Privacy notice

1. Who we are

DT Tigers Phone Finance ("DT Tigers", "we", "us") finances iPhones sold by our partner shops in Ghana. The customer pays a deposit to the shop and repays the rest to us over 12 weeks. For the personal information in this notice, DT Tigers is the data controller under Act 843: we decide why and how it is used.

Phone

055 970 1831

Email

[email protected]

Ghana Post address

G2-099-3382

Website

dttigersphone.com

2. What we collect

If you are a customer:

• Who you are: your full name, date of birth and gender, your Ghana Card number, and what you do for a living.
• How to reach you: your phone number, any second number, your address and, if you give one, your email address.
• The phone you buy: the model, its serial number and IMEI, and photographs of the handset.
• Your agreement: a photograph of you taken at the shop, your signature, the terms you accepted and when.
• Paying us back: your mobile money number, the name the network holds for it, and every payment, attempt, receipt and reference on your plan.
• Talking to us: notes of calls with customer care, messages we send you and messages you send us, and when you sign in to your plan page.
• Your handset's status: whether it is locked, when it last connected, and its battery level, as reported by our device-management service; and, only while it is locked for a missed payment, where it is.
• Your guarantor: the name and phone number of the person who stands behind your plan, and how they know you.

We do not keep a copy or photograph of your Ghana Card. Only the number is recorded, and it is checked against the national identity register through our payment and verification provider. Our system refuses any upload of a card image.

If you are a guarantor: your name, phone number, address if given, your relationship to the customer, the name your mobile network holds for your number, and your signature.

If you work with us (partner shops, sales people, auditors and staff): your name, phone number, the shop you work for, and what you do in the system, which is recorded in our audit log.

3. Why we use it, and on what basis

Act 843 allows personal information to be processed only for a lawful reason. We rely on these:

We use your information only for these purposes. We do not sell it, and we do not use it to market other companies' products to you.

4. Your phone and device management

The phone you buy on a plan is enrolled with a device-management service until the plan is paid. This is part of the agreement you sign. It lets us:

• confirm at the shop that the handset on your agreement is the one you are given;
• lock the phone if a weekly payment is missed and not paid within the time given in your notice — you are always told first, and paying unlocks it; and
• remove the management from the phone when you have paid in full, so the phone is entirely yours.

We do not read your messages, photographs, contacts or apps. If your phone is locked for a missed payment, we may see its location while it stays locked, only to recover the phone under your agreement; only a manager can do this, and each look is recorded with the reason. We do not see the location of a phone that is not locked.

5. Who we share it with

Only what each needs, for the purposes in section 3:

• Our payment and verification provider, a Ghanaian licensed payment service, which processes your mobile money payments, sends our text messages, and checks Ghana Card numbers and mobile money names against the national identity register and the mobile networks.
• Your mobile network, to carry payments and text messages.
• Our device-management service, which holds your handset's serial number, IMEI and the name and number it is registered to.
• The partner shop where you bought the phone, and the auditor who took your application, for your own plan only.
• Your guarantor, who is told they are guarantor for your plan, and who may be contacted if payments fall behind.
• Our email and internet providers, which carry our emails and protect our website.
• The police, courts or regulators, when the law requires us to.

Everyone we share with must keep your information confidential and secure and may use it only to do the job we give them. Some of these providers run their systems outside Ghana; where they do, we require the same protection your information has here.

6. How long we keep it

We keep your information for as long as your plan runs, and then for six years after it ends or after an application is declined — the period in which a claim on the agreement can be brought under the Limitation Act, 1972 (NRCD 54). After that it is deleted.

7. How we keep it safe

• Each person who works with us sees only what their job needs; customer care sees only their own customers.
• Staff sign in with a PIN and, for the office, a second step.
• Links we send you work once and expire.
• Our backups are encrypted, and every change to your record is written in an audit log.

If your information were ever exposed without authority, we would tell you and the Data Protection Commission as soon as reasonably possible, as Act 843 requires.

8. Your rights

Under Act 843 you may:

• see the personal information we hold about you and be given a copy;
• ask us to correct anything that is wrong or out of date;
• ask us to delete information we no longer have a lawful reason to keep;
• object to our using your information for a purpose you did not agree to; and
• ask that a decision about you is reviewed by a person. Every plan is approved by a member of our office, not by a computer alone.

To use any of these rights, call or email us using the details in section 1. We will ask you to confirm who you are, and we aim to reply within 21 days. It costs nothing. Some information must be kept while money is owed or for the period in section 6, and we will tell you if that applies.

9. Complaints

If you are unhappy with how we have handled your information, please tell us first and we will try to put it right. You also have the right to complain to the Data Protection Commission, the body that oversees Act 843 in Ghana, at www.dataprotection.org.gh.

10. Changes to this notice

We will update this notice if what we do with your information changes, and show the date it was last updated at the top. The current version is always at dttigersphone.com/privacy.