Smalla Client Privacy Policy

Effective Date: 15 Aug 2026
Last Updated: 15 Aug 2026

1. About This Policy

This Privacy Policy explains how TETRACK TRADENET LTD (“Smalla”, “we”, “us” or “our”) collects, uses, stores, shares and protects your personal information when you use the Smalla client application.

The Smalla client application allows users to view mobile phone purchase or instalment orders, check repayment amounts, make repayments and access customer support. We only process information necessary to provide these functions, protect transaction security and comply with our legal obligations.

2. Information We Process

Depending on the functions you use, we may process:

• Account information: Your name, mobile phone number, account identifier and authentication information submitted during registration or login.
• Order and repayment information: Mobile phone purchase or instalment orders, contract number, repayment amount, payment due date, payment result, refund and reconciliation records.
• Approximate location: With your permission, we collect and transmit your approximate regional location to Smalla’s servers when you use relevant functions.
• Device and security information: App version, device model, operating system version, login time, crash records and security logs.
• Customer support information: Enquiries, complaints, feedback and related communication records you submit.
• Information returned by service providers: Payment results, identity or transaction verification results, and other information necessary to complete repayments and protect transaction security.

3. How We Use Information

We use this information to:

• Create, authenticate and protect your account.
• Display and manage orders, contracts, repayment amounts and payment due dates.
• Process payments, refunds, reconciliation and repayment reminders.
• Determine whether relevant services are available in your approximate area.
• Detect abnormal logins, unusual payments, identity misuse and other fraud risks.
• Handle enquiries, complaints and after-sales support.
• Perform contracts and comply with applicable accounting, auditing, consumer protection and regulatory obligations.

Where information is not necessary to provide a particular function, you may refuse to provide it. Refusal will only affect the specific function that depends on that information.

4. Permission Disclosure

The Smalla client application only requests permission when required for a specific function. You may refuse permission or disable previously granted permission at any time through your Android system settings.

4.1 Approximate Location

Purpose: When you actively use a relevant function, the application securely transmits your approximate regional location to Smalla’s servers. We use it to determine whether repayment or other services are available in your area and to assist in detecting unusual transaction risks.

Is it required? No. You may disable this permission. If disabled, functions that determine service availability based on your current location may not be available. You may continue using other functions that do not depend on location.

The Smalla client application only accesses your approximate location. It does not access your location while the application is not in use. Location permission is requested only when you access a relevant function, and location access stops when that function is completed.

Uploaded approximate location information is not used for advertising or marketing. Location records are retained according to the retention period for general customer information or security logs described in Section 7, depending on the relevant business purpose.

5. Information Sharing and Processing by Service Providers

We do not sell or rent your personal information. We do not permit service providers to use your information for their own marketing purposes.

To the extent necessary to provide our services, we may appoint the following categories of service providers to process necessary information:

• Payment providers, to process payments, refunds and reconciliation.
• Cloud hosting and server providers, to operate the service securely and store service data.
• SMS and messaging service providers, to deliver verification codes, transaction results and service messages.
• Security and fraud prevention providers, to identify unusual accounts or transactions.
• Customer support technology providers, to process enquiries and complaints.

These service providers may only process information according to our instructions and must comply with confidentiality and security obligations.

We may also disclose necessary information where you have given explicit consent, where disclosure is required to comply with applicable law, or in response to a lawful request from a court or competent regulatory authority.

6. Data Storage and Transfer Location

Your information is uploaded to and stored in cloud service facilities located in Ghana.

The data recipient is Smalla, operated by TETRACK TRADENET LTD, and the cloud service provider is Huawei Cloud.

If your information is transferred outside Ghana, we will implement the necessary contractual, security and cross-border transfer safeguards required under applicable Ghanaian data protection laws.

7. Information Retention and Deletion

We retain information only for as long as necessary to fulfil the relevant processing purpose or comply with applicable legal obligations.

Where applicable Ghanaian law, a regulatory investigation or dispute requires a longer retention period, we will retain the relevant information only to the extent necessary. It will be deleted or anonymised when the reason for continued retention no longer applies.

8. Account and Information Deletion

You may request account deletion through the Delete Account option within the application. You may also submit a request through our official website or the contact details in Section 13.

After your account is deleted, we will delete the information associated with it. Contracts, transaction records, identity verification records or anti-money laundering information that must be retained by law will be restricted and retained only for the applicable statutory period. They will be deleted when that period expires.

Uninstalling the application does not automatically delete your account or information stored on our servers.

9. Information Security

We implement security measures appropriate to the risks involved, including encryption in transit, access controls, least-privilege access, log auditing, employee confidentiality requirements and security incident response procedures.

These measures are designed to protect information against unauthorised access, disclosure, alteration or loss.

10. Your Rights

Subject to applicable Ghanaian law, you may request access to, correction of or deletion of your personal information. You may also object to or request restrictions on certain processing activities and withdraw previously granted consent.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

To protect your account, we may verify your identity before responding to a request. We will respond within the period required by applicable law.

11. Minors

Smalla’s mobile phone instalment and financing services are not intended for anyone under 18 years of age or below the applicable legal age to enter into a contract.

If we become aware that we have unintentionally collected information from a minor, we will stop processing and delete the relevant information as required by law.

12. Changes to This Policy

We may update this Privacy Policy when our service functions, information processing practices or applicable laws change.

Before a material change takes effect, we will notify you through an in-app notice or another appropriate method. Where renewed consent is legally required, we will obtain it before beginning the relevant processing.

13. Contact Us

Operating Company: TETRACK TRADENET LTD

Customer Support Email: support@smalla.info

Customer Support Telephone: +233 540991676

Data Protection Officer Email: dpo@smalla.info

Registered Address: HOUSE NUMBER CE-182-5697, Windybay Avenue, close to Chicken Man Pizza Man, Winneba, Cape Coast, Effutu Municipal, Central Region, Ghana.