TrustPool ("we", "our", or "us") respects your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use the TrustPool mobile application, website, and related services (collectively, the "Platform"). By using the Platform, you agree to the collection and use of information described in this Policy. If you do not agree, please do not use the Platform.
This Policy should be read alongside our Terms of Service and our Compliance page, which sets out our Pool Participation Agreement and KYC/AML practices.
Information We Collect
We collect the following categories of information:
Identity and verification information (collected during account creation and KYC):
- Full name
- Date of birth
- Phone number
- Ghana Card or other valid government-issued ID
- Selfie for biometric verification
Account and contact information:
- Phone number
- Email address (when provided)
Transaction records:
- Pool contributions, payouts, withdrawals, and fees
- Mobile Money or bank account details used for payouts (collected only as needed by our payment partners)
Pool activity:
- Pools you create or join
- Voting activity within pools
- Trust Score and reputation events
Device and usage information:
- Device type, operating system, and identifiers
- IP address, app version, and crash logs
- Approximate location, if device permissions allow
Communications:
- Messages you send to support
- Notifications and OTP codes we send to you
How We Collect Your Information
We collect information:
- Directly from you, when you register, complete KYC, contribute to a pool, vote, or contact us
- Automatically, through your use of the Platform (logs, device information, transaction history)
- From third-party providers, including payment processors, identity verification services, and community heads who issue invitation codes
How We Use Your Information
We use your information to:
- Operate and maintain the Platform
- Verify your identity and prevent fraud
- Process contributions, payouts, and withdrawals
- Calculate your Trust Score and surface reputation signals
- Communicate with you, including account notifications, support replies, and OTP codes
- Detect and prevent money laundering, terrorism financing, and financial fraud
- Improve the Platform’s reliability, security, and user experience
- Comply with legal, regulatory, and audit obligations under Ghanaian law
How We Share Your Information
We do not sell your personal information. We share information only as necessary to operate the Platform and to comply with the law:
- With other members of pools you participate in — limited to information they need to see who is in the pool, payment status, and the payout schedule
- With community heads — limited to what they need to manage their community
- With third-party service providers we rely on to run the Platform, including payment processors, identity verification providers, cloud hosting providers, and communication providers (SMS, email, push notifications)
With authorities, when required for AML or legal compliance:
- Financial Intelligence Centre (Ghana)
- Bank of Ghana
- Law enforcement and other regulators
- With our advisors and auditors, under confidentiality obligations
- In the event of a corporate transaction (merger, acquisition, restructuring), with appropriate notice
Data Retention
We retain your personal information for as long as your account is active and for as long as needed to:
- Provide the Platform and resolve any disputes
- Meet our legal, accounting, and regulatory obligations under Ghanaian law, including AML record-keeping rules
- Defend against legal claims
When the information is no longer needed, we will delete or anonymize it.
Data Security
We implement reasonable technical and organizational measures to protect your information from loss, misuse, and unauthorized access. No system is perfectly secure; you are responsible for keeping your account credentials confidential and using a secure device.
Your Rights
You have the right to:
- Access the personal information we hold about you
- Request correction of inaccurate or incomplete information
- Request deletion of your information, subject to our legal and AML record-keeping obligations
- Object to or restrict certain types of processing
- Withdraw consent for processing that relies on your consent (this may limit your ability to use parts of the Platform)
- Lodge a complaint with the relevant Ghanaian data protection authority
To exercise any of these rights, please contact us using the details below. We may need to verify your identity before responding.
Children's Privacy
The Platform is not intended for children under 16. Because registration requires a valid Ghana Card or a government issued ID, minors should not be able to register. If we learn that we have collected information from a child, we will delete it.
International Transfers
Some of our service providers may process your information outside Ghana. Where this happens, we take steps to ensure an appropriate level of protection consistent with this Policy.
Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated through the Platform. The "Last updated" date at the top of this page will always reflect the most recent revision. Continued use of the Platform after a change means you accept the updated Policy.