1. Introduction

Ahenemba Group Ltd, doing business as Ahenemba XP and Ahenemba Experience ("we," "us," or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, store, and protect your personal information in accordance with the Data Protection Act, 2012 (Act 843) of Ghana and the General Data Protection Regulation (GDPR) of the European Union.

By accessing our services, you consent to the practices described in this Privacy Policy. We are registered with the Data Protection Commission of Ghana and Registered with the Registrar of Companies, Ghana, maintaining strict compliance with international data protection standards.

2. Data Controller Information

Data Controller: Ahenemba Group Ltd (DBA Ahenemba XP / Ahenemba Experience)
Registered Address: 1 Pawpaw St, Accra, Ghana
Legal Contact: legal@ahenembaxp.com
Phone: +233 549200123
Registered with the Registrar of Companies, Ghana

3. Information We Collect

3.1 Personal Information

• Full legal name and any former names
• Date and place of birth
• Nationality and citizenship status
• Passport number and expiry date
• Residential address and proof of address
• Email address and telephone numbers
• Professional occupation and employer details
• Photographic identification

3.2 Financial Information

• Source of funds documentation
• Investment profile and net worth verification
• Bank references and financial statements
• Tax identification numbers
• Payment and transaction records

3.3 Special Categories of Data

We may process special categories of personal data where necessary for regulatory compliance, including:

• Health information relevant to travel arrangements
• Dietary requirements and accessibility needs
• Criminal background check results (for vetting purposes)

4. Legal Basis for Processing

Under GDPR and Ghana's Data Protection Act, we process your personal data based on the following legal grounds:

• Contractual Necessity: To fulfill our obligations under your membership agreement
• Legal Obligation: Compliance with anti-money laundering (AML) and know-your-customer (KYC) regulations
• Legitimate Interests: To ensure the security and quality of our services
• Consent: For marketing communications and optional services
• Vital Interests: For emergency medical situations

5. How We Use Your Information

• Processing and managing your membership application
• Delivering the sovereign experience and related services
• Compliance with regulatory requirements (KYC/AML)
• Security vetting and background verification
• Communication regarding your membership and experiences
• Quality assurance and service improvement
• Legal and regulatory reporting obligations
• Fraud prevention and security measures

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• AES-256 encryption for data at rest and in transit
• Secure server infrastructure with regular security audits
• Access controls and authentication protocols
• Regular staff training on data protection
• Incident response and breach notification procedures

7. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this policy:

• Active membership data: Retained throughout membership period
• Financial records: Retained for 7 years per Ghanaian tax law
• Regulatory compliance data: Retained as required by AML/KYC regulations
• Marketing preferences: Retained until consent is withdrawn

8. Your Rights

Under Ghana's Data Protection Act and GDPR, you have the following rights:

• Right to Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data (subject to legal obligations)
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time

9. International Data Transfers

Your personal data may be transferred to and processed in countries outside Ghana and the EU. We ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions for countries with adequate data protection
• Binding Corporate Rules for intra-group transfers

10. Third-Party Disclosures

We may share your personal data with:

• Regulatory authorities (Ghana Minerals Commission, GoldBod)
• Service providers (security, transportation, accommodation partners)
• Professional advisors (legal, accounting)
• Law enforcement when legally required

11. Cookies and Tracking

Our website uses cookies to enhance user experience. You can manage cookie preferences through your browser settings.

12. Changes to This Policy

We may update this Privacy Policy periodically. Significant changes will be communicated to you directly.

13. Contact Information

For questions about this Privacy Policy or to exercise your rights, contact us:

Email: legal@ahenembaxp.com
Postal Address: 1 Pawpaw St, Accra, Ghana
Phone: +233 549200123

14. Complaints

If you believe we have not handled your personal data appropriately, you have the right to lodge a complaint with:

• Ghana Data Protection Commission: info@dataprotection.gov.gh
• EU Supervisory Authority: If you are in the EU, your local data protection authority

Last Updated: March 2025

1. Introduction and Agreement to Terms

Welcome to Ahenemba Group Ltd, doing business as Ahenemba XP and Ahenemba Experience ("Ahenemba XP," "we," "us," or "our"). These Terms of Service ("Terms") constitute a legally binding agreement between you and Ahenemba Group Ltd, Registered with the Registrar of Companies, Ghana, regarding your access to and use of our website, services, experiences, and programs (collectively, the "Services").

By accessing or using our Services, submitting an application, making a payment, or participating in any Ahenemba XP experience, you acknowledge that you have read, understood, and agree to be bound by these Terms in their entirety. If you do not agree to these Terms, you must not access or use our Services.

We reserve the right to modify these Terms at any time. Changes will be effective immediately upon posting to our website. Your continued use of the Services following any changes constitutes your acceptance of the revised Terms.

2. Definitions

For the purposes of these Terms:

• "Experience" refers to any Ahenemba XP curated journey, program, or event, including but not limited to the 7-Day Sovereign Journey.
• "Participant" or "Member" means any individual who has been accepted into and participates in an Ahenemba XP Experience.
• "Application" refers to the formal submission for consideration to participate in an Ahenemba XP Experience.
• "Cohort" refers to a specific group of Participants undertaking an Experience together.
• "Confidential Information" means any non-public information disclosed by Ahenemba XP or other Participants during the Experience.
• "Gold Allocation" refers to the certified gold ownership component included in certain Experience tiers.

3. Eligibility and Membership Application

3.1 Age Requirement

Participation in Ahenemba XP Experiences is strictly limited to individuals who are 21 years of age or older at the time of application. By submitting an application, you represent and warrant that you meet this age requirement.

3.2 Application Process

All potential Participants must complete and submit a formal application. Submission of an application does not guarantee acceptance. Ahenemba XP reserves the sole and absolute discretion to accept or reject any application without obligation to provide reasons.

3.3 Due Diligence

As part of our commitment to maintaining the integrity and security of our Experiences, all applicants are subject to a comprehensive due diligence process, which may include:

• Identity verification and background checks
• Source of funds verification in compliance with anti-money laundering (AML) regulations
• Reference checks
• Verification of professional and personal information provided

You authorize Ahenemba XP to conduct such investigations and agree to provide all requested documentation promptly and accurately.

3.4 Accuracy of Information

You represent and warrant that all information provided in your application and throughout your relationship with Ahenemba XP is true, accurate, current, and complete. Providing false or misleading information may result in immediate rejection of your application or termination of your participation without refund.

4. Services Description

4.1 Experience Inclusions

Ahenemba XP Experiences are curated ultra-luxury programs that may include:

• Luxury accommodation and hospitality services
• Curated cultural, educational, and networking activities
• Access to exclusive locations and events
• Gold ownership certification and related services (where applicable)
• Ground transportation during the Experience
• Selected meals and refreshments

4.2 Specific Inclusions by Tier

The specific inclusions for your Experience will depend on the tier selected (EARTH, LEGACY, or VAULT). Detailed inclusions will be provided upon acceptance and prior to payment.

4.3 Exclusions

Unless explicitly stated, the following are not included:

• International and domestic airfare to and from Ghana
• Travel insurance (strongly recommended)
• Personal expenses, souvenirs, and optional activities
• Visa fees and passport costs
• Vaccinations and medical expenses
• Alcoholic beverages beyond what is provided as part of curated experiences

5. Payment Terms

5.1 Pricing

All pricing is quoted in United States Dollars (USD) unless otherwise specified. Prices are subject to change until your application is accepted and a formal offer is extended.

5.2 Payment Schedule

Upon acceptance into an Ahenemba XP Experience:

• Deposit: A non-refundable deposit of 30% of the total Experience fee is due within 7 days of acceptance to secure your place.
• Final Payment: The remaining balance is due no later than 60 days prior to the Experience start date.

Failure to make payments by the specified deadlines may result in forfeiture of your place and any deposits paid.

5.3 Payment Methods

We accept payment via bank wire transfer, major credit cards, and other methods as specified in your acceptance documentation. All bank fees and transfer charges are the responsibility of the Participant.

5.4 Late Payments

Late payments may incur administrative fees and may result in cancellation of your participation. Ahenemba XP reserves the right to offer your place to another applicant if payment is not received by the due date.

6. Cancellation and Refund Policy

6.1 Cancellation by Participant

If you need to cancel your participation, the following refund structure applies based on the date we receive your written cancellation notice:

• 90 days or more prior to start date: Full refund of amounts paid, minus the non-refundable 30% deposit.
• 60-89 days prior to start date: 50% refund of total Experience fee, minus the non-refundable deposit.
• 30-59 days prior to start date: 25% refund of total Experience fee, minus the non-refundable deposit.
• Less than 30 days prior to start date: No refund will be provided.

6.2 No-Show Policy

Failure to arrive for the Experience without prior written cancellation will result in forfeiture of all amounts paid with no refund.

6.3 Cancellation by Ahenemba XP

Ahenemba XP reserves the right to cancel any Experience due to circumstances beyond our reasonable control, including but not limited to:

• Insufficient number of Participants
• Force majeure events (natural disasters, political instability, pandemic, etc.)
• Safety concerns
• Other operational necessities

In the event of cancellation by Ahenemba XP, you will be offered the choice of:

• Full refund of all amounts paid, including the deposit
• Transfer of your booking to a future Experience of equivalent value

6.4 Travel Insurance

We strongly recommend that all Participants purchase comprehensive travel insurance covering trip cancellation, medical expenses, evacuation, and personal belongings. Ahenemba XP is not responsible for any costs incurred due to cancellation, interruption, or other circumstances.

7. Participant Responsibilities and Code of Conduct

7.1 General Conduct

Participants are expected to conduct themselves in a manner consistent with the exclusive and respectful nature of Ahenemba XP Experiences. This includes:

• Treating fellow Participants, staff, hosts, and local communities with respect and courtesy
• Adhering to all schedules and instructions provided by Ahenemba XP representatives
• Respecting local customs, traditions, and cultural sensitivities
• Maintaining appropriate behavior at all times

7.2 Prohibited Conduct

The following conduct is strictly prohibited:

• Illegal activities of any kind
• Harassment, discrimination, or abusive behavior toward any person
• Disruption of Experience activities or interference with other Participants
• Unauthorized recording, photography, or distribution of content featuring other Participants
• Consumption of illegal substances
• Damage to property

7.3 Consequences of Violations

Ahenemba XP reserves the right to remove any Participant from the Experience without refund for violation of these Terms or the Code of Conduct. In such cases, the Participant will be responsible for all costs associated with their departure.

7.4 Confidentiality

Participants agree to maintain the confidentiality of all information shared during the Experience, including but not limited to:

• Identity and personal information of other Participants
• Business and investment discussions
• Location details of exclusive venues
• Any information designated as confidential by Ahenemba XP

8. Intellectual Property

8.1 Ownership

All content, materials, trademarks, logos, and intellectual property displayed on our website and provided during Experiences are the exclusive property of Ahenemba XP or our licensors and are protected by intellectual property laws.

8.2 Limited License

We grant you a limited, non-exclusive, non-transferable license to access and use our website and materials for personal, non-commercial purposes only.

8.3 Media Release

By participating in an Ahenemba XP Experience, you grant us the right to capture photographs, video, and audio recordings that may include your likeness. You consent to our use of such media for promotional, marketing, and archival purposes without compensation. If you do not wish to be photographed or recorded, you must notify us in writing prior to the Experience.

8.4 Restrictions

You may not:

• Copy, reproduce, distribute, or create derivative works from our content without written permission
• Use our trademarks or logos without authorization
• Remove or alter any copyright or proprietary notices

9. Limitation of Liability

9.1 Assumption of Risk

Participation in Ahenemba XP Experiences involves inherent risks, including but not limited to:

• Travel-related risks and transportation hazards
• Physical activity and outdoor exposure
• Interaction with wildlife and natural environments
• Consumption of food and beverages
• Health risks associated with travel to Ghana

By participating, you voluntarily assume all such risks.

9.2 Limitation of Liability

To the maximum extent permitted by applicable law, Ahenemba XP and our officers, directors, employees, agents, and affiliates shall not be liable for any:

• Direct, indirect, incidental, special, consequential, or punitive damages
• Loss of profits, revenue, data, or business opportunities
• Personal injury, illness, or death
• Property damage or loss
• Any other damages arising from or related to your participation

9.3 Maximum Liability

In no event shall our total liability to you exceed the total amount you paid for the specific Experience giving rise to the claim.

9.4 Indemnification

You agree to indemnify, defend, and hold harmless Ahenemba XP and our affiliates from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising from:

• Your violation of these Terms
• Your violation of any third-party rights
• Your negligence or willful misconduct
• Any damage caused by you during the Experience

10. Insurance and Risk Acknowledgment

10.1 Insurance Requirement

All Participants are required to maintain comprehensive travel insurance throughout the Experience. Your insurance should cover:

• Emergency medical treatment and hospitalization
• Emergency medical evacuation and repatriation
• Trip cancellation and interruption
• Personal belongings and baggage
• Personal liability

10.2 Insurance Documentation

You may be required to provide proof of adequate insurance coverage prior to the Experience start date. Failure to provide such proof may result in denial of participation without refund.

10.3 No Insurance Provided

Ahenemba XP does not provide insurance coverage for Participants. We are not responsible for any costs or losses not covered by your personal insurance.

11. Health and Safety Requirements

11.1 Health Declaration

You represent that you are in good physical and mental health and have no medical conditions that would prevent you from safely participating in the Experience. You must disclose any medical conditions, allergies, or special requirements at the time of application.

11.2 Medical Clearance

We reserve the right to require a medical clearance from your physician if we have concerns about your fitness to participate. Additional medical documentation may be required for certain activities.

11.3 Vaccinations

Participants are responsible for ensuring they meet all vaccination and health requirements for entry into Ghana. This includes obtaining and carrying proof of yellow fever vaccination as required by Ghanaian law.

11.4 Emergency Medical Treatment

In the event of a medical emergency, you authorize Ahenemba XP to arrange for emergency medical treatment on your behalf. You are responsible for all associated costs.

12. Privacy and Data Protection

Your privacy is important to us. Our collection and use of your personal information is governed by our Privacy Policy, which is incorporated into these Terms by reference.

13. Governing Law and Dispute Resolution

13.1 Governing Law

These Terms shall be governed by and construed in accordance with the laws of the Republic of Ghana, without regard to its conflict of law principles.

13.2 Dispute Resolution

Any dispute, controversy, or claim arising out of or relating to these Terms or your participation in an Ahenemba XP Experience shall be resolved through the following process:

1. Negotiation: The parties shall first attempt to resolve the dispute through good faith negotiation.
2. Mediation: If negotiation fails, the parties shall attempt mediation through a mutually agreed mediator.
3. Arbitration: If mediation fails, the dispute shall be finally resolved through binding arbitration in Accra, Ghana, in accordance with the Arbitration Act, 1961 (Act 38) of Ghana.

13.3 Class Action Waiver

You agree that any proceedings shall be conducted only on an individual basis and not in a class, consolidated, or representative action.

13.4 Waiver of Jury Trial

To the extent permitted by law, you waive any right to a jury trial in any legal proceeding arising from these Terms.

14. Modifications to Terms

Ahenemba XP reserves the right to modify these Terms at any time. Changes will be effective immediately upon posting to our website with an updated "Last Updated" date. Your continued use of the Services after any changes constitutes your acceptance of the revised Terms. It is your responsibility to review these Terms periodically.

15. Force Majeure

Ahenemba XP shall not be liable for any failure or delay in performing our obligations under these Terms where such failure or delay results from circumstances beyond our reasonable control, including but not limited to:

• Acts of God, natural disasters, or extreme weather
• War, terrorism, civil unrest, or political instability
• Epidemics, pandemics, or public health emergencies
• Government actions, restrictions, or regulations
• Strikes, labor disputes, or industrial action
• Failure of utilities, transportation, or communication systems

16. Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be severed from these Terms, and the remaining provisions shall continue in full force and effect.

17. Entire Agreement

These Terms, together with our Privacy Policy and any other written agreements between you and Ahenemba XP, constitute the entire agreement between you and us regarding your participation in our Services and supersede all prior or contemporaneous agreements, understandings, and communications.

18. Waiver

No waiver of any provision of these Terms shall be effective unless in writing and signed by the party against whom the waiver is sought to be enforced. Our failure to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision.

19. Assignment

You may not assign or transfer these Terms or any rights or obligations hereunder without our prior written consent. Ahenemba XP may assign these Terms at any time without notice to you.

20. Third-Party Beneficiaries

These Terms do not create any third-party beneficiary rights except as expressly provided herein.

21. Notices

All notices and communications under these Terms shall be in writing and shall be deemed given when:

• Delivered personally
• Sent by confirmed email to the addresses on record
• Sent by registered or certified mail, return receipt requested

22. Gold Ownership Terms

22.1 Gold Allocation

For Experiences that include gold ownership (LEGACY and VAULT tiers), the following additional terms apply:

• Gold is allocated in the form of certified gold products meeting international standards
• Certificate of ownership will be provided upon completion of the Experience
• Storage and custody arrangements will be specified in your acceptance documentation

22.2 Gold Value

The value of gold allocated is based on market rates at the time of allocation. Ahenemba XP does not guarantee any future value or appreciation of gold holdings. Gold ownership involves market risks.

22.3 Transfer and Liquidation

Terms regarding transfer, sale, or liquidation of gold holdings will be provided in your gold ownership documentation.

23. Contact Information

If you have any questions, concerns, or comments about these Terms, please contact us:

Ahenemba Group Ltd (DBA Ahenemba XP / Ahenemba Experience)
Legal: legal@ahenembaxp.com
Concierge: concierge@ahenembaxp.com
Phone: +233 549200123
Address: 1 Pawpaw St, Accra, Ghana
Registered with the Registrar of Companies, Ghana

By submitting an application or participating in an Ahenemba XP Experience, you acknowledge that you have read, understood, and agree to be bound by these Terms of Service in their entirety.