Smalla Sales 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 the personal information of authorised sales personnel and customers when the Smalla Sales application is used.

Smalla Sales helps authorised sales personnel assist customers with purchasing mobile phones, completing and submitting applications, determining service availability, capturing application documents, completing identity verification and checking application results.

Before entering or capturing customer information, sales personnel must explain what information will be processed, why it is required, and confirm that the customer has been informed.

2. Information We Process

Depending on the transaction being handled, we may process:

• Sales account information: The sales representative’s name, mobile phone number, employee or sales identifier, login credentials, assigned store and business permissions.
• Customer application information: The customer’s name, contact details, date of birth, address, occupation, income or payment-capacity information, and application form information voluntarily provided by the customer.
• Identity verification information: Identity document details, photographs of identity documents, on-site facial photographs and identity verification results voluntarily provided by the customer.
• Order and contract information: The selected mobile phone, price, initial payment, instalment amount, repayment period, fees, repayment schedule, contract, signature and delivery records.
• Approximate location: With the sales representative’s permission, approximate regional location information collected during relevant transactions and transmitted to Smalla’s servers.
• Device and security information: App version, device model, operating system version, IP address, login time, network type, crash records and security logs.
• Customer service and business records: Enquiries, complaints, after-sales support records, application review records and business operation records.
• Information returned by service providers: Payment, identity verification, application review and fraud prevention results.

3. How We Use Information

We use this information to:

• Verify the identity, login status and business permissions of sales personnel.
• Assist customers in completing and submitting mobile phone purchase or instalment applications.
• Determine whether relevant services are available in the approximate area where the transaction is being handled.
• Capture and submit application materials voluntarily provided by customers.
• Verify customer identity, on-site liveness, orders and device delivery.
• Detect duplicate applications, identity misuse, unusual orders and other fraud risks.
• Handle business enquiries, complaints, after-sales support and compliance audits.
• Perform contracts and comply with applicable accounting, auditing, consumer protection and regulatory obligations.

4. Permission Disclosure

Smalla Sales only requests permission when required for a specific business step. Sales personnel may refuse permission or disable previously granted permission at any time through their Android system settings.

4.1 Camera

Purpose: When initiated by the sales representative, the camera is used to capture customer identity documents, application materials and delivery evidence, scan business QR codes, and complete on-site identity or liveness verification.

Is it required? No. If camera permission is disabled, photography, scanning or identity verification functions within the relevant application process may not be available. Other functions that do not depend on the camera will remain available.

The camera is activated only after the sales representative enters the relevant page and initiates the function. Before each capture, the sales representative must explain what will be photographed and why, and obtain the customer’s consent.

4.2 Approximate Location

Purpose: When handling a relevant transaction, Smalla Sales securely transmits the device’s approximate regional location to Smalla’s servers. We use it to determine whether services are available in that area and to assist in detecting unusual applications and transaction risks.

Is it required? No. If this permission is disabled, the system may be unable to determine which services are available in the current area. Some processes that depend on service-area assessment or location-assisted fraud prevention may not continue. Other functions that do not depend on location will remain available.

Smalla Sales only accesses approximate location. It does not access location while the application is not in use. Location permission is requested only when required to determine service availability or process a relevant order, and location access stops when the 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 8, depending on the relevant business purpose.

4.3 Notifications

Purpose: To send new task alerts, application review results, order status updates and account security notifications.

Is it required? No. If notifications are disabled, sales personnel may not receive system alerts promptly but may still access the application to view the relevant information.

5. Identity Document Photographs and Facial Verification

With the customer’s consent and after the function is initiated by the sales representative, Smalla Sales may capture photographs of the customer’s identity documents and face.

These photographs are used to verify that the applicant is the holder of the identity document, confirm that the application is being completed in person and prevent identity misuse.

Facial detection is used to determine whether a single face is present in the camera frame and whether the customer has completed the actions requested on the screen. Photographs and verification results are used only for identity verification, application review and fraud prevention. They are not used for advertising, marketing or facial recognition unrelated to the relevant application.

Photographs are initially stored in the application’s private temporary directory on the sales device. They are deleted from that directory after successful submission, cancellation of the application or completion of the necessary processing.

Photographs submitted to Smalla’s servers are retained according to Section 8.

Facial template disclosure: [Before publication, confirm whether the application creates or stores facial feature templates. Replace this text with either “Smalla does not create or store facial feature templates” or an accurate description of the processing.]

6. Information Sharing and Processing by Service Providers

We do not sell or rent the personal information of sales personnel or customers. We do not permit service providers to use such 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:

• Cloud hosting and server providers, to operate the service securely and store application information.
• SMS and messaging service providers, to deliver verification codes, tasks and review results.
• Identity verification and fraud prevention providers, to verify identities and identify unusual applications.
• Payment providers, to confirm initial payments, repayments and refunds.
• Authorised financing, contract-performance or device-delivery service providers, to review applications, enter into and perform contracts, and complete delivery.
• Customer support technology providers, to handle enquiries, complaints and after-sales support.

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 the customer or sales representative has 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.

7. Data Storage and Transfer Location

Information relating to sales personnel and customers is uploaded to and stored on Smalla servers or 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 information is transferred outside Ghana, we will implement the necessary contractual, security and cross-border transfer safeguards required under applicable Ghanaian data protection laws.

8. 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.

9. Account and Information Deletion

Sales personnel and customers may submit a request to access, correct or delete their information through the application, our official website or the contact details provided in Section 13.

After receiving a valid deletion request, we will delete the relevant information. 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 accounts or business information stored on our servers.

10. Information Security

We implement security measures appropriate to the risks involved, including encryption in transit, access controls, separation of sales personnel permissions, 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.

Sales personnel must not save customer materials to personal photo galleries, forward them through personal communication accounts or use them for any purpose unrelated to Smalla business.

11. Your Rights

Subject to applicable Ghanaian law, customers and sales personnel may request access to, correction of or deletion of their personal information. They 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 information security, we may verify the applicant’s identity before responding to a request. We will respond within the period required by applicable 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 users 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.