Privacy Policy RMS GH Agent App

This Privacy Policy explains how RMS GH ("we," "us," or "our") collects, uses, discloses, and protects information through the RMS GH Agent App, a mobile application that allows registered sales agents to onboard customers, process installment (hire-purchase) applications, collect payments, and earn commissions on the RMS GH platform (rms.installmentzone.com). RMS GH Agent App, together with the RMS GH Locking App used by customers, has been in operation since 2022.

This policy is written for agents using the app in their capacity as RMS GH sales agents. If you are a customer purchasing goods on installment, please refer to our separate Customer Privacy Policy.

By registering as an agent or using the Agent App, you agree to the collection and use of information as described in this policy.

1. Who We Are

RMS GH is a trading name of Reliance Mobile Services, a multi-sided installment sales platform operating in Ghana, connecting sellers of goods (primarily mobile phones), customers who purchase on hire-purchase plans, and agents who facilitate onboarding, sales, and collections in the field.

Data Controller

RELIANCE MOBILE SERVICES ("RMS GH")
Gomoa Akotsi, near Deliverance Power Ministry, Central Region, Ghana

2. Information We Collect

2.1 Information You Provide About Yourself (Agent)

When you register and operate as an agent, we collect:

• Full name, date of birth, gender
• Phone number and email address
• Ghana Card / National ID details and photo/scan
• Profile photograph
• Residential address and region of operation
• Bank account or mobile money details (for commission payouts)
• Guarantor information, where applicable
• Login credentials (password is stored encrypted/hashed)

2.2 Information You Collect and Submit About Customers

As part of onboarding customers into installment plans, the app requires you to capture and submit:

• Customer full name, phone number, and contact details
• Customer Ghana Card / ID details and photo
• Customer residential/work address
• Guarantor details for the customer
• Product/order details and down payment information
• Photographs taken during verification visits (where applicable)

2.3 Location Data

The app may collect GPS location data when you:

• Check in for field visits or customer verification
• Submit an order or collect a payment
• Are actively logged in and using location-dependent features

Location data helps us verify field activity, prevent fraud, and support commission/territory tracking.

2.4 Payment & Transaction Information

• Down payments and installment payments collected from customers via Paystack (mobile money/card)
• Commission calculations, payout history, and account balances
• Transaction references, timestamps, and status (via Paystack webhooks)

We do not store full mobile money PINs or card numbers these are processed directly and securely by Paystack, our licensed payment processor.

2.5 Device & Technical Information

• Device model, operating system version, unique device identifiers
• App version, crash logs, and diagnostic data
• IP address and general network information

2.6 Communications

• Messages sent through the in-app support chat
• SMS notifications sent to you or on your behalf via our SMS gateway (Nalo) e.g., order confirmations, payment reminders, OTPs
• Records of calls or messages with our admin/support team

3. How We Use Your Information

We use the information described above to:

1. Verify your identity and eligibility to act as a RMS GH agent
2. Create and manage your agent account and dashboard
3. Process customer registrations, installment applications, and orders you submit
4. Calculate, track, and pay out commissions
5. Process payments and reconcile transactions via Paystack
6. Send transactional SMS/notifications via Nalo (e.g., OTPs, payment confirmations, reminders)
7. Monitor field activity and prevent fraud (e.g., via location checks)
8. Provide customer/agent support and respond to inquiries
9. Maintain security, detect misuse, and enforce our Agent Terms of Service
10. Comply with legal, regulatory, and tax obligations
11. Improve the app, troubleshoot issues, and analyze usage patterns

4. Legal Basis for Processing

We process personal data in accordance with Ghana's Data Protection Act, 2012 (Act 843). Our legal bases include:

• Consent where you or a customer explicitly agree to data collection
• Contract performance to fulfil our Agent Agreement with you and installment agreements with customers
• Legal obligation e.g., tax, anti-fraud, and regulatory record-keeping
• Legitimate interest e.g., fraud prevention, platform security, and business operations

5. How We Share Information

We share information only as necessary:

• Paystack processing mobile money/card payments and down payments
• Nalo (SMS Gateway) sending OTPs, payment reminders, and transactional SMS
• Sellers on the platform order fulfilment for products you sell on their behalf
• RMS GH Admin/Support team account verification, dispute resolution, and support
• Regulators/Law enforcement where required by law, court order, or to prevent fraud
• Service providers hosting, cloud storage, and technical infrastructure providers who process data on our behalf under confidentiality obligations

We do not sell your personal data or customer data to third parties for marketing purposes.

6. Data Storage & Security

• Data is stored on secured servers with access-controlled MySQL databases.
• Passwords are encrypted/hashed and never stored in plain text.
• Payment card/mobile money details are handled by Paystack under PCI-DSS compliant infrastructure RMS GH does not store full payment credentials.
• Access to agent and customer data within our admin system is role-restricted to authorized personnel only.
• Despite these measures, no system is 100% secure. You should protect your login credentials and report any suspected unauthorized access immediately.

7. Data Retention

We retain:

• Agent account data for as long as your agent account is active, and for a reasonable period after deactivation for legal, audit, and dispute-resolution purposes.
• Customer data you submit for the duration of the customer's installment agreement and thereafter as required for record-keeping, dispute resolution, or legal obligations.
• Transaction and payment records retained in line with financial record-keeping requirements under Ghanaian law.

When data is no longer required, it is securely deleted or anonymized.

8. Your Rights

Under the Data Protection Act, 2012 (Act 843), you (and customers whose data you submit) have the right to:

• Access personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request deletion of data, subject to our legal retention obligations
• Object to certain processing activities
• Withdraw consent, where processing is based on consent
• Lodge a complaint with the Data Protection Commission of Ghana

To exercise these rights, contact us at installmentzone@gmail.com.

As an agent, if a customer asks you to help them exercise these rights, please direct them to contact RMS GH support directly rather than handling the request yourself.

9. Agent Responsibilities

Because agents collect personal data from customers on our behalf, you agree to:

• Only collect the data necessary for the installment application
• Obtain the customer's informed consent before collecting their information
• Never share customer data outside the RMS GH app/system
• Never use customer data for personal, commercial, or unrelated purposes
• Immediately report any lost devices, suspected data breaches, or unauthorized access
• Delete any locally cached customer data (e.g., photos) from your device once submitted, where the app does not do so automatically

Failure to comply may result in suspension of your agent account and, where applicable, legal liability.

10. Children's Privacy

The Agent App and RMS GH platform are not intended for individuals under 18 years old. Agents must not onboard customers who are minors. We do not knowingly collect personal data from children.

11. Third-Party Services

The app integrates with third-party services (Paystack for payments, Nalo for SMS) that have their own privacy policies. We encourage you to review their policies:

Paystack Privacy Policy

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify agents of material changes via the app or SMS/email. Continued use of the app after changes take effect constitutes acceptance of the updated policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your data:

RMS GH

Address: Gomoa Akotsi, near Deliverance Power Ministry, Central Region, Ghana

You may also lodge a complaint with:

Data Protection Commission of Ghana
www.dataprotection.org.gh