1. Scope of the Privacy Policy
This Privacy Policy explains how TrustLink Escrow ("TrustLink", "we", "us") collects, processes, stores, shares, and safeguards personal information obtained when you interact with our web applications, checkout links, dashboards, API services, and WhatsApp bot interface. This policy applies to sellers, buyers, and general website visitors.
2. Who is responsible for the service
TrustLink Escrow operates technology infrastructure for social commerce protected payments in Ghana. We process data in compliance with applicable laws, including the Data Protection Act, 2012 (Act 843) of Ghana.
3. Information users provide
We collect personal information that you voluntarily provide when registering an account, minting an escrow link, filling out forms, or communicating with support. Depending on your role, this may include your name, email address, phone number, and transaction descriptions.
4. Account and authentication information
When sellers register or log in via email or Google Sign-In, Firebase Authentication processes login credentials, OAuth tokens, email addresses, and profile identifiers to securely authenticate your account across sessions.
5. Buyer and seller transaction information
When an escrow order is created, we record transaction parameters in Firestore, including seller ID, buyer phone number, buyer email (if supplied), item description, price in Ghana Cedis (GH₵), fee split rule, order creation timestamp, and transaction status transitions.
6. Payment metadata
We process payment metadata necessary to verify mobile money collections and disbursements. This includes payment reference IDs, network provider names (MTN, Telecel, AT), transaction status responses from Moolre gateway, and wallet balance records. TrustLink does not collect or store Mobile Money PINs.
7. Product, delivery and fulfilment information
We store product catalog details uploaded by sellers (item title, price, image URL) and fulfilment status timestamps (e.g. PENDING_PAYMENT, FUNDS_ESCROWED, ITEM_SHIPPED, COMPLETED) to present tracking progress to both parties.
8. Support, chat and dispute communications
If you contact customer support or submit evidence during a transaction dispute, we process the contents of your messages, screenshots, chat transcripts, and contact details to assist in resolving the inquiry.
9. Verification or KYC data
Where high transaction volumes or anti-fraud rules require identity verification, we may process identification details (such as Ghana Card numbers or national ID document images) strictly for identity confirmation and regulatory compliance.
10. Device, browser, IP address, security-log and usage information
When you access our platform, our servers automatically record standard device information, browser type, IP address, access timestamps, and referring URLs to maintain platform security and diagnose technical issues.
11. Cookies, local storage and similar technologies
We use essential cookies and browser LocalStorage to maintain user authentication sessions, preserve theme preferences, and store transient state while navigating between dashboard tabs. We do not use intrusive third-party tracking cookies for targeted advertising.
12. How information is obtained
Information is collected directly from you when you submit input forms, automatically via web technology when navigating pages, and via webhooks from integrated payment gateways (Moolre) and messaging networks (WhatsApp/Twilio) when order state updates occur.
13. How TrustLink uses information
We process personal data to provide conditional payment facilitation, manage user accounts, deliver SMS/WhatsApp progress alerts, handle disputes, prevent fraud, execute payout disbursements, and comply with legal requirements under Ghanaian law.
14. Payment processing and transaction administration
Buyer and seller details are processed to initiate USSD payment prompts, monitor collection confirmations, ring-fence escrowed funds in state machine records, and release payouts upon delivery confirmation.
15. Fraud prevention and service security
We analyze transaction patterns, IP logs, and seller dispute histories to detect unauthorized access, prevent fraudulent transactions, protect platform integrity, and safeguard user funds.
16. Messaging and notification delivery
We use buyer and seller phone numbers to send automated transaction status alerts via SMS or WhatsApp (such as order link notifications, payment confirmation alerts, shipping notifications, and confirmation codes).
17. Customer support and dispute handling
When a dispute is raised, submitted evidence and contact records are reviewed by platform administrators to evaluate delivery proof and determine refund or payout resolution under established rules.
18. Legal and regulatory requirements
We process and disclose transaction records where necessary to comply with applicable laws, court orders, anti-money laundering obligations, or lawful inquiries by Ghanaian law enforcement authorities.
19. Product analytics and improvement
Aggregated, non-identifiable usage statistics are reviewed to optimize page load speeds, improve mobile navigation, and enhance dashboard features.
20. Information shared between transaction parties
To fulfill an order, certain information must be shared between the buyer and seller (such as order item name, total price, shipping status, and buyer contact details for delivery communication).
21. Information shared with service providers
We share data strictly on a need-to-know basis with trusted service providers who enable core features:
- Google Firebase: Database hosting, user authentication, and cloud infrastructure.
- Moolre Fintech API: Mobile Money payment prompt processing and payout disbursements.
- Meta WhatsApp & Twilio: Transactional WhatsApp message and SMS notification delivery.
- Tawk.to: Live customer support chat widget.
22. International or cross-border processing
Cloud infrastructure providers (such as Google Firebase) may process and host encrypted data on secure servers located outside Ghana. All cross-border data flows are subject to high physical and logical security standards.
23. Data retention
Personal data and transaction records are retained only for as long as reasonably necessary to provide services, resolve disputes, satisfy financial accounting requirements, and comply with legal retention obligations under Ghanaian law.
24. Data security
We employ reasonable administrative and technical safeguards—including HTTPS encryption, database access controls, Firebase security rules, and API key authentication—to protect your personal information against unauthorized access, loss, or alteration. However, no internet service or transmission can guarantee absolute security.
25. User privacy rights
Under Ghana’s Data Protection Act, 2012 (Act 843), you have the right to request access to the personal data we hold about you, request corrections to inaccurate records, or request account closure. Requests may be submitted via customer support. Legal exceptions apply where records must be retained for legal or accounting purposes.
26. Children’s privacy
TrustLink Escrow does not knowingly collect personal information from individuals under 18 years of age. If we learn that a minor has created an account, we will take steps to disable the account and delete associated data.
27. Third-party websites and services
Our platform may contain links to third-party sites (such as Moolre documentation or external logistics portals). We are not responsible for the privacy practices or content of third-party websites.
28. Changes to this Privacy Policy
We may update this Privacy Policy periodically. When revisions occur, we will update the "Last updated" date at the top of this document. Continued use of the platform after changes indicates acceptance of the updated policy.
29. Contacting TrustLink
If you have questions, privacy concerns, or data protection inquiries, please contact our support team via the live chat widget available on our website.
30. How to contact Ghana’s Data Protection Commission
If you believe your data protection rights have not been adequately addressed, you may contact the statutory regulator, the Data Protection Commission (DPC) Ghana:
Website: https://dataprotection.org.gh/
Official Act: Data Protection Act, 2012 (Act 843) PDF