BISAME PLATFORM & BRAND PRIVACY POLICY

Last Updated: September 28, 2026
Effective Date: September 28, 2026
Legal Data Controller: BisaMe Digital Limited ("BisaMe", "We", "Us", "Our")
Applicable Ecosystem: Mobile Applications (iOS & Android), Web Application (bisame.com), BisaMe Ride, BisaMe Marketplace, BisaMe Trade Assurance (BTA), Merchant Portals, and Backend APIs.

[!IMPORTANT] YOUR PRIVACY MATTERS TO US.
This Privacy Policy explains how BisaMe Digital Limited collects, uses, stores, shares, discloses, and protects your personal data when you interact with our mobile application, web application (bisame.com), and associated services. It outlines your statutory privacy rights under the Ghana Data Protection Act, 2012 (Act 843), the General Data Protection Regulation (GDPR), Apple App Store Privacy Guidelines (Section 5.1), and Google Play Developer User Data Policies.

TABLE OF CONTENTS

1. Executive Summary & Regulatory Framework
2. Data Categories We Collect Across Mobile & Web
3. Sensitive Permissions & Prominent Disclosures
4. How We Collect Your Data
5. Legal Bases & Purposes of Data Processing
6. Data Sharing, SDKs & Third-Party Processors
7. Location Data & Background GPS Policy
8. Identity Verification & Ghana Card KYC Processing
9. Financial Data & Mobile Money Security
10. Data Retention, Archival & Destruction
11. Account Deletion & Self-Service Erasure (Apple & Google Mandate)
12. Security Architecture & Technical Safeguards
13. Your Statutory Privacy Rights
14. Children's Privacy & Age Restrictions
15. International Data Transfers
16. Policy Changes & Official Contact Information

1. EXECUTIVE SUMMARY & REGULATORY FRAMEWORK

BisaMe Digital Limited is committed to maintaining a transparent, secure, and privacy-respecting platform for e-commerce, mobility, trade assurance, and merchant business services.

• Data Controller Identity: BisaMe Digital Limited, incorporated in Accra, Ghana, acts as the Data Controller responsible for your personal information.
• Compliance Framework: Our privacy infrastructure strictly complies with:
  1. Ghana Data Protection Act, 2012 (Act 843)
  2. Electronic Transactions Act, 2008 (Act 772)
  3. Apple App Store Review Guidelines (Section 5.1.1 & 5.1.2)
  4. Google Play Developer User Data & Target API Policies
  5. EU General Data Protection Regulation (GDPR) / UK GDPR (for international visitors).

2. DATA CATEGORIES WE COLLECT ACROSS MOBILE & WEB

We collect personal data to operate, secure, and personalize the BisaMe platform across mobile and web environments:

3. SENSITIVE PERMISSIONS & PROMINENT DISCLOSURES

Pursuant to Google Play Policies and Apple Privacy Guidelines, BisaMe provides explicit, runtime disclosures before requesting access to sensitive device features:

• Location (Foreground & Background): Required to connect riders with nearby drivers, calculate transportation routes, track BTA deliveries, and enable localized product searches.
• Camera & Photos: Required when capturing photos for Ghana Card identity verification, uploading marketplace product media, or updating your profile photo.
• Push Notifications & Web Alerts: Required to send instant updates for incoming buyer messages, BTA status changes, driver arrival, and security alerts.

4. HOW WE COLLECT YOUR DATA

1. Direct Submissions: When you register an account on the mobile app or web portal (bisame.com), complete KYC forms, post listings, book a ride, or message support.
2. Automated Cross-Platform Collection: Collected automatically during mobile app navigation or web browsing (e.g., GPS telemetry, IP logs, device specifications, browser cookies).
3. Third-Party Integrations: Received from trusted partner systems:
   • National Identification Authority (NIA) / Verification APIs: To validate Ghana Card authenticity.
   • Telecoms & Payment Gateways: To verify Mobile Money transactions and wallet balances.
   • Geocoding Services: To convert GPS coordinates into human-readable addresses.

5. LEGAL BASES & PURPOSES OF DATA PROCESSING

Under applicable data protection laws, BisaMe Digital Limited processes data under the following legal grounds:

1. Performance of a Contract: Fulfilling platform transactions, matching mobility rides, holding BTA escrow funds, and completing deliveries.
2. Legal Compliance: Adhering to anti-money laundering (AML) laws, tax reporting (GRA E-Levy/VAT), and statutory regulations under Ghanaian law.
3. Legitimate Business Interests: Enhancing platform security, preventing fraud, monitoring system health, and optimizing mobile/web UX.
4. Consent: Processing sensitive attributes such as continuous background location tracking. Consent can be updated at any time in app/device settings.

6. DATA SHARING, SDKs & THIRD-PARTY PROCESSORS

BisaMe Digital Limited does NOT sell, trade, or rent your personal information to third-party data brokers or advertisers. Data is shared exclusively with authorized service providers under strict data processing agreements:

6.1 Third-Party Processors & Infrastructure

• Payment Gateways & Telecoms: MTN Ghana, Telecel Ghana, AT Ghana, Paystack, and Hubtel for payment execution and wallet withdrawals.
• Identity Verification Partners: Accredited KYC verification providers querying government national databases.
• Location & Map Services: Google Maps API / Mapbox for mapping, address lookup, and navigation routing.
• Cloud Hosting & Analytics: Firebase (Auth, Cloud Messaging, Crashlytics), Google Cloud for encrypted storage and web API hosting.

6.2 Inter-User Information Sharing

• Marketplace Orders: Buyers' names, phone numbers, and delivery addresses are shared with Sellers upon order confirmation.
• BisaMe Ride Trips: Rider profile information and pickup coordinates are shared with assigned Drivers. Driver vehicle details, ratings, phone numbers, and live location are displayed to Riders.

7. LOCATION DATA & BACKGROUND GPS POLICY

7.1 Prominent Disclosure for Background Geolocation

BisaMe Ride collects Background Location data to support critical safety and dispatch features across mobile applications:

PROMINENT LOCATION DISCLOSURE:
BisaMe collects location data to enable real-time driver tracking, accurate trip distance calculation, emergency safety monitoring, and ride dispatch even when the mobile app is closed or running in the background. Background location tracking occurs ONLY when a Driver is toggled "On Duty" or when a Rider is participating in an active trip.

7.2 Managing Location Settings

Location permissions can be adjusted at any time via OS settings:

• iOS: Settings -> Privacy & Security -> Location Services -> BisaMe -> Select While Using the App or Never.
• Android: Settings -> Apps -> BisaMe -> Permissions -> Location -> Choose Allow only while using the app or Ask every time.

8. IDENTITY VERIFICATION & GHANA CARD KYC PROCESSING

1. Encryption in Transit: When you upload your Ghana Card details and selfie photo, data is encrypted via TLS 1.3 and sent directly to accredited verification partners.
2. Cryptographic Tokens: Raw biometric images are never stored permanently on mobile devices. Verification results are saved as secure cryptographic hashes linked to your account ID.
3. Audit Retention: KYC verification records are retained during your active account lifecycle plus statutory anti-fraud retention periods.

9. FINANCIAL DATA & MOBILE MONEY SECURITY

• Mobile Money PIN Safety: Mobile Money authorizations are handled via secure telecom USSD prompts. BisaMe Digital Limited never prompts for, requests, or stores your 4-digit Mobile Money PIN.
• PCI-DSS Gateway Compliance: Payment card details are processed exclusively by PCI-DSS Level 1 certified gateways.
• BTA Escrow Custody: Escrow funds for BisaMe Trade Assurance transactions are maintained in ring-fenced custodial bank accounts with licensed financial institutions.

10. DATA RETENTION, ARCHIVAL & DESTRUCTION

• Active Account Data: Maintained for the duration of your account registration.
• Location Telemetry: Raw GPS coordinates are aggregated and anonymized after 90 days, retained only for summary analytics and dispute verification.
• Financial & Tax Ledgers: Retained for seven (7) years in accordance with Ghanaian tax laws and auditing standards.
• Chat Histories & Support Logs: Retained for twenty-four (24) months from transaction completion to manage dispute appeals.

Upon retention expiry, data is permanently destroyed or irreversibly anonymized using industry-standard protocols.

11. ACCOUNT DELETION & SELF-SERVICE ERASURE (APPLE & GOOGLE MANDATE)

In compliance with Apple App Store Guideline 5.1.1(v) and Google Play Data Safety Policies, BisaMe provides simple, self-service account deletion across mobile and web interfaces.

11.1 How to Delete Your Account In-App

1. Open the BisaMe Mobile App.
2. Go to Profile / Account Settings.
3. Select Security & Privacy.
4. Tap Delete Account.
5. Confirm deletion via OTP / Password verification.

11.2 Web Account Deletion Request

Users can also initiate account deletion via our web portal:
🔗 https://bisame.com/delete-account

11.3 Execution Timeline

Upon submitting an account deletion request, your profile, active listings, store settings, and personal identifiers will be permanently deactivated and purged within 30 calendar days, except financial ledgers required under statutory law.

12. SECURITY ARCHITECTURE & TECHNICAL SAFEGUARDS

• Data Encryption: All web and mobile communications use TLS 1.3 / HTTPS. Data at rest (credentials, databases, backups) is encrypted using AES-256.
• Access Governance: Systems are governed by strict Role-Based Access Control (RBAC) and Multi-Factor Authentication (MFA).
• Cybersecurity Telemetry: Automated threat monitoring, API rate limiting, SQL injection defense, and bot prevention.

13. YOUR STATUTORY PRIVACY RIGHTS

Under the Ghana Data Protection Act (Act 843), you have the statutory right to:

1. Request Access: Obtain a copy of your personal data processed by BisaMe.
2. Request Correction: Rectify inaccurate, incomplete, or outdated information.
3. Request Erasure: Request deletion of personal data where legally permissible.
4. Withdraw Consent: Revoke location tracking or marketing preferences at any time.

To exercise your statutory rights, email [email protected] or [email protected].

14. CHILDREN'S PRIVACY & AGE RESTRICTIONS

The BisaMe platform is restricted to individuals aged 18 years and older. We do not knowingly collect personal data from minors under 18. If we discover that a minor has submitted personal data, the account will be immediately terminated and data purged.

15. INTERNATIONAL DATA TRANSFERS

BisaMe Digital Limited operates primarily in Ghana. Where cloud hosting or partner APIs utilize international data centers (such as EU/US regions), data transfers are governed by standard contractual clauses and encryption standards approved by regulatory authorities.

16. POLICY CHANGES & OFFICIAL CONTACT INFORMATION

We may update this Privacy Policy to reflect system enhancements or legal updates. Revisions will be published at https://bisame.com/privacy_policy and announced via in-app notifications.

Official Legal & Privacy Contact:
BisaMe Digital Limited
Accra, Ghana

📧 Primary Support Email: [email protected]
📧 General Corporate Email: [email protected]
📧 Alternative Contact Email: [email protected]
🌐 Web Application: https://bisame.com
🔗 Privacy Policy Link: https://bisame.com/privacy_policy

If you believe your privacy rights have been violated, you have the right to submit a complaint to the Data Protection Commission (DPC) of Ghana (https://www.dpc.gov.gh).