PocketBuy Privacy Policy

Data controller: WEB-BRAINS INTEL TRADING GHANA LTD.
Brand: PocketBuy
Company registration number: CS148830726 (TIN: C0067629490)
Effective date: 28 July 2026
Version: 1.0

1. What this policy covers

This Privacy Policy explains how WEB-BRAINS INTEL TRADING GHANA LTD. (“PocketBuy”, “we”, “us” or “our”) handles personal data when you:

create or use a PocketBuy account;
apply for or use phone-installment or related services;
make or receive an installment payment, refund or other transaction;
contact customer support or submit a complaint;
visit our website or interact with our digital communications; or
otherwise provide information to us or permit an authorised partner to provide it to us.

This Policy applies to personal data processed by PocketBuy as a data controller. A third party may process data under its own privacy notice when it independently determines why and how the data is used. For example, your bank, app store, payment provider or identity-verification provider may have its own notice.

2. Who is responsible for your data

The responsible company is WEB-BRAINS INTEL TRADING GHANA LTD., a private company limited by shares incorporated in the Republic of Ghana under CS148830726 (TIN: C0067629490), trading through the PocketBuy brand.

Registered address: House Number GD-001-2345, Nii Lantey Street, Near The Church of Pentecost-Nmai Dzorn, Adentan, Accra, Greater Accra Region, Ghana (Digital Address: GD-001-2345)
Operating address: House Number GD-001-2345, Nii Lantey Street, Near The Church of Pentecost-Nmai Dzorn, Adentan, Accra, Ghana
Email: [email protected]
Website: https://pocketbuy.global/gh
Privacy enquiries: Please use the email above.

3. Our privacy commitments

PocketBuy aims to process personal data in a way that is fair, transparent, proportionate and secure. In particular, we aim to:

collect data for specific and lawful purposes;
request only data that is reasonably relevant to the service or compliance purpose;
keep information accurate and allow reasonable correction;
keep data only for as long as a lawful business, contractual, regulatory or dispute-related purpose requires;
protect data against unauthorised access, loss, alteration, disclosure or destruction; and
explain important processing in the App before or when the relevant data is collected.

4. Personal data we may collect

The information we collect depends on the service you use and the stage of your relationship with us. We may collect:

4.1 Information you provide

name, date of birth, gender where required, nationality and identification details;
phone number, email address, residential or delivery address and emergency or reference-contact details where required for a product;
employment, occupation, income, affordability and business information;
bank-account, payment-instrument and settlement information;
login details, PIN-related security information and communication preferences;
documents, photographs, signatures, selfies or other verification material that you choose or are required to submit; and
information in messages, applications, complaints, support calls or other correspondence.

4.2 Information created through your use of PocketBuy

application, approval, phone-order, device, payment, installment and account history;
notices, reminders, support interactions and records of consent or acceptance;
fraud, security and audit records, including authentication events and suspected misuse; and
preferences and responses to product or service communications.

4.3 Information from devices and technical services

When enabled by the App, your operating system and your permission choices may provide technical information such as device model, operating-system version, App version, language, network information, IP address, advertising or installation identifiers, crash information and security signals.

We may use approximate location only where the App requests the permission and the purpose is explained, such as service availability, fraud prevention or delivery. We do not treat this Policy as blanket permission to access every file, photo, contact, message, call record or calendar entry on your Device. Any sensitive or device-level permission must be separately requested and used only for the disclosed purpose and as permitted by law.

4.4 Information from other sources

Subject to applicable law, we may receive information from banks and payment providers, identity and address-verification providers, telecommunications or device-security providers, merchants, delivery partners, fraud-prevention services, public registers, affiliates and other parties that lawfully provide information to us.

We may combine information from these sources with information you provide, but only for compatible and disclosed purposes.

5. Why we use personal data and the lawful basis

The lawful basis depends on the processing activity and the circumstances. We may rely on performance of a contract or steps requested before entering a contract, compliance with a legal or regulatory obligation, consent, protection of a person’s vital interests, or a legitimate interest that is balanced against your rights.

Processing activity	Typical data used	Main lawful basis
Create and secure your account	Identity, contact and authentication data	Contract / steps before contract; legal obligation
Assess an application and affordability for a phone installment plan	Identity, financial, employment, transaction and verification data	Contract / steps before contract; legitimate interest; legal obligation
Provide phone purchase, device-financing and installment services	Account, product, payment and transaction data	Contract; legal obligation
Verify identity and prevent fraud	Identity documents, device and security signals	Legal obligation; legitimate interest; consent where required
Process payments and reconcile transactions	Bank, wallet, card or payment details and transaction references	Contract; legal obligation
Communicate service information	Contact details, account and transaction data	Contract; legal obligation; legitimate interest
Handle complaints and defend legal claims	Correspondence, account history and case records	Legal obligation; legitimate interest
Improve reliability and understand product use	Technical events, aggregated usage and support feedback	Legitimate interest; consent where required
Send optional marketing	Contact details, preferences and campaign interaction	Consent or another lawful basis permitted by law; opt-out available
Meet audit, tax, accounting and regulatory duties	Relevant identity, transaction and account data	Legal obligation

We do not use your data for a new purpose that is incompatible with the purpose explained at collection unless a lawful basis and any required notice or consent are in place.

6. Affordability assessment and automated decisions

A phone-installment application may involve rules, scoring, eligibility checks or other automated processing. These checks may consider information such as identity, affordability, prior installment-payment history with PocketBuy, transaction behaviour, fraud indicators and information from authorised verification providers.

An automated result may affect whether an application is approved, the deposit or installment terms offered, whether additional verification is required, or whether an account, order or payment channel is restricted. We will provide information about the relevant decision and available review route where required by law. You may request human review, challenge inaccurate information and exercise other rights available under applicable data-protection law.

PocketBuy will not make a decision solely from a sensitive data category unless a lawful exception applies and appropriate safeguards are in place.

7. When we share personal data

We may share the minimum information reasonably required with:

payment processors, banks, wallet providers and settlement partners;
identity and address-verification providers and fraud-prevention services;
device-financing, merchant, delivery, repair, insurance or warranty partners where relevant to the product you select;
cloud hosting, customer-support, messaging, analytics, cybersecurity, document-storage and software vendors acting on our instructions;
professional advisers, auditors, insurers, collections or dispute-resolution providers where lawfully necessary;
our affiliates or a successor entity in connection with a restructuring, financing, merger, acquisition or transfer of a business, subject to appropriate safeguards;
courts, law-enforcement agencies, regulators, tax authorities or other public bodies where disclosure is required or permitted by law; and
another person where you direct us to share the information or give the required consent.

We do not sell your personal data. We do not provide a third party with access merely because it is a marketing partner. Any optional marketing sharing must have a lawful basis and must respect your communication choices.

Service providers may act as processors and may use subcontractors. We require them to apply appropriate confidentiality, security and data-handling obligations, but their access is limited to the service they provide.

8. International and cross-border transfers

Some technology, payment, verification, support or hosting providers may process personal data outside Ghana. Before making a cross-border transfer, we will apply the safeguards required by the Data Protection Act, 2012 (Act 843) of Ghana, which may include an adequacy decision, contractual safeguards, another lawful transfer mechanism, or a permitted exception.

You may ask us for general information about the countries or categories of recipients involved in a transfer and the safeguards used, subject to security and confidentiality limitations.

9. Cookies and similar technologies

Our website and selected App or communication features may use cookies, SDKs, pixels or similar technologies to keep sessions secure, remember preferences, measure performance, diagnose failures and understand how features are used.

Where required, non-essential analytics or marketing technologies will be enabled only after the relevant consent. You can manage browser or Device settings, but disabling essential technologies may affect login, security or service functionality. A separate cookie notice may provide more detail for the website.

10. Data retention

We do not retain all data for the same period. We determine the retention period by considering:

whether your account, application, financing or dispute is still active;
legal, regulatory, tax, accounting, anti-fraud and audit obligations;
limitation periods and the need to establish, exercise or defend legal claims;
security, incident investigation and complaint-handling requirements; and
whether the information can be deleted, anonymised or aggregated without affecting a necessary lawful purpose.

When a retention period ends, we will securely delete, anonymise or aggregate the relevant data unless another lawful reason requires continued retention. Backup copies may remain for a limited period while they are securely rotated or overwritten.

11. Security and personal-data incidents

We use administrative, technical and organisational safeguards proportionate to the risk, which may include access controls, authentication, encryption in transit, secure storage, logging, vendor controls, staff confidentiality obligations, backup protection and incident monitoring.

No online system is completely risk-free. You must protect your Device and Credentials and report suspected account compromise promptly. If a personal-data incident occurs, we will assess it, contain and remediate it, keep appropriate records and notify affected persons or the relevant authority where required by law.

12. Your rights

Subject to applicable legal limits and verification of your identity, you may have the right to:

receive clear information about how your data is used;
request access to personal data we hold about you;
request correction of inaccurate or incomplete data;
request deletion where the data is no longer needed or another legal condition applies;
restrict or object to certain processing;
withdraw consent where processing is based on consent;
receive certain data in a portable format;
object to direct marketing at any time; and
request information or safeguards relating to qualifying automated decisions.

Exercising a right does not automatically cancel an Installment Agreement, payment duty or other contract. We may retain information that we are legally required to keep or need to use for a lawful claim, fraud prevention, security or regulatory purpose.

13. How to make a privacy request or complaint

Send a request to [email protected] with “Privacy Request” in the subject line, or use the privacy route identified in the App. Please describe the request, the account or phone number concerned and a safe way to contact you. We may ask for reasonable identity verification before responding. To request deletion of your PocketBuy account and associated data, follow our Account Deletion Guide.

We aim to acknowledge requests promptly and respond within the period required by applicable law. If you are not satisfied with our response, you may escalate the matter through our complaint process or lodge a complaint with the Data Protection Commission (DPC) of Ghana through its official channels: https://www.dataprotection.org.gh/.

14. Children and vulnerable persons

PocketBuy’s phone-purchase and installment services are intended for adults who can lawfully enter into the relevant agreement. The Services are limited to mobile-phone purchases, installment payments and related device services. We do not knowingly target children or knowingly collect their personal data for these Services. If we learn that a child has provided personal data without an appropriate lawful basis, we will take reasonable steps to delete or otherwise handle it in accordance with applicable law.

If you apply or use a Service on behalf of another person, you must have the authority to provide their data and must make this Policy available to them where required.

15. Third-party services and links

The App or website may contain links to third-party websites, payment pages, app stores or services. Their privacy practices are controlled by their own notices, not this Policy. Review those notices before providing information or completing a transaction.

Where a third party processes data independently, PocketBuy is not responsible for processing outside our control, but we will investigate a concern when it relates to a PocketBuy-arranged service.

16. Changes to this policy

We may update this Policy to reflect changes in our Services, technology, vendors, law or privacy practices. The current version will be made available in the App or on our website, with the “Effective date” updated. Where a change materially affects how we use your data, we will provide additional notice or request consent where required.

17. Contact details and version history

WEB-BRAINS INTEL TRADING GHANA LTD. / PocketBuy Ghana
Email: [email protected]
Website: https://pocketbuy.global/gh
Registered address: House Number GD-001-2345, Nii Lantey Street, Near The Church of Pentecost-Nmai Dzorn, Adentan, Accra, Greater Accra Region, Ghana (Digital Address: GD-001-2345)

Effective date: 28 July 2026
Published on: 28 July 2026
Last updated: 28 July 2026
Version: 1.0