Policy Policy

Scope of this Privacy Policy

Smarty Delivery Services of Sims Technologies Ltd, a limited liability company registered and located in Ghana, values the privacy of individuals who use our website and mobile apps (collectively, our “Platform”). Smarty Delivery takes privacy and data security seriously. We are committed to transparency in collecting, using, and disclosing your personal information. This privacy policy (the Privacy Policy”) explains how we collect, use, and share information from Smarty Delivery users (“Users”). It applies to our customers (“Customers”), individuals who deliver products requested by Customers through our Platform (“Couriers”), anyone who signs up to become a Courier (“Prospective Couriers”), businesses selling products through our Platform (“Merchants”). It also applies to other partners and end-users who use our Platform to facilitate
the delivery and sale of products (“Partners”). By using the Platform, you agree to the Privacy Policy and any future amendments and additions. Your use of our Platform is also subject to our Terms and Conditions.

1. Information Smarty Delivery Collects From Users
Smarty Delivery collects information from its Users. The categories of information we collect are
described below in this Section 1.

A. Information You Provide Directly to Us
Customers
Sign Up and Profile Information: When you sign up or place an order through Smarty Delivery as a Customer, you provide us with information, including, but not limited to your name, email address, physical address, and phone number. If you sign up using your Facebook account, we receive your name and email address. After registration, Customers can add multiple delivery addresses to their profile. You may be required to provide us with a photograph.

Order Information: When you place an order, we collect information related to the Order, including items purchased, special instructions, date and time of Order, and subtotal.
Feedback: We may ask you for feedback on your Order, including rating of experience, the applicable Merchant, or the applicable Courier.

Surveys: We may offer an opportunity to participate in surveys, promotions, or contests. When a User participates, we may request certain information, including name and email address.

Payment Information: When you add a payment card to your Smarty Delivery account, a thirdparty payments service provider receives your card information. We do not store the entire payment card information on our servers.

Active and Prospective Couriers
Sign Up and Profile Information: When you sign up to become a Courier, you may provide us with certain information, including, but not limited to your legal name, date of birth, email address, physical address, phone number, photo, vehicle information, and car insurance information. We share this information with third-party providers who initiate background check reports on you.
Additional information about the third parties who run the background checks is provided in Section C below. We may also collect information from you after signing up (as is necessary) to effectively operate the Platform.
Surveys We may offer an opportunity to participate in surveys, promotions, or contests. When a User participates, we may request certain information, including name and email address.

Payment Information: We receive information from Couriers to provide payment and for tax reporting purposes, including but not limited to bank account and tax information.


Merchants and Partners
Profile Information: A Merchant who signs up for our Platform or a Partner who utilizes our Platform provides us with certain information, including but not limited to contact name, phone number, email address, physical address, hours, and product information, including product details and price.

Payment Information: We may receive “Merchants” bank account information to provide payment as well as any other information necessary to set up payment.

All Users
Communications: If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Support team, we will receive your name, email address, and the contents of any message or attachments that you may send to us, as well as any other information you choose to provide.

Feedback: Customers and Couriers may be able to rate and review each other at the end of every delivery. Customers may see a Courier s aggregate ratings during a delivery. After delivery, we may share feedback or comments that Customers provide with Couriers or Merchants, but we will not identify the Customer. If you are a Customer and do not want a Courier to know you provided specific feedback or comments, please do not include identifying information in that feedback or those comments. We may also share with Couriers their aggregate ratings. Customers may also provide us information and feedback related to your experience on the Platform, including but not limited to order reviews, merchant reviews and merchant ratings.


B. Information We Collect Automatically Through Your Use of the Platform
Location and Sensor Information: We receive a Customer s location information when you are using the Smarty Delivery app, including when the app is in use in the foreground or background. We may continuously collect location information and other motion-generated or orientation-generated mobile sensor data from Couriers and Prospective Couriers when the Smarty Delivery app is used in the foreground or background. This collection is done to personalize the app experience, assist in finding available markets or available delivery opportunities, offer delivery incentives, track the progress and completion of deliveries, and other similar purposes. We also use this information for analytics
purposes. For information on your choices for sharing location information, please consult Section 6 on Your Choices.

Device Information:
We receive information from Users” devices, including IP address, web browser type, mobile operating system version, phone carrier and manufacturer. Also, unique device identifiers and other information such as your device type and, if you register with your Facebook account, your Facebook identifier are also collected.

Usage Information:
We automatically receive information about your interactions with our Platform, such as the pages you were visiting before accessing the Site or mobile application, other content you view, the products you search for or purchase, and the dates and times of your visits. This information helps us understand how you use our Platform, help us improve our Platform, and provide you information about our Platform, Merchants, and Partners.

Call and Text Information:
We work with one or more third parties to facilitate phone calls and text messages between Customers and Couriers who deliver the “Customers” products. We further receive information about these communications, including the date and time of the call or text message, the “parties” phone numbers, and the content of the text messages. We do not record or have access to the content of the phone calls between Customers and Couriers. We do record or have access to the content of phone calls between Users and Smarty Delivery.


Information from Cookies and Similar Technologies:
Smarty Delivery and our service providers collect information through the use of “cookies” and similar technologies to understand how you navigate through and interact with our Platform, to learn what content is popular for authentication and advertising purposes, and to save your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information and help websites and apps recognize your browser. We may use both
session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our Platform. We also use cookies for data analytics purposes, including from Google Analytics.
You can find more information on how Google uses data from these cookies at google.com/policies/privacy/partners. To prevent Google Analytics from using your information
for analytics, you may install the Google Analytics Opt-Out Browser Add-on. You should consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may be missing out on certain features of our Platform.

Referrals:
You may be able to refer Smarty Delivery to friends and other contacts. We may request to help you do this, and you may grant us access to your mobile device address book. You can then direct us to send referral text messages or emails to contacts you select in your address book. We will use the data from your address book only to process your referral. You also consent to Smarty Delivery sending your public profile image to the contacts you select to receive a referral link by sending a referral. By choosing to invite a friend, you represent that you have received the friend’s consent to provide his or her name and email address with Smarty Delivery. Smarty Delivery will use that information to send an email inviting him or her to visit the Platform. It will store that information to track the success of the referral program. Smarty Delivery may also send marketing emails.
Smarty Delivery users may not send, publish, or share any false, misleading, or deceptive communications in connection with participation in the referral program. These actions may violate various domestic or international laws. In addition, Smarty Delivery users may not send any referral emails, text messages, or other communications to children under 13 years.
If you are referred to Smarty Delivery through one of our referral programs, or if someone attempts to refer you, Smarty Delivery may share your name with the person(s) who referred you. This sharing will be done whether you have already signed up, are a new customer, or have placed a qualifying order with Smarty Delivery.
C. Personal Information from Publicly-Available Sources and Third Parties Information We Receive From Partners. Suppose you purchase through one of our Partners that offers delivery with Smarty Delivery. In that case, we receive information about your purchase, including your name, phone number, the product you purchased, and the delivery location.

Background Information on Couriers.
Smarty Delivery works with third-party providers to perform driving records and criminal background checks on prospective and active Couriers. In some instances, these third parties provide Prospective Couriers and active Couriers” records to Smarty Delivery as part of the background check process.

Information From Affiliates and Non-Affiliated Third Parties.
We may collect information about you or others through Smarty Delivery affiliates or nonaffiliated third parties. For example, you may access the Platform through a social networking account, such as Facebook. If you access the Platform through your Facebook account, you may allow us to access certain information in your Facebook profile. This information may include your name, profile picture, gender, networks, email address and other information you allow to be imported from Facebook, controlled in your Facebook privacy settings. Social networking sites, such as Facebook, have their policies for handling your information. To describe how these sites may use and disclose your information, including any information you make public, please consult the sites’ privacy policies. We have no control over how any thirdparty site uses or discloses the personal information it collects about you. We may also collect information about you or others through non-affiliated third parties. For example, to the extent permitted by law, we may, in our sole discretion, ask for and collect supplemental information from third parties. Such information may include information about your credit from a credit bureau, information to verify your identity or trustworthiness, or other fraud or safety protection purposes. We may also collect demographic information, including income, marital status, spending habits, and other information about customers. We may combine information that we collect from you through the Platform with information from such affiliated and non-affiliated third parties and information derived from any other products or services we provide.

How We Use The Information We Collect From Users
We use the information collected from and about Users for the following business and commercial purposes:

A. Provide services and features.
Smarty Delivery uses the data we collect to provide, personalize, improve, expand, and promote our Platform and other services.
This includes: using data to Facilitate transactions, deliveries, and payments, analyze how you use our Platform, track and share the progress of deliveries and orders and notify you about the progress of deliveries and orders.

B. Communications.
Smarty Delivery uses the data we collect to communicate with you, either directly or through one of our service providers, including for marketing and promotional purposes, and to respond to any issues that may arise during deliveries. Smarty Delivery also uses the data we collect to provide customer support, including but not
limited to responding to customer support questions or your requests and investigating and addressing User concerns.

C. Conduct research and development.
Smarty Delivery may use the data we collect for testing, analysis, product development, and machine learning to improve a user s experience on the Platform.

D. Security and safety.
We use the information we collect to help maintain our services’ safety, security, integrity, third parties, and Users. This includes using data to Find and prevent fraud, protecting Users and the Smarty Delivery business, and providing account and network security.

E. Maintain legal and regulatory compliance.
Smarty Delivery may use the information we collect to maintain legal and regulatory compliance. This includes using data to:
Resolve disputes to enforce any legal terms that govern your platform use. Pay our taxes or fulfil our business obligations. Respond to requests by regulators, government entities, and official inquiries.

F. Smarty Delivery business purposes.
We may aggregate or de-identify information collected through the Platform. We may use deidentified or aggregated data for any purpose, including without limitation for research and marketing purposes and share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, or others. How Smarty Delivery Shares Information It Collects From Users

A. Sharing between Customers and Couriers
To facilitate the delivery of orders, Couriers and Customers may have access to certain information about each other. When Couriers are offered delivery opportunities, they may see the Customers delivery location. Once a Courier accepts a delivery request from a Customer, the Customer may see the Courier’s name photo, the aggregate rating, real-time location (which may reveal locations of other Customers to whom a Courier is providing a delivery). Also, other information to identify the Courier, including, but not limited to the Courier s license plate, colour, make, and model of vehicle, may be seen. Couriers may see the Customer’s name, delivery address or real-time location. Smarty Delivery allows Customers and Couriers can call and text each other. Customers and Couriers may be able to see the other’s phone number.
As described above, Customers can see a Courier s aggregate ratings during a delivery. After delivery, we may share feedback or comments that a Customer provides with a Courier, but we will not identify the Customer. If you are a Customer and do not want a Courier to know you provided specific feedback or comments, please do not include identifying information in that feedback or those comments. We may also share with Couriers their aggregate ratings.

B. Sharing between Couriers and Merchants
Before a Courier picks up the delivery from the Merchant or Partner and during the delivery, the Merchant or Partners may see the Courier s name, real-time location. They may be able to communicate directly with the Courier.

C. Sharing between Customers and Merchants
We may share specific transactional details with Merchants from whom you have placed orders. Such information may include your name, phone number, email address, the physical address associated with your account or any delivery with the Merchants from whom you have placed orders. Merchants may also have access to your public profile image, feedback, or Order information, including your purchase history and other information related to your orders with the particular Merchant. Such information provided to Merchants is not subject to this Privacy Policy. Instead, it is subject to Merchant s privacy policies which may allow Merchant to, among other things, send you marketing communications and other promotional content.

D. Service Providers
We share your information with service providers that perform services on our behalf, including all of the uses described in this Section 3. Some examples of service providers are third parties we use for payment processing, advertising, marketing, and analytics.

E. Other Sharing
We may share your information with third parties in the following cases:
Where disclosure is required or appropriate in order to comply with laws, regulations, legal processes, or an agency or governmental request;
With law enforcement officials, government authorities, or third parties, if we think doing so is ecessary to protect the rights, property, or safety of Smarty Delivery, our Users, or the public;
To protect the security or integrity of our Platform;
To enforce our agreements, policies, and Terms of Service;
To respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person;
To investigate and defend ourselves or others against any third-party claims or allegations.
To provide information about our Platform’s use to Couriers, Merchants, Partners, or potential business partners in an aggregated or de-identified form that cannot reasonably be used to identify you; while negotiating about a business transaction, such as a merger, sale of assets, or bankruptcy.

Whenever you consent to the sharing, including without limitation when you use the social features of the Platform to (1) review, rate, or provide feedback on Merchants that will be available for viewing by other Users; (2) share the orders you have placed through the Platform with other Users, including, but not limited to designated favourite orders; or (3) share your favourite items/Merchants or lists of items/Merchants with other Users.
When you share certain information related to orders with other Users or non-Users, including, but not limited to (a) your cart; (b) the fees associated with your Order (e.g. to split payment with others); (c) the estimated time of delivery and progress of your Order; or (d) order destination.

Online Analytics & Interest-Based Advertising
Third parties or we may place cookies, web beacons, or other tracking technologies on your computer, mobile phone, or other devices to collect information about your use of the Platform.
Cookies are small bits of data we store on the device (computer, mobile phone, tablet or any other mobile device) that you use to access the Platform. We use cookies, and other tracking technologies to (a) inform, optimize, and serve marketing content based on past visits to our websites and other sites, (b) report how our marketing content
impressions, other uses of marketing services, and interactions with these marketing impressions and marketing services are related to visits to our websites, (c) help us understand how the Platform is being used, (d) let you navigate between pages efficiently, (d) remember your preferences, and (e) generally improve your browsing experience.
We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick, and others) to serve tailored marketing to you. They may also access their cookies or other tracking technologies on your computer, mobile phone, or other devices you use to access the Platform. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other devices you use to access the Platform, by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties.
Those parties that use these technologies may offer you a way to opt-out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider in hashed, non-human-readable form.

Our third-party vendors and we may use Device IDs and other automated technologies (including cookie identifiers on our website), along with other collected information, to deliver content or tailor ads when you are on our Platform or other devices, apps or websites. These ads may be based on the types of websites you visit over time, the types of apps you have on your device, or de-identified information about you and your likely interests based on your activities on our Platform. This type of advertising is often called interest-based” or personalized” advertising—and when it occurs on mobile apps, cross-app” advertising. Partners we or others work with to do the above may track your activities over time (including across different apps or websites) by collecting information through automated means. They may also use this information, and other information
they receive from us or other sources, to deliver advertisements. Suppose you are interested in more information about tailored browser advertising and how you
can generally control cookies from being put on your computer to deliver tailored marketing.
In that case, you may visit the Network Advertising Initiative’s Consumer Opt-Out Link or the Digital Advertising Alliance’s Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt-out of Google Analytics for Display Advertising or customize Google Display Network
ads, you can visit the Google Ads Settings page. You can also opt-out of cross-app advertising by following the instructions for your operating system (iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices). Please note that to the extent advertising technology is integrated into the Platform, you may still receive advertising content even if you opt-out of tailored advertising. In that case, the advertising content will just not be tailored to your interests.

Also, we do not control any of the above opt-out links. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites, accessible by the above links.

Social Media Usage
You may choose to enable or log in to our Platform via various online services, including social networking services like Facebook and Google. Our Services also may enable you to access social networking services such as Facebook, Twitter, Instagram, or Snapchat (collectively, Social Network”) directly or indirectly through our Platform.
When you link a Social Network account to Smarty Delivery or log into our Platform using your Social Network account, we may collect relevant Personal Information necessary to enable our Platform access that Social Network and your data contained within that Social Network. We also may share your information with the operator of that Social Network to facilitate or enhance the delivery of that Social Network or other services to you. A Social Network may provide us with access to certain information you have provided to them. We will use, store, and disclose such information per this Privacy Policy.

Additionally, a Social Network may automatically collect information about your use of our Platform. How a Social Network collects, uses, stores, and discloses the policies of such third parties govern your information. Smarty Delivery shall have no liability or responsibility for the privacy practices or other actions of any Social Network that may be enabled within our Platform. You may also have the option of posting your activities on our Platform and other content to a Social Network when you access content through our Platform. For example, you may post to Facebook that you placed an order with Smarty Delivery. Keep in mind that your usage of Social Network features is governed by applicable Social Networks and not by Smarty Delivery and may be visible or accessible to the public.

Your Choices
In addition to other choices described in this Privacy Policy and the Platform, you have other choices regarding your information:
Profile Information: You can update your profile information through your profile settings. If you need to change your account’s email address, please contact us via our Call Centre on (233) 32- 204-9659.

Location Information: While you can prevent your device from sharing location information at any time through your device s operating system settings, Customer and Courier location is core to our Platform, and without it, you may not be able to use our Platform successfully.

Email Subscriptions: You can always unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out from receiving promotional messages from us, you will continue to receive administrative messages.

Account Deletion: If you would like to delete your Smarty Delivery account, please contact us through our Call Centre on (233) 32-204-9659 with your request. If you choose to delete your account, we will delete it for you. However, we may retain certain information to collect any fees owed, resolve disputes, troubleshoot problems, analyze usage of the Platform, assist with any investigations, prevent fraud, enforce our Terms of Service, or take other actions as required or permitted by law or regulations.

Third-Party Links
Our Platform may contain links to other websites, products, or services that we do not control. Please be aware that we are not responsible for the privacy practices of such third parties. We encourage you to read their privacy policies before giving them your information.

Data Security
We are committed to protecting your information. We use administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. Unfortunately, no security measures can be 100% secure, so we cannot guarantee the security of Users” data. While we do our best to protect your information, you are also responsible for protecting your information by, for example, protecting your account credentials. If you have any reason to believe that your account has been compromised, please notify us immediately through our Call Centre on (233) 32-204-9659.

Children s Privacy
Smarty Delivery is not directed to children, and we do not knowingly collect personal information from children under 13. If you believe that a child under 13 years has given us personal information, please contact us via our Call Centre on (233) 32-204-9659.

Consent to Transfer
Our computer systems are currently based in Ghana, so your data will be processed by us in Ghana, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. If you create an account with the Platform as a visitor from outside Ghana, you agree to this Privacy Policy by using the Platform. You consent to the transfer of all such information to Ghana, which may not offer a level of protection equivalent to that required in certain other countries, and to processing that information as described in this Privacy Policy.

Changes to Our Privacy Policy
We may make changes to this Privacy Policy from time to time. If we make any changes, we will revise the “Last Updated” date at the top of this Privacy Policy. If we make any material changes, we will let you know through the Platform, email, or other communication. We encourage Users to read this Privacy Policy periodically to stay up-to-date about our privacy practices. As long as you use the Platform, you agree to this Privacy Policy and any updates we make to it.

Contact information
Feel free to contact us at any time with any questions or comments about this Privacy Policy, your personal information, our use and sharing practices, or your choices regarding your information by contacting us at our Call Centre at (233) 32-204-9659