This Privacy Policy explains how JSN Digital (“we”, “us”, or “our”) collects, uses, shares, and protects personal data when you use SusuTracks (the “Service”). We operate under Ghana’s Data Protection Act, 2012 (Act 843).

It covers two kinds of people: the operators and staff who use SusuTracks to run their business, and the savings customers whose records those operators enter into the Service.

For the personal data of your own savings customers that you enter into the Service, you (the operator) are the data controller and we are your data processor — we process that data on your instructions to provide the Service.

For account and billing data about you and your staff, and for data we collect to run and secure the platform, we act as the data controller.

Account data: the business name, admin name, email, and phone number you provide when you sign up.

Operational data you enter: your agents’ details and your customers’ details — names, phone numbers, contributions, balances, and collection history — needed to run your collections.

Technical data: limited information such as device and log data needed to operate the Service securely, sync offline records, and diagnose problems.

We use personal data only to provide, support, secure, and improve the Service: running collections, syncing agent records, sending SMS receipts on your behalf, generating your reports, billing, and communicating with you about your account.

We do not sell your data, and we do not use your customers’ data for advertising.

We process personal data on the basis of performing our contract with you, your consent where required, our legitimate interest in operating and securing the Service, and compliance with our legal obligations under Ghanaian law.

Collection receipts and related notifications are sent by SMS to the customer numbers you provide, through a licensed messaging gateway.

As the controller of your customers’ data, you are responsible for having a lawful basis and the right to contact those customers.

We share personal data only with service providers who help us run SusuTracks — for example our cloud hosting provider and our SMS gateway — and only to the extent needed to provide the Service. These providers are bound to protect the data.

We may disclose data where required by law or a valid order from a competent Ghanaian authority. We do not otherwise share your data with third parties.

Data is encrypted in transit (TLS) and at rest. Access is controlled at the database level so that each agent can only see their assigned customers.

Agent PINs are never stored in plain text — they are protected with bcrypt hashing, on the device and on the server. We take reasonable technical and organisational measures to protect personal data against loss, misuse, and unauthorised access.

We keep Customer Data for as long as your account is active. On cancellation we provide a full export of your data on request.

After that, we delete or anonymise personal data in line with our retention schedule, except where we must keep certain records to meet legal or accounting obligations.

Under Act 843 you have the right to access your personal data, to correct inaccurate data, to object to or restrict certain processing, and to request deletion of your data, subject to legal limits.

If you are a savings customer of an operator that uses SusuTracks, please contact that operator first, as they control your records. To exercise any right regarding data we control, email hello@susutracks.com.

The Service is intended for business use by operators and their staff. We do not knowingly collect personal data directly from children through the Service.

We may update this Privacy Policy from time to time. If we make material changes we will notify admins by email or in-app and update the “last updated” date above.

Privacy questions or requests? Email hello@susutracks.com. JSN Digital is based in Accra, Ghana, and is registered with Ghana’s Data Protection Commission.