SMARTDASH PRIVACY POLICY
Applies to SmartDash, SmartDasher and Order Manage
Effective Date: 18th November 2026
Last Updated: 2nd September 2026
1. Introduction
SmartDash is a technology-enabled ordering, delivery, logistics and marketplace platform operated by SmartLogic Tech (“SmartLogic Tech,” “SmartDash,” “we,” “our,” or “us”).
This Privacy Policy explains how we collect, use, process, store, disclose, protect and otherwise handle personal data when individuals interact with:
- the SmartDash customer application;
- the SmartDasher delivery-partner application;
- the Order Manage merchant application/portal;
- SmartDash websites and administrative portals;
- customer and merchant support systems;
- delivery and logistics systems;
- communications systems;
- payment integrations;
- APIs and related SmartDash technology and services.
We are committed to processing personal data lawfully, fairly, transparently and securely.
Our privacy program is intended to operate in accordance with the laws of the Republic of Ghana, including the Data Protection Act, 2012 (Act 843) and other applicable Ghanaian laws and regulations.
2. Scope
This Privacy Policy applies to personal data relating to:
- customers;
- prospective customers;
- SmartDash users;
- SmartDasher applicants;
- approved Dashers and delivery partners;
- merchants;
- merchant employees and representatives;
- business partners;
- support users;
- website visitors; and
- other individuals whose information is processed through SmartDash.
Different information may be collected depending upon the SmartDash service being used.
3. Information We May Collect
3.1 Account and Identity Information
We may collect:
- full name;
- username;
- email address;
- telephone number;
- profile photograph;
- account identifiers;
- date of birth where required;
- authentication information;
- verification status;
- business or merchant information; and
- other information necessary to create or maintain an account.
3.2 SmartDasher Information
For individuals applying to provide delivery services, we may collect information reasonably necessary for onboarding, verification, safety, compliance and administration, including:
- legal name;
- telephone number;
- email address;
- profile photograph;
- date of birth;
- residential or contact information;
- government-issued identification information;
- driver's licence information where applicable;
- vehicle information;
- vehicle registration information;
- insurance information where required;
- delivery history;
- account status;
- ratings and service-quality information;
- payment or payout information;
- compliance documentation; and
- information submitted during identity or eligibility verification.
SmartDash may require additional verification where reasonably necessary to protect customers, merchants, Dashers, SmartDash or the public.
3.3 Merchant Information
Through Order Manage and related merchant systems, we may collect:
- business name;
- business registration information;
- merchant address;
- contact persons;
- telephone numbers;
- email addresses;
- store information;
- menu and product information;
- bank or payout information;
- transaction information;
- order records;
- merchant performance information;
- support communications; and
- information required for verification, fraud prevention or regulatory compliance.
3.4 Order and Transaction Information
When an order is created or processed, we may collect:
- order number;
- items purchased;
- merchant;
- prices;
- discounts;
- taxes;
- fees;
- delivery charges;
- payment status;
- payment method information or payment tokens;
- delivery instructions;
- pickup information;
- delivery destination;
- order timestamps;
- cancellations;
- refunds;
- disputes; and
- delivery status.
SmartDash should not intentionally store complete payment-card credentials where payment processing is handled by an authorised third-party payment provider.
3.5 Location Information
Location information is important to the operation of a delivery platform.
Subject to device permissions and applicable law, SmartDash and SmartDasher may process:
- GPS location;
- approximate location;
- pickup location;
- delivery destination;
- delivery route;
- Dasher location during an active delivery;
- location timestamps; and
- information necessary to estimate distance, arrival time and delivery progress.
For Dashers, location information may be processed while the Dasher is online, available for deliveries or completing an active delivery, depending on the application's configuration and permissions disclosed to the Dasher.
SmartDash will seek to limit location collection to what is reasonably necessary for legitimate platform operations, safety, fraud prevention, support and delivery services.
4. Device and Technical Information
We may automatically collect information such as:
- device type;
- operating system;
- application version;
- IP address;
- device identifiers;
- language;
- crash information;
- login timestamps;
- security events;
- application activity;
- diagnostic information; and
- network information.
This information may be used for security, authentication, troubleshooting, analytics, fraud prevention and service improvement.
5. Communications
When customers, merchants and Dashers communicate through SmartDash, we may process information associated with those communications.
SmartDash may use communication-routing technology designed to reduce unnecessary disclosure of personal telephone numbers.
For example, where technically implemented, a customer calling a Dasher or a Dasher calling a customer may communicate through a SmartDash-controlled or third-party communication service so that the recipient's private telephone number does not have to be displayed directly to the other party.
Communication metadata may be retained where reasonably necessary for:
- safety;
- fraud prevention;
- dispute resolution;
- delivery investigation;
- customer support;
- platform security; and
- compliance with law.
Where calls are recorded, monitored or transcribed, SmartDash will provide any notice or obtain any consent required by applicable law.
6. How We Use Personal Data
We may process personal data to:
- create and maintain accounts;
- authenticate users;
- verify identity;
- connect customers with merchants and Dashers;
- process orders;
- arrange pickups and deliveries;
- display delivery progress;
- calculate delivery distance and estimated arrival times;
- process payments and payouts;
- prevent fraud;
- detect account abuse;
- investigate suspicious transactions;
- protect users and merchants;
- provide customer support;
- resolve complaints and disputes;
- maintain platform security;
- communicate important service information;
- improve SmartDash services;
- perform analytics;
- maintain business and financial records;
- enforce our agreements;
- satisfy legal obligations; and
- protect the legal rights and legitimate interests of SmartLogic Tech and other parties.
7. Legal Basis and Lawful Processing
SmartDash will process personal data only where there is a lawful basis for doing so.
Depending on the circumstances, processing may be necessary:
- with the consent of the data subject;
- to enter into or perform a contract;
- to comply with a legal obligation;
- to protect legitimate interests where permitted by law;
- to protect the vital interests of an individual; or
- for another lawful purpose recognised under applicable Ghanaian law.
Where processing depends specifically upon consent, users may withdraw that consent subject to applicable law and the consequences of withdrawing permission for a service that requires the relevant information.
8. Data Minimisation
SmartDash intends to collect personal data that is adequate, relevant and reasonably necessary for the purposes for which it is collected.
We will seek to avoid collecting personal data that is unnecessary for legitimate SmartDash operations.
9. Sharing of Information
SmartDash does not sell personal information merely for financial gain as a data-broker business.
We may, however, disclose information where reasonably necessary to operate SmartDash.
Information may be shared with:
Merchants
A merchant may receive information necessary to prepare and fulfil an order.
Dashers
A Dasher may receive information reasonably necessary to collect and deliver an order, including relevant pickup and delivery information.
Customers
Customers may receive information necessary to identify or communicate with the assigned Dasher and track the delivery.
Service Providers
Information may be processed by contracted service providers supporting:
- cloud hosting;
- authentication;
- communications;
- mapping;
- location services;
- analytics;
- fraud prevention;
- customer support;
- cybersecurity;
- payments;
- notifications; and
- infrastructure.
Service providers are expected to process information only for authorised purposes and subject to appropriate confidentiality, security and contractual obligations.
Government and Law-Enforcement Authorities
SmartDash may disclose information when disclosure is lawfully required by:
- legislation;
- court order;
- warrant;
- regulatory requirement;
- lawful governmental request; or
- other legally enforceable process.
SmartDash may challenge or reject requests that we reasonably determine are invalid, unlawful, excessive or unsupported by proper legal authority.
10. Payment Information
Payments may be processed through third-party banks, mobile-money operators, payment gateways or payment service providers.
Where an external payment provider processes a transaction, that provider may independently process information according to its own legal and privacy obligations.
SmartDash may receive transaction identifiers, payment confirmation, payment status and other information necessary to administer an order without necessarily receiving or storing complete financial credentials.
11. Security
SmartDash will implement reasonable technical and organisational safeguards appropriate to the nature of the personal data being processed.
Measures may include:
- encryption in transit;
- encryption or protected storage where appropriate;
- access controls;
- authentication controls;
- role-based permissions;
- logging;
- monitoring;
- secure APIs;
- administrative access restrictions;
- backups;
- incident-response procedures;
- security testing;
- fraud-detection controls; and
- employee or contractor confidentiality requirements.
No electronic platform can guarantee absolute security. SmartDash nevertheless intends to maintain safeguards appropriate to the risks associated with the personal data it processes.
12. Security Incidents and Data Breaches
SmartDash will maintain procedures for responding to suspected or confirmed personal-data security incidents.
Where SmartDash determines that notification is legally required following unauthorised access to or acquisition of personal data, SmartDash will provide the required notifications to the appropriate regulatory authority and affected data subjects in accordance with applicable Ghanaian law.
13. Data Retention
SmartDash will retain personal data only for as long as reasonably necessary for the purpose for which it was collected or as required for:
- active account administration;
- delivery records;
- financial and accounting obligations;
- tax requirements;
- fraud prevention;
- safety investigations;
- dispute resolution;
- legal claims;
- regulatory obligations; and
- enforcement of agreements.
Different categories of information may have different retention periods.
When information is no longer reasonably required, SmartDash may delete, anonymise or securely dispose of it, subject to legal and operational requirements.
14. User Privacy Rights
Subject to applicable Ghanaian law, individuals may have rights concerning their personal data, including rights to:
- be informed about processing;
- request access to personal data;
- request correction of inaccurate information;
- object to certain processing;
- prevent certain processing;
- withdraw consent where processing depends on consent;
- object to direct marketing; and
- request that a decision with a significant effect is not based solely on automated processing, where applicable;
- request human reconsideration of an eligible automated decision; and
- make a complaint concerning the processing of personal data.
SmartDash may require reasonable identity verification before processing a privacy request.
14.1 Automated Decisions and Human Review
SmartDash may use automated tools to support fraud detection, safety review, order allocation, account security and platform-integrity decisions. Where a decision that significantly affects an individual is based solely on automated processing and applicable law provides a right of review, SmartDash will provide a way to request human reconsideration and submit relevant information.
SmartDash will handle an eligible reconsideration request within the period required by applicable law, including the applicable twenty-one-day period under the Data Protection Act, 2012 where that requirement applies.
15. Marketing Communications
SmartDash may send promotional communications only where legally permitted and, where required by Ghanaian law, after obtaining the recipient's prior consent.
Users may opt out of direct marketing communications using the unsubscribe or preference mechanisms provided by SmartDash.
An objection or withdrawal of marketing consent will be applied without requiring the user to close the SmartDash account. SmartDash will stop the affected direct marketing within the period required by law.
Opting out of marketing does not necessarily prevent SmartDash from sending essential transactional, account, security, delivery or legal communications.
16. Children's Privacy
SmartDash is not intended to permit children who lack legal capacity to independently enter into transactions through the platform.
Where age restrictions apply, SmartDash may restrict account creation or require appropriate authorisation.
SmartDash does not knowingly seek to collect children's personal information in violation of applicable law.
17. International Data Processing
SmartDash may use technology and service providers whose infrastructure operates outside Ghana.
Where personal data is transferred or processed internationally, SmartDash will seek to implement safeguards required under applicable Ghanaian data-protection law.
Service providers processing SmartDash personal data are expected to maintain appropriate confidentiality and security protections.
18. Fraud, Safety and Platform Integrity
SmartDash may process account, device, transaction, location and delivery information to identify:
- fraudulent orders;
- stolen accounts;
- payment abuse;
- false deliveries;
- account duplication;
- manipulation of delivery location;
- merchant fraud;
- Dasher fraud;
- unauthorised account access;
- abuse of promotions;
- threats to users; and
- other violations of SmartDash policies.
Where appropriate, SmartDash may suspend accounts or transactions while conducting an investigation.
19. Account Deletion
Users may request account deletion through available SmartDash account controls or by contacting SmartDash.
Deletion does not require SmartDash to erase information that must lawfully be retained for legal, financial, security, fraud-prevention, dispute or regulatory purposes.
Where retention is required, access may be restricted and the information retained only for the applicable purpose and period.
20. Changes to This Privacy Policy
SmartDash may update this Privacy Policy to reflect changes in:
- law;
- regulation;
- technology;
- platform functionality;
- security practices; or
- business operations.
Material changes may be communicated through the application, website, email, push notification or another appropriate method.
21. Governing Framework
This Privacy Policy is intended to be interpreted consistently with applicable laws of the Republic of Ghana, including the Data Protection Act, 2012 (Act 843), and other applicable legislation and regulatory requirements.
Nothing in this Privacy Policy is intended to waive or restrict a data subject's rights where those rights cannot lawfully be waived.
22. Contact SmartDash
Questions, complaints and privacy requests may be submitted to:
SmartLogic Tech / SmartDash
East Airport / Nungua 121
Digital Address: GZ-121-9506
Accra, Ghana
Website: smartlogictechs.com
Email: support@smartlogictechs.com
Use the subject line “Privacy Request” so the request can be directed to the appropriate privacy contact.
23. Regulatory Complaints
Individuals who believe their personal data rights have been violated may also have the right to lodge a complaint with the Data Protection Commission of Ghana, subject to the procedures established by the Commission.
Website: dataprotection.org.gh
24. Acceptance
By creating an account or using SmartDash services, users acknowledge that they have been provided access to this Privacy Policy.
Where consent is legally required for a particular processing activity, SmartDash will obtain that consent separately where appropriate.