Last updated: September 26, 2026
1. Who we are and what this policy covers
360 IDEAS (ATLAS 360 IDEAS) is a marketing and advertising company based in Accra, Ghana. We are responsible for the personal information described in this policy.
This policy explains what personal information we collect, why, who we share it with, how long we keep it, and the rights you have. It applies to:
- Our website, 3sixtyideas.com, including our blog, pricing, contact and careers pages.
- Bookings and consultations made through our booking page, calendar links, phone, email or social media.
- Our marketing and advertising services, including brand strategy, market research, customer segmentation, social media management, content marketing, SEO, email marketing, paid advertising and media buying, influencer marketing, livestream commerce, product video shoots, web design and development, traditional media (TV, radio, print, out-of-home), analytics and reporting.
- Campaign Portal, our client portal at app.3sixtyideas.com, where clients view live campaign performance, approve content, message our team, manage assets and budgets, and receive reports.
- Our own social media pages on Facebook, Instagram, LinkedIn, TikTok and X.
- Recruitment, when you apply for a role with us.
This policy is written for Ghana’s Data Protection Act, 2012 (Act 843). If you are outside Ghana, you may have additional rights under your local law, and we will honour them where they apply.
This policy does not cover third-party websites or platforms we link to, such as Meta, Google, TikTok or LinkedIn. Their own privacy policies apply when you use them.
2. Key terms
| Term | Meaning in this policy |
| Personal information | Any information that identifies you or can be linked to you, such as your name, phone number, email, IP address or photo. Act 843 calls this “personal data”. |
| Special personal information | Sensitive information such as health, religious or political beliefs, ethnic origin, criminal records, or information about children. Act 843 calls this “special personal data”. |
| Client | A business or organisation that engages 360 IDEAS for services or subscribes to Campaign Portal. |
| Portal user | Anyone with a Campaign Portal login: client team members and 360 IDEAS staff. |
| Campaign audience | People who see, click, respond to, or buy from a client’s advertising or content that we manage. |
| Data controller | The party that decides why and how personal information is used. |
| Data processor | A party that handles personal information only on a controller’s instructions. |
| Ad platforms | Advertising and social platforms such as Meta (Facebook, Instagram), Google (Search, YouTube, Display), TikTok and LinkedIn. |
3. Our role: controller or processor
We are the data controller for information about our own website visitors, prospects, clients’ contact people, portal users, influencers we contract, and job applicants. We act as a data processor when we handle a client’s customer or audience data to run that client’s campaigns.
In practice:
- When we are the controller, this policy governs how we use your information, and you can exercise your rights directly with us.
- When we act for a client, the client decides what data is used and why. Examples include a customer list the client uploads for a lookalike audience, leads collected through a client’s ad form, orders received during a client’s livestream, or the client’s email subscribers. We use that data only to deliver the agreed services and follow the client’s instructions and our service agreement with them.
- If you are a client’s customer and want to access, correct or delete your information, please contact that business first. If you contact us, we will pass your request to the client and help them respond.
Clients are responsible for having a lawful basis, including any required consent, for the personal information they share with us or ask us to collect for them. Our service agreements set out each party’s responsibilities in more detail.
4. Information we collect
What we collect depends on how you interact with us. We collect only what we need for the purpose involved.
| Who you are | Information we collect |
| Website visitor | IP address, device and browser type, pages viewed, referring site, approximate location, and cookie or pixel identifiers (see Section 8). |
| Prospect or enquirer | Name, business name, role, email, phone or WhatsApp number, industry, the service you are interested in, your budget range, and anything you tell us during a consultation. |
| Client contact | Contact details, job title, billing details, invoices and payment records, contracts, and communications with our team. |
| Client business materials | Brand assets, product information, business goals, and login or admin access to your social media, ad accounts, website or email tools, where you grant it. |
| Campaign Portal portal user | Name, work email, role, hashed password, two-factor authentication settings, profile and notification preferences, messages, approval decisions and comments, uploaded files, and activity logs including IP address and timestamps. |
| Campaign audience (on a client’s behalf) | Aggregated ad performance data (impressions, reach, clicks, spend, conversions); lead form submissions; comments, messages and orders on managed pages or livestreams; and customer lists a client supplies for targeting. |
| Influencer or content creator | Name, handle, follower and engagement statistics, contact details, rates, payment details, contracts, and content you produce for a campaign. |
| Person featured in our content | Photos, video, voice and name, for example in product shoots, testimonials or event coverage. |
| Social media follower | Your public profile, comments, messages and reactions on our pages, plus aggregated page insights the platforms provide. |
| Job applicant | CV, contact details, work history, qualifications, references, portfolio links and interview notes. |
Special personal information. We do not intentionally collect special personal information. Our psychographic approach uses interests, values, attitudes and behaviours at an audience or segment level, not individual profiles of sensitive traits. Ad platform targeting we set up follows each platform’s rules on sensitive categories. If a campaign ever needs special personal information, we will only proceed with explicit consent or another basis allowed by Act 843.
Payment information. Card and mobile money payments are handled by PAYMENT PROVIDER. We do not store full card numbers.
5. How we collect it
We collect information in three ways:
- From you directly, when you fill in a form, book a consultation, email, call or message us, sign a contract, use Campaign Portal, send us files, or apply for a job.
- Automatically, through cookies, pixels and server logs on our website and in Campaign Portal.
- From third parties, including ad platforms and social networks (performance and audience data for accounts you authorise us to manage), our clients (customer lists, brand materials), booking and payment providers, influencer agencies, referrers, and public sources such as business directories and public social profiles.
6. How we use it and our lawful basis
Act 843 only allows us to process personal information when we have a lawful reason. The table shows each purpose and the reason we rely on.
| Purpose | Examples | Lawful basis |
| Respond to enquiries and run consultations | Replying to a contact form, preparing a proposal or quote | Steps you ask for before a contract; our legitimate interest in answering enquiries |
| Deliver agreed services | Running social media, creating content, buying media, managing ad accounts, building websites, coordinating influencers | Performance of our contract with the client |
| Provide Campaign Portal | Creating accounts, syncing ad platform data, approvals, messaging, budget tracking, scheduled reports | Performance of our contract |
| Measure and report results | Dashboards, weekly and monthly reports, ROI analysis | Performance of our contract |
| Keep systems secure | Two-factor authentication, audit logs, fraud and abuse prevention, error monitoring | Legitimate interest in security; legal obligations |
| Bill and keep financial records | Invoices, payment tracking, tax filings | Contract; legal obligation |
| Market our own services | Newsletters, event invitations, retargeting ads for 360 IDEAS | Your consent where required; otherwise legitimate interest, with an easy opt-out |
| Improve our services | Website analytics, product feedback, aggregated campaign benchmarks | Legitimate interest |
| Showcase our work | Portfolio, case studies, testimonials (see Section 15) | Consent, or the client agreement |
| Recruit staff | Assessing applications, interviews | Steps before an employment contract; legitimate interest |
| Meet legal duties | Responding to lawful requests, resolving disputes | Legal obligation; legitimate interest in defending claims |
Aggregated benchmarks. We may combine campaign performance data across clients to understand typical results by industry or channel. These benchmarks are anonymised and never identify a client or individual.
Automated decisions. We do not make decisions that have a legal or similarly significant effect on you based solely on automated processing. Ad platforms use automated systems to deliver ads; their policies govern that.
7. Campaign Portal
Campaign Portal reads advertising performance data from ad accounts a client authorises, and stores portal activity so clients and our team can collaborate. It does not sell data, and it does not use ad platform data for any purpose other than showing the client its own campaign results.
7.1 Ad platform connections
When a client connects an ad account, Campaign Portal uses the platform’s official API to read:
- Campaign, ad set and ad names, status, budgets and schedules.
- Performance metrics such as impressions, reach, clicks, spend, conversions and cost per result.
- Aggregated audience breakdowns (for example by age band, region or device) where the platform provides them.
Connected platforms are Meta (Facebook and Instagram) via the Marketing API, Google Ads via the Google Ads API, TikTok via the TikTok Marketing API, and LinkedIn via the LinkedIn Marketing API where enabled. Campaign Portal syncs this data on a schedule and stores daily snapshots so clients can see trends and budget pacing.
Campaign Portal does not collect individual-level data about people who see a client’s ads through these connections. The data is aggregated by the platforms.
7.2 How platform data is used
We use data received from ad platform APIs only to:
- Display the connected client’s own campaign performance, budgets and reports in Campaign Portal.
- Let our authorised team manage and optimise that client’s campaigns as agreed.
- Generate the client’s scheduled or on-demand reports.
We do not use platform data to build advertising profiles, sell or rent it, share it with other clients, or use it to train general-purpose AI models.
Google. Campaign Portal’s use and transfer of information received from Google APIs follows the Google API Services User Data Policy, including its Limited Use requirements.
Meta, TikTok and LinkedIn. Our use of data from these platforms follows their platform terms and developer policies.
7.3 Portal data
Campaign Portal stores account details, role assignments, approval requests and decisions, threaded comments, messages, uploaded assets, budget records, generated reports and notifications. Every data-changing action is written to a tamper-resistant audit log with the user ID, time, IP address and action type. Clients control who sees what through built-in roles, and our staff can only access accounts assigned to them.
7.4 Disconnecting and deleting data
You can stop Campaign Portal from accessing an ad account at any time:
- In Campaign Portal, an account Owner can go to Settings and disconnect the platform.
- You can also remove access from the platform itself:
- Meta: Facebook Settings > Business Integrations (or Meta Business Settings > Integrations) and remove Campaign Portal.
- Google: your Google Account > Security > Third-party connections, or Google Ads > Admin > Access and security.
- TikTok: TikTok Ads Manager > Account settings > Authorised apps.
- LinkedIn: LinkedIn Settings > Data privacy > Permitted services.
After disconnection, we stop syncing new data. To delete data already stored, email privacy@3sixtyideas.com from the account Owner’s email address with the subject “Campaign Portal data deletion”. We confirm receipt within 5 working days and delete synced platform data, portal content and user accounts within 30 days, except records we must keep by law (such as invoices) and backups, which are overwritten on their normal cycle. We will send you a confirmation reference once deletion is complete.
If a client’s subscription ends, we keep their Campaign Portal data for 90 days so they can export it, then delete it as above.
8. Cookies, pixels and analytics
Our website uses cookies and similar tools, managed through Google Tag Manager, to keep the site working, understand how it is used, and measure our own advertising. Campaign Portal uses only the cookies needed for login and security.
| Type | What it does | Examples | Can you refuse? |
| Strictly necessary | Keeps the site and Campaign Portal secure and working, e.g. login sessions | Campaign Portal session and security cookies; Website cookies | No, the service will not work without them |
| Analytics | Counts visits and shows which pages are used, in aggregate | Google Analytics 4 | Yes |
| Advertising | Measures and retargets 360 IDEAS ads to past visitors | Meta Pixel, TikTok Pixel, LinkedIn Insight Tag, Google Ads tags | Yes |
| Embedded content | Loads booking, calendar or media content from other providers | Setmore, Google Calendar, YouTube | Yes, but some features may not load |
Where required, we ask for your consent before setting non-essential cookies, and you can change your choice at any time through the cookie banner or settings link in our website footer. You can also block or delete cookies in your browser settings, and opt out of personalised ads through Google Ads Settings, Meta’s Ad Preferences, and TikTok’s ad settings.
When we run campaigns for clients, the pixels and tags on the client’s own website are governed by the client’s privacy and cookie policy.
9. Marketing communications and opting out
We send marketing emails, WhatsApp messages or SMS about 360 IDEAS only when you have agreed to receive them, or when you are an existing client or enquirer and the message relates to similar services. You can opt out at any time, free of charge, and we will stop within 10 working days.
To opt out, use the unsubscribe link in any email, reply “STOP” to an SMS or WhatsApp message, or email privacy@3sixtyideas.com. Opting out of marketing does not stop service messages we need to send, such as invoices, approval requests, Campaign Portal security alerts and scheduled reports.
When we send email or SMS campaigns on behalf of clients, we use only contact lists the client confirms were collected lawfully, and every message includes a way to opt out.
10. Who we share information with
We do not sell personal information. We share it only with the people and providers below, and only as much as each needs.
| Category of recipient | Why we share | Where they may be located |
| Our team and contractors | To deliver services; access is limited by role and bound by confidentiality | Ghana |
| Our clients | To report campaign results, leads and orders collected for them | Client’s location |
| Advertising and social media platforms (such as Meta, Google, TikTok, LinkedIn and X) | To run, target and measure campaigns, and to upload client-approved audience lists, which platforms match in hashed form | Mainly United States and Europe |
| Media, influencer and production partners | To deliver campaigns, such as TV, radio, print and out-of-home placements, shoots and livestreams | Mainly Ghana |
| Cloud hosting and storage providers | To host our website, the Campaign Portal application, its database, files and reports | United States, Europe and global |
| Communication providers | To send account, notification and marketing emails and messages | United States and global |
| Scheduling and productivity tools | To manage consultation bookings, calendars, email and documents | United States and global |
| Analytics and security monitoring providers | To understand website use, detect errors (with personal data scrubbing) and keep our services reliable | United States and global |
| Payment processors | To process payments | Processor’s location |
| Professional advisers | Lawyers, accountants and auditors, under confidentiality | Ghana |
| Authorities | Where the law requires, such as tax authorities, courts or the Data Protection Commission | Ghana |
Our service providers may only use your information to provide their service to us. If 360 IDEAS is merged, acquired or restructured, personal information may transfer to the new owner, who must continue to protect it under this policy.
11. International transfers
Some of our providers store or process information outside Ghana. When this happens, we choose providers with strong security, use contracts that require them to protect personal information to a standard comparable to Act 843, and transfer only what is needed. You can ask us for more detail about the safeguards for a specific provider.
12. How long we keep information
We keep personal information only as long as needed for the purpose we collected it, then delete or anonymise it.
| Information | How long we keep it |
| Enquiries and consultation notes (no contract signed) | 12 months after last contact |
| Client contracts, invoices and payment records | 6 years after the end of the engagement, or as Ghana tax law requires. |
| Campaign files, content and reports | Length of the engagement plus 2 years |
| Campaign Portal account and portal data | While the subscription is active, plus 90 days for export, then deleted |
| Campaign Portal audit logs | 2 years, for security and dispute resolution |
| Synced ad platform data | While the connection is active; deleted within 30 days of a deletion request |
| Client-supplied audience lists | Deleted from our systems once uploaded to the platform or when the campaign ends, whichever is sooner |
| Marketing lists | Until you opt out; we keep a minimal suppression record so we do not contact you again |
| Website analytics | 14 months (Google Analytics setting) |
| Job applications | 12 months after the role is filled, unless you agree to a longer period |
| Portfolio and testimonials | Until you or the client asks us to remove them |
13. How we protect information
We use technical and organisational safeguards suited to the sensitivity of the information. They include:
- Encryption in transit (HTTPS/TLS) on our website and Campaign Portal, and encryption of sensitive stored values such as two-factor authentication secrets.
- Two-factor authentication, mandatory for all 360 IDEAS staff and available to every Campaign Portal user.
- Role-based access enforced on our servers, so each person sees only what their role allows.
- Automatic session timeouts after inactivity.
- A tamper-resistant audit log of every data-changing action in Campaign Portal.
- Secure, time-limited links for file uploads and downloads.
- Personal data scrubbing in our error-monitoring tools.
- Confidentiality obligations for staff and contractors, and access to client ad accounts only through the platforms’ own permission systems where possible.
No system is completely secure. If a security breach affects your personal information, we will notify the Data Protection Commission and affected people as Act 843 requires, and tell you what we are doing about it. Please keep your Campaign Portal password private and tell us immediately if you think your account has been compromised.
14. Your rights
Under Act 843 you have the following rights over personal information we hold as data controller:
| Right | What it means |
| Access | Ask whether we hold information about you and get a copy, with details of how we use it. |
| Correction | Ask us to correct or complete inaccurate or out-of-date information. |
| Deletion | Ask us to delete information we no longer need or have no lawful basis to keep. |
| Object | Object to processing that causes you unwarranted damage or distress. |
| Stop direct marketing | Tell us to stop using your information for marketing at any time. |
| Withdraw consent | Where we rely on consent, withdraw it at any time. This does not affect earlier processing. |
| Automated decisions | Ask for a human review of any decision made solely by automated means that significantly affects you. |
| Compensation | Seek compensation if you suffer damage because we breached Act 843. |
How to make a request. Email privacy@3sixtyideas.com to submit requests. We may ask you to confirm your identity before responding. We aim to respond within 21 days and will tell you if we need longer. Requests are free, unless they are clearly unfounded or excessive.
If your request is about data we hold for one of our clients (see Section 3), we will forward it to that client and support their response.
15. Portfolio, testimonials and content featuring people
We may show completed work, client names, logos, results and testimonials in our portfolio, website, social media and proposals, as our Terms & Conditions allow, unless a client asks us not to in writing. We do not publish confidential campaign data without permission.
When a person appears in photos, video or audio we produce, such as a model, staff member, customer or event attendee, we get their consent or a signed release before using it in published content. Testimonials are published with the person’s permission and only with the name and details they approve. You can ask us to remove your image or testimonial at any time; we will remove it from content we control within 14 days, though copies already shared by others may remain.
16. Children
Our services and Campaign Portal are for businesses and adults. We do not knowingly collect personal information from anyone under 18. We do not target advertising at children or feature a child in campaign content without the written consent of a parent or guardian. If you believe we have a child’s information without that consent, contact us, and we will delete it.
17. Changes, contact and complaints
Changes. We may update this policy as our services, Campaign Portal features or the law change. We will post the new version on this page with a new “last updated” date, and notify clients and Campaign Portal users by email or in-app notice before significant changes take effect.
Contact us. For any privacy question or request:
Data Protection Supervisor: Atingane Adumbire
ATLAS 360 IDEAS, Ashaley Botwe, Accra, Ghana
Email: privacy@3sixtyideas.com
Phone: +233 546 649 261
Website: https://3sixtyideas.com
Complaints. If you are unhappy with how we have handled your information, please contact us first so we can try to resolve it. You also have the right to complain to the Data Protection Commission of Ghana at dataprotection.org.gh.
