Privacy Policy for MySmartInfraCo

Last Updated: May 7, 2025

This Privacy Policy applies to the MySmartInfraCo mobile application (“App”), developed and operated by MySmartInfraCo Inc. (“we,” “us,” or “our”), as listed on the Google Play Store. This policy outlines how we collect, process, store, and disclose personal data in compliance with the Data Protection Act, 2012 (Act 843) of Ghana, which regulates the processing of personal data to protect individual privacy. The App allows users to subscribe to services, view subscriptions, and make inquiries, and we are committed to safeguarding your personal data in accordance with Ghanaian law.

1. Information We Collect

In line with Section 17 of Act 843, we collect only personal data that is necessary, relevant, and not excessive for the purposes of providing our services. The types of data we collect include:

a. Personal Data You Provide

• Account Information: When you create an account or subscribe to services, we collect your name, email address, phone number, and payment information (processed securely via third-party payment providers).
• Inquiries: When you submit inquiries, we collect your name, email address, phone number, and inquiry content.
• Subscription Data: Details about your subscriptions, including service type, status, and renewal dates.

b. Automatically Collected Data

• Device Information: We collect device details (e.g., device ID, IP address, operating system) to optimize App performance, as permitted under Section 28 of Act 843.
• Usage Data: We collect anonymized data on App interactions (e.g., features used, session duration) to improve user experience.
• Analytics: We use third-party analytics tools (e.g., Firebase Analytics) to collect anonymized usage statistics, ensuring compliance with data minimization principles.

c. Third-Party Services

• Payment Processors: Subscription payments are handled by third-party providers (e.g., Stripe, Google Play Billing), who process payment data directly. We do not store full payment details.
• Support Services: Inquiries may be managed via third-party platforms (e.g., Zendesk), which collect contact information you provide.

d. Children’s Privacy

The App is not intended for users under 13 years old. We do not knowingly collect personal data from children, as required by Act 843. If we discover such data, we will delete it promptly. Parents or guardians can contact us at support@mysmartinfraco.com.

2. How We Use Your Information

We process personal data in a lawful and reasonable manner, as mandated by Section 18 of Act 843, for the following purposes:

• Manage subscriptions, process payments, and send renewal notifications.
• Respond to inquiries and provide customer support.
• Improve App functionality through anonymized analytics.
• Send service-related communications (e.g., updates, notifications). You may opt out of non-essential communications.
• Comply with legal obligations under Ghanaian law.

3. Data Protection Principles

We adhere to the eight data protection principles outlined in Section 17 of Act 843:

• Accountability: We are responsible for complying with Act 843 and maintaining transparency.
• Lawfulness: Data is processed lawfully and reasonably without infringing your rights.
• Purpose Specification: Data is collected for specific, legitimate purposes (e.g., subscriptions, inquiries).
• Compatibility: Further processing aligns with the original purpose.
• Quality: We ensure data is accurate and up-to-date.
• Openness: We inform you about data collection and processing practices.
• Security: We implement safeguards to protect data.
• Data Subject Participation: You can exercise your rights (see Section 4).

4. Your Rights Under Act 843

As a data subject under the Data Protection Act, 2012, you have the following rights:

• Right to be Informed: You will be notified promptly about the processing of your data and its purposes.
• Right to Access: Request confirmation of whether we hold your data and obtain a copy.
• Right to Rectification: Request correction of inaccurate or outdated data.
• Right to Erasure: Request deletion of data no longer needed, subject to legal obligations.
• Right to Object: Object to processing for direct marketing or automated decision-making.
• Right to Complain: Lodge complaints with the Data Protection Commission (DPC) at support@dataprotection.org.gh.

To exercise these rights, contact us at support@mysmartinfraco.com. We will respond within 30 days, as required by Act 843.

5. Data Sharing and Third Parties

We do not sell or share your personal data except as follows, in compliance with Act 843:

• Service Providers: We share data with third-party providers (e.g., payment processors, analytics tools) under written contracts ensuring compliance with Act 843.
• Legal Requirements: We may disclose data if required by Ghanaian law or a court order.
• Business Transfers: Data may be transferred in the event of a merger or acquisition.

Selling personal data is prohibited under Act 843 and may result in fines or imprisonment.

6. Data Security

We implement industry-standard security measures, as required by Section 28 of Act 843, including encryption and access controls, to protect your data. However, no system is entirely secure, and we cannot guarantee absolute security. In case of a data breach, we will notify the Data Protection Commission and affected users promptly, as mandated by Act 843.

7. International Data Transfers

If data is transferred outside Ghana (e.g., to third-party servers), we ensure compliance with Act 843 by notifying the Data Protection Commission and verifying that the recipient complies with equivalent data protection laws.

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined (e.g., active subscriptions, legal obligations). Data no longer needed is securely deleted or anonymized.

9. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or Ghanaian law. Significant changes will be communicated via the App or email. The updated policy will be posted at https://mysmartinfraco.com/privacy-policy with the revised “Last Updated” date.

10. Contact Us

For questions, concerns, or to exercise your rights under Act 843, contact us at:

You may also contact the Data Protection Commission at:

By using the MySmartInfraCo App, you agree to this Privacy Policy.