstances:

RecipientPurposeWhat is shared
The relevant Business UserTo fulfil a BookingA Client's name, phone number, optional email, and Booking details.
Stripe / PaystackPayment processing and payoutsPayment amount, currency, and the minimum identity/account information those processors require by law.
Twilio (incl. SendGrid)Sending SMS, WhatsApp, and email messagesRecipient phone number/email and message content.
SupabaseHosting our database, authentication, and file storageAll data stored in the Service, encrypted in transit and at rest by Supabase's infrastructure.
Google Maps/PlacesLocation search and address autocomplete for Business UsersSearch queries you type and the resulting selected address.
Law enforcement or regulatorsWhere required by law, legal process, or to protect rights, safety, or propertyOnly the information reasonably required to comply.
A successor entityIn connection with a merger, acquisition, financing, or sale of assetsPersonal data as part of the transferred business, subject to this Policy or a successor policy.

9. International Data Transfers

We and our service providers may process and store personal data in countries other than your own, including Ghana and the countries where our infrastructure and processor partners operate. Where we transfer personal data of individuals in the European Economic Area, the United Kingdom, or Switzerland to a country that has not been found to provide an adequate level of protection, we rely on appropriate safeguards recognized under applicable law, such as Standard Contractual Clauses, and require our processors to provide an equivalent level of protection to your data wherever it is processed.

10. Data Retention

We retain personal data for as long as necessary to provide the Service and for legitimate business purposes, such as maintaining Booking history, complying with legal, tax, and accounting obligations, resolving disputes, and enforcing our agreements. Booking and payment records are typically retained for the period required by applicable tax and financial-record-keeping laws (commonly up to 6–7 years). When data is no longer needed, we delete it or anonymize it so it can no longer identify you.

11. Your Privacy Rights

Wherever you are located, you can ask us to: confirm what personal data we hold about you; correct inaccurate data; delete your data, subject to our legal retention obligations; or ask a question about how we handle your data. You can exercise these rights by contacting support@turnup.show. If your data was provided to us by a Business User you booked with, we may direct part of your request to that Business User, since they control the underlying Booking relationship.

12. Additional Rights for EEA, UK & Swiss Users (GDPR)

If the GDPR or the UK GDPR applies to you, you additionally have the right to:

  • Access a copy of the personal data we hold about you;
  • Rectification of inaccurate or incomplete data;
  • Erasure ("right to be forgotten") of your data in certain circumstances;
  • Restriction of processing in certain circumstances;
  • Data portability — receiving data you provided to us in a structured, machine-readable format;
  • Objection to processing based on legitimate interests, including direct marketing; and
  • Withdraw consent at any time where processing is based on consent, without affecting processing carried out before withdrawal.

You also have the right to lodge a complaint with your local data-protection supervisory authority. We encourage you to contact us first at support@turnup.show so we can try to resolve your concern directly.

13. Additional Rights for California Users (CCPA/CPRA)

If you are a California resident, you additionally have the right to:

  • Know what categories of personal information we collect, use, and disclose, and the purposes for doing so (set out in Sections 3, 4, and 8 above);
  • Request deletion of your personal information, subject to certain exceptions;
  • Correct inaccurate personal information;
  • Opt out of the "sale" or "sharing" of personal information — we do not sell or share personal information as those terms are defined by the CCPA/CPRA, so there is nothing to opt out of today; and
  • Not be discriminated against for exercising any of these rights.

You may exercise these rights yourself or through an authorized agent by contacting support@turnup.show. We may need to verify your identity before completing certain requests.

14. Rights for Ghana Users (Data Protection Act, 2012, Act 843)

As a Ghana-incorporated company, we are subject to Ghana's Data Protection Act, 2012 (Act 843) and registered, or in the process of registering, as a data controller with Ghana's Data Protection Commission. If you are in Ghana, you have the rights described in Section 11 above, and may also lodge a complaint with the Data Protection Commission if you believe we have not handled your personal data lawfully.

15. Other Regions

Because TurnUp is used across several countries, we aim to honor equivalent rights for users protected by other data-protection frameworks, including Nigeria's Data Protection Act 2023, Kenya's Data Protection Act 2019, and South Africa's Protection of Personal Information Act (POPIA). If a local law grants you rights beyond those described in this Policy, contact us and we will do our best to honor them.

16. Children's Privacy

The Service is not directed at, and we do not knowingly collect personal data from, children under the age of 16. If you believe a child has provided us with personal data, contact support@turnup.show and we will delete it.

17. Data Security

We use technical and organizational measures designed to protect personal data, including encryption of data in transit (HTTPS/TLS) and at rest, access controls limiting who can view data within our organization, and hashed (never plain-text) storage of passwords. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

18. Data Breach Notification

If we become aware of a security incident that risks your personal data, we will notify affected users and, where required by law, the relevant supervisory authority (such as Ghana's Data Protection Commission or an EU authority), without undue delay and in line with applicable legal timelines.

The Service may contain links to third-party websites (for example, a payment processor's checkout page or a map provider). We are not responsible for the privacy practices of those third parties; please review their own privacy policies.

20. Changes to this Policy

We may update this Policy from time to time. We will post the updated Policy with a new "Last updated" date and, for material changes, provide additional notice where required by law.

21. Contact Us

Bilo Tech Ltd — for any privacy question or to exercise your rights, contact support@turnup.show.