Privacy Policy for CediSmart

CediSmart ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the CediSmart mobile application (the "App") and our associated services in accordance with the Data Protection Act, 2012 (Act 843) of Ghana.

Please read this Privacy Policy carefully. By accessing or using the App, you consent to the practices described in this policy.

1. Information We Collect

To provide our financial management and tracking services, we collect information that you provide to us directly or that is generated during your use of the App.

A. Personal Identification Data

• Account Credentials: When you register, we collect your phone number, full name, and your chosen 6-digit security PIN.
• National Identification (Ghana Card): If you choose to complete Tier 1 identity verification, we collect your Ghana Card number (NIA number) and Date of Birth to verify your identity.

B. Financial and Transaction Data

• Linked Portals: When you connect external accounts (Mobile Money wallets like MTN MoMo, Telecel Cash, AT Money, or bank accounts), we receive details such as account identifiers and balances.
• Manual Entries: We store transaction descriptions, categories, spent amounts, and budget limits that you enter manually.
• Autofill Data: If you use our smart AI SMS parser to log transactions, the SMS text snippet is parsed on your device to autofill amount and vendor details. We do not upload your raw SMS inbox to our servers.

C. Device and Security Data

• Biometric Auth: If you enable biometrics (Face ID or Fingerprint login), this authentication is handled entirely by your mobile device's operating system (iOS/Android). We never access, collect, or store your biometric templates on our servers.
• Offline Queue: To support offline tracking, we store pending transaction records in your device's local encrypted storage until you restore internet connection and manually or automatically sync them to our database.

2. How We Use Your Information

We use the collected information for the following business and service purposes:

1. App Functionality: To calculate and present your Net Position, track budgets, and manage transaction logs.
2. Account Switching: To allow you to securely cache and switch between multiple CediSmart profiles on a single device.
3. Identity Verification: To run compliance and identity checks against official verification records.
4. Push Notifications: To deliver budget warning alerts and security updates if push permissions are granted.
5. Security and Auditing: To protect against fraud, prevent unauthorized account access, and debug service performance.

3. Data Storage, Security, and Compliance

• Local Encrypted Storage: Your active session tokens and local PINs are locked inside the device's native secure environment (Keychain on iOS, Keystore on Android).
• Network Security: All data in transit between the App and our backend API is encrypted using secure HTTPS (Transport Layer Security/TLS) tunnels.
• Subnet Isolation: Our production databases are isolated in private subnets and are not accessible from the public internet.

4. Sharing of Information

We never sell or lease your personal or financial data to third-party advertisers. We only share information in the following circumstances:

• Service Providers: To authentication and notification providers (such as Clerk) strictly to verify your identity and deliver registration or PIN reset verification codes.
• Legal Requirements: If required to do so by law, court order, or regulatory request in compliance with the laws of the Republic of Ghana.

5. Your Data Rights

Under the Data Protection Act of Ghana, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectify: Correct or update inaccurate profile details.
• Delete: Delete your account and purge all transaction records from our servers using the "Delete Account" button in the Settings menu.

6. Contact Us

If you have any questions or feedback regarding this Privacy Policy, please contact us:

• Email: support@cedismart.com
• Address: Accra, Ghana